n.17); (4) proportionality reviews should be informed by objective factors, id. at 1000 (citing Solem, 463 U.S. at 290); and (5) "the Eighth Amendment does not require strict proportionality between crime and sentence" but"[r]ather, it forbids only extreme sentences that are `grossly disproportionate' to the crime," id. at 1001 (citing Solem, 463 U.S. at 288, 303).

Relying on these "common principles," Justice Kennedy concluded that courts need not examine the second and third factors specified in Solem -- the intrajurisdictional and interjurisdictional reviews -- unless a "threshold comparison of the crime committed and the sentence imposed leads to an inference of gross disproportionality." Id . at 1005. While Justice White in his Harmelin dissent considered this "an abandonment of the second and third factors set forth in Solem," id. at 1020, Justice Kennedy argued that it was consistent with the Solem Court's "admonition that `a reviewing court rarely will be required to engage in extended analysis to determine that a sentence is not constitutionally disproportionate,' " id. at 1004 (citing Solem, 463 U.S. at 290 n.16).

The means by which Justice Kennedy decided that Harmelin's sentence did not violate the Eighth Amendment demonstrates the conformity between his proportionality analysis and that articulated by the Solem Court. Rather than emphasizing a different analytical framework, Justice Kennedy based his analysis on the more serious nature of Harmelin's offense. Justice Kennedy stressed that Harmelin's offense "threatened to cause grave harm to society" unlike "the relatively minor, nonviolent crime at issue in Solem ." Id. at 1002. Justice Kennedy further noted that the "[p]ossession, use, and distribution of illegal drugs represent `one of the greatest problems affecting the health and welfare of our population' " and that the quantity of cocaine that Harmelin possessed had "a potential yield of between 32,500 and 65,000 doses." Id. at 1002 (internal citations omitted). Thus, in concluding that Harmelin's sentence did not raise an inference of gross dis-

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