Christi Lynn Coker v. State, 12-15-00161-CR

Appellant Christi Lynn Coker was placed on community supervision for state‑jail theft (value < $1,500) on September 5, 2014.
The State filed a motion to revoke that alleged prior convictions; a revocation hearing was held June 3, 2015.
The trial court revoked community supervision and sentenced Coker to 24 months’ confinement (maximum for a state‑jail felony).
Coker appealed, arguing the 24‑month sentence is grossly disproportionate in violation of the Eighth Amendment and the Texas Constitution.
The brief asks the appellate court to vacate the commitment and remand for a new punishment hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a 24‑month sentence for state‑jail theft is grossly disproportionate	Coker: 24 months is excessive given the offense facts, her criminal history, and that she initially received community supervision	State (implicit): sentence is within statutory range and supported by revocation	Trial court revoked probation and imposed 24 months; on appeal Coker seeks reversal—no appellate ruling included in this brief

Solem v. Helm, 463 U.S. 277 (1983) (established multi‑factor proportionality review for criminal sentences)
Harmelin v. Michigan, 501 U.S. 957 (1991) (revisited Eighth Amendment proportionality analysis)
McGruder v. Puckett, 954 F.2d 313 (5th Cir.) (1992) (advocates first asking whether a sentence is "grossly disproportionate" then comparing to other sentences)
Jackson v. State, 989 S.W.2d 842 (Tex. App. — Texarkana) (application of Eighth Amendment proportionality to sentences within statutory ranges)
Lilly v. State, 365 S.W.3d 321 (Ct. Crim. App.) (Texas authority on sentencing and proportionality issues)