Christopher Jackson v. State, 12-17-00139-CR

Christopher Jackson pleaded guilty to obstruction/retaliation with two prior felony enhancements (burglary of a habitation; delivery of a controlled substance). The habitual-offender statute applied.
Pursuant to a plea agreement, the trial court placed Jackson on six years' deferred adjudication community supervision.
The State later moved to proceed with adjudication and revoke supervision; at the revocation hearing Jackson admitted several allegations and the court found them true.
The trial court revoked community supervision and sentenced Jackson to 25 years' imprisonment—the statutory minimum under the invoked habitual-offender enhancement.
Jackson appealed, arguing the 25-year sentence constituted cruel and unusual (grossly disproportionate) punishment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jackson's 25-year sentence is cruel and unusual (grossly disproportionate)	Jackson: 25 years is grossly disproportionate to his offense and violates Eighth Amendment protections	State: Sentence is within statutory range, is the legislative minimum for enhanced offense, and not constitutionally disproportionate	Court: Error not preserved, and in any event sentence not grossly disproportionate; affirmed

Rummel v. Estelle, 445 U.S. 263 (1980) (upheld life sentence under habitual-offender statute for relatively small thefts; supports deference to legislature on harsh recidivist sentences)
Solem v. Helm, 463 U.S. 277 (1983) (articulated three-part proportionality test for Eighth Amendment challenges)
Harmelin v. Michigan, 501 U.S. 957 (1991) (clarified proportionality analysis and prompted a threshold requirement showing gross disproportionality)
McGruder v. Puckett, 954 F.2d 313 (5th Cir. 1992) (applies Harmelin’s threshold approach to proportionality claims)
Rhoades v. State, 934 S.W.2d 113 (Tex. Crim. App. 1996) (procedural waiver: Eighth Amendment/Texas Constitution objections must be timely raised to preserve error)