cases in Supreme Court Following the Robinson decision, the Court upheld a law criminalizing public drunkenness under Powell v. Texas, despite the argument advanced by some members of the Court that Robinson held that it was not criminal to give in to the irresistible compulsions of a "disease" (alcoholism) "Disproportionality" cases based on Robinson The first case in which the Supreme Court applied the expanded "cruel and unusual" principle of Robinson to cases in which the penalty was considered disproportionate or excessive relative to the crime was Coker v. Georgia. The Court held that, because of the disproportionality, it was a violation of the Cruel and Unusual Punishments Clause to impose capital punishment for rape of an adult woman. In Rummel v. Estelle, the Court held that it did not constitute cruel and unusual punishment to impose a life sentence, under a recidivist statute, upon a defendant who had been convicted, successively, of fraudulent use of a credit card to obtain $80 worth of goods or services, passing a forged check in the amount of $28.36, and obtaining $120.75 by false pretenses. The Court said that "one could argue without fear of contradiction by any decision of this Court that for crimes concededly classified and classifiable as felonies, that is, as punishable by significant terms of imprisonment in a state penitentiary, the length of the sentence actually imposed is purely a matter of legislative prerogative." Despite its unwillingness to find unconstitutional disproportionality, the Court conceded, ""This is not to say that a proportionality principle would not come into play in the extreme example mentioned by the dissent, . . . if a legislature made overtime parking a felony punishable by life imprisonment." In Solem v. Helm, a 5-4 majority set a conviction aside under the Eighth Amendment, because it was disproportionate—a sentence of life imprisonment without possibility of parole, imposed under a recidivist statute for successive offenses that included three convictions of third-degree burglary, one of obtaining money by false pretenses, one of grand larceny, one of third-offense driving while intoxicated, and one of writing a "no account" check with intent to defraud. The Court later characterized this decision as "scarcely the expression of clear and well accepted constitutional law." In Harmelin v. Michigan, the Court examined the historical basis for the Eighth Amendment, found it based on the "cruel and unusual Punishments" provision of the English Declaration of Rights