Keithlynn Germaine Williams v. State, 12-17-00044-CR

Appellant Keithlynn Germaine Williams pleaded guilty to third-degree felony deadly conduct and received a ten-year sentence, suspended in favor of ten years' community supervision pursuant to a plea agreement.
The State filed a motion to revoke supervision alleging violations; at the revocation hearing Williams admitted several allegations as true.
The trial court found the allegations true, revoked community supervision, and sentenced Williams to four years' imprisonment.
Williams appealed, arguing his four-year sentence constituted cruel and unusual punishment (grossly disproportionate).
The Court of Appeals considered preservation of error and the merits of the Eighth Amendment proportionality claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a four-year sentence after revocation is cruel and unusual (grossly disproportionate)	Williams: four-year term is grossly disproportionate to his offense	State: sentence is within statutory range and not disproportionate; error not preserved	Court: Issue not preserved but, on merits, sentence is not grossly disproportionate and is constitutional

Rummel v. Estelle, 445 U.S. 263 (1980) (upheld severe life sentence under habitual-offender statute and framed proportionality analysis)
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 need for threshold showing of gross disproportionality)
Rhoades v. State, 934 S.W.2d 113 (Tex. Crim. App. 1996) (discussed waiver of constitutional complaints not timely raised)
McGruder v. Puckett, 954 F.2d 313 (5th Cir. 1992) (applied Harmelin-modified proportionality analysis)