decision was therefore not “contrary to” the governing legal principles set forth in our cases. Andrade’s sentence also was not materially indistinguishable from the facts in Solem. The facts here fall in between the facts in Rummel and the facts in Solem. Solem involved a sentence of life in prison without the possibility of parole. 463 U. S., at 279. The defendant in Rummel was sentenced to life in prison with the possibility of parole. 445 U. S., at 267. Here, Andrade retains the possibility of parole. Solem acknowledged that Rummel would apply in a “similar factual situation.” 463 U. S., at 304, n. 32. And while this case resembles to some degree both Rummel and Solem, it is not materially indistinguishable from either. Cf. Ewing v. California, ante, at 40 (Breyer, J., dissenting) (<HOLDING>). Consequently, the state court did not
recognizing difference between tolling and equitable estoppel recognizing conflict between circuits recognizing distinction between tolling and estoppel recognizing a twilight zone between solem and rummel recognizing possible conflict between the cases