Justice Kennedy pointed to the two aspects of Harmelin's sentence that might cause difficulty under the Eighth Amendment—the severity of the sentence, along with its mandatory nature. Life without parole is the second most severe sentence known to American law, after the death penalty. Yet Harmelin's crime was more severe than the crime at issue in "Solem". In "Solem", the Court struck down a life-without-parole sentence imposed for the crime of uttering a no-account check; Harmelin, however, was convicted of possessing 650 grams of cocaine. Uttering is "one of the most passive felonies a person could commit." The illegal drug trade, by contrast, begets a tremendous amount of violence. In view of these observations, a legislature could rationally conclude that a life sentence without parole is appropriate to deter others from distributing cocaine and to achieve an appropriate amount of retribution. Because Harmelin's crime was more serious than the crimes involved in other cases where the Court had confronted the constitutionality of a life sentence, Kennedy reasoned that it might be appropriate to dispense with the detailed "Solem" analysis. "A better reading of our cases leads to the conclusion that intrajurisdictional and interjurisdictional analyses are appropriate only in the rare case in which a threshold comparison of the crime committed and the sentence imposed leads to an inference of gross disproportionality."