The Court's narrow ruling left a major question of Eighth Amendment law unresolved. Since the Court's decision in "Gregg v. Georgia", the Court had incorporated a detailed proportionality analysis into the cruel and unusual punishment analysis required in capital cases. The defendant Ronald Harmelin directly asked the Court to extend the reach of that analysis to noncapital cases such as his. Although five Justices agreed that Harmelin's sentence was not unconstitutionally cruel and unusual, six Justices agreed that the Cruel and Unusual Punishment Clause bore "some kind" of proportionality analysis. Yet among those six, three supported a proportionality principle that is highly deferential to legislative judgments, while three others supported a more searching proportionality analysis that would have struck down Michigan's mandatory life-without-parole sentence for possessing more than of cocaine ().