their Eighth Amendment analyses. For example, in MacLean v. State Board of Retirement, 432 Mass. 339, 733 N.E.2d 1053 (Mass.2000), the Supreme Judicial Court of Massachusetts examined the gravity of the offense, the maximum fine that could be imposed, the extent of the unlawful activity, the amount of illegal gain in relation to the penalty, and the harm caused. See id. at 1061-62; see also Bajakajian, 524 U.S. at 339-40, 118 S.Ct. 2028 (comparing the amount of the forfeiture, $357,144, to the gravity of the offense; examining also the harm that the respondent caused); United States v. Lippert, 148 F.3d 974, 978 (8th Cir.1998) (taking into account maximum fine that could have been imposed). ¶ 19 Applying these factors here, we conclude that the $135,000 fine asses th Cir.1995) (<HOLDING>), with Commonwealth v. 5444 Spruce St., 574 Pa.
holding the measure of damages is the difference between the value of the automobile prior to the upset and its value when prepared and presented to the plaintiff for acceptance holding that forfeiture of farm worth 245000 was not grossly disproportional because the farms value was roughly equal to the wholesale value of the marijuana that was brought to the farm or distributed from the farm during the life of the conspiracy holding determination of property value in case to decide if assessed value was excessive is not a liquidated demand where only evidence of property value was the conclusory allegation of value in plaintiffs unsworn petition holding that the failure to place a dollar value on a possible decrease in property value was not unreasonable holding the aggregate value of the land and its improvements is the controlling value