Finally, White argued that the "Solem" test works well in practice. Simply because courts will be reviewing sentences for proportionality does not mean that courts will strike them down with great frequency. "Solem" requires a certain amount of deference to the legislature, and courts have proven able to apply that amount of deference. And although Scalia concedes that an egregious prison term—such as life in prison for overtime parking—would be unconstitutional, White faults him for striking such extreme punishments down in a principled manner. White also argues that adopting Scalia's view of the proportionality requirement would strike at the foundation of the Court's capital punishment jurisprudence, much of which would then "rest on quicksand".