Justice O'Connor wrote an opinion for herself, Chief Justice Rehnquist, and Justice Kennedy. Under the Eighth Amendment, a narrow proportionality principle applies to non-capital sentences. Before "Ewing," the Court had from time to time examined lengthy sentences imposed for relatively minor crimes. In "Rummel v. Estelle," the Court upheld a life sentence for obtaining $120.75 by false pretenses imposed on a three-time offender under Texas's recidivist statute. In "Solem v. Helm," the Court struck down a life without parole (LWOP) sentence imposed on a defendant who had committed a seventh non-violent felony. Most recently, in "Harmelin v. Michigan," the Court upheld a life without parole sentence imposed on a first-time offender convicted of possession of more than 650 grams of cocaine. Against this backdrop of case law, O'Connor said that the gross disproportionality principle contained in the Eighth Amendment would require striking down only an extreme noncapital sentence, such as a life sentence for overtime parking.