Rummel v. Estelle, 445 U.S. 263 (1980), (sometimes erroneously cited as Rummel v. Estell) was a United States Supreme Court case in which the Court upheld a life sentence with the possibility of parole under Texas' three strikes law for a felony fraud crime, where the offense and the defendant's two prior offenses involved approximately $230 of fraudulent activity (worth $847 in 2023 dollars, or about four 40-hour weeks at the contemporary Texas minimum wage of $1.40/hour).

However, a divided panel of the United States Court of Appeals for the Fifth Circuit reversed the sentence on grounds that it "was 'so grossly disproportionate' to his offenses as to constitute cruel and unusual punishment."

The Court noted, however, that Washington and West Virginia also imposed mandatory life sentences for habitual offenders, so Texas was not as harsh as other states.

However, as the question posed was "whether those procedures fall below the minimum level the [Constitution] will tolerate", Justice Stewart was "constrained to join the opinion and judgment of the Court.

"[1] Justice Powell delivered a dissenting opinion, arguing that "(i) the penalty for a noncapital offense may be unconstitutionally disproportionate, (ii) the possibility of parole should not be considered in assessing the nature of the punishment, (iii) a mandatory life sentence is grossly disproportionate as applied to petitioner, and (iv) the conclusion that this petitioner has suffered a violation of his Eighth Amendment rights is compatible with principles of judicial restraint and federalism.

[6] The Rummel case is commonly used by Texas courts as a proportionality test (if requested on appeal, usually by the defendant) to determine whether, under the Eighth Amendment, a sentence is excessive.