Solem v. Helm, 463 U.S. 277 (1983), was a United States Supreme Court case concerned with the scope of the Eighth Amendment protection from cruel and unusual punishment.

Helm, who had written a check from a fictitious account and had reached his seventh nonviolent felony conviction since 1964, received a mandatory sentence, under South Dakota law at that time, to life in prison with no parole.

Justice Powell reasoned that Helm had "received the penultimate sentence for relatively minor criminal conduct."

The language of the opinion, however, refrained from striking down state statutes setting minimum sentencing guidelines for recidivism.

The majority opinion only called for exceptions to the statutes protecting the constitutional freedom from cruel and unusual punishment.