v. Estelle, , the Court upheld a life sentence with the possibility of parole imposed per Texas's three strikes law for fraud crimes totaling $230. A few months later, Rummel challenged his sentence for ineffective assistance of counsel, his appeal was upheld, and as part of a plea bargain Rummel pled guilty to theft and was released for time served. In Harmelin v. Michigan, , the Court upheld a life sentence without the possibility of parole for possession of 672 grams (1.5 pounds) of cocaine. In Lockyer v. Andrade, , the Court upheld a 50 years to life sentence with the possibility of parole imposed under California's three strikes law when the defendant was convicted of shoplifting videotapes worth a total of about $150. In Baze v. Rees, the Court upheld Kentucky's execution protocol using a three-drug cocktail. In Glossip v. Gross the Court upheld the use of lethal injections using the drug midazolam. In Bucklew v. Precythe, the Court ruled that when a convict sentenced to death challenges the State's method of execution due to claims of excessive pain, the convict must show that other alternative methods of execution exist and clearly demonstrate they would cause less pain than the state-determined one. The Supreme Court also held in Bucklew that the Due Process Clause expressly allows the death penalty in the United States because "the Fifth Amendment, added to the Constitution at the same time as the Eighth, expressly contemplates that a defendant may be tried for a ‘capital’ crime and ‘deprived of life’ as a penalty, so long as proper procedures are followed". The Court also explicitly said: "The Constitution allows capital punishment. [...] Nor did the later addition of the Eighth Amendment outlaw the practice. [...] Of course, that doesn’t mean the American people must continue to use the death penalty. The same Constitution that permits States to authorize capital punishment also allows them to outlaw it. But it does mean that the judiciary bears no license to end a debate reserved for the people and their representatives. While the Eighth Amendment doesn’t forbid capital punishment, it does speak to how States may carry out that punishment, prohibiting methods that are “cruel and unusual.”" Evolving standards of decency In Trop v. Dulles, , Chief Justice Earl Warren said: "The [Eighth] Amendment must draw its meaning from the evolving standards of decency that mark the progress of a