Because White disagreed that "Solem" should be abandoned, he proceeded to apply it to Harmelin's sentence, and concluded that Harmelin's sentence was unconstitutional. First, because Michigan has no death penalty, the life-without-parole sentence for possession of of cocaine was the most severe available under Michigan law. Second, it reserved the sentence for only one other crime—first-degree murder. Third, no other jurisdiction imposed such a severe sentence for possession of 650 grams of cocaine. Alabama came close, White observed, but only when the defendant possessed of cocaine. Thus, White concluded, "Solem" required the Court to strike down Harmelin's sentence.