State v. Larsen-Smith, 807 N.W.2d 817

Larsen-Smith was sentenced to life without parole for first-degree manslaughter (Class C felony) following a fatal DUI-driven crash.
The offense occurred after a high-speed police chase; Larsen-Smith ran a red light and collided with a vehicle, killing its driver.
A blood draw about an hour after the crash showed a BAC of .12%.
Larsen-Smith had a long history of DUI offenses and prior incarcerations, with minimal time outside prison since age 18.
The circuit court imposed consecutive sentences: life without parole for manslaughter and ten years for DUI; defense challenged the sentence as cruel and unusual.
The issue presented is whether the life-without-parole sentence is grossly disproportionate to the crime under the Eighth Amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether life without parole for first-degree manslaughter is grossly disproportionate	Larsen-Smith argues disproportionality under the Eighth Amendment.	Larsen-Smith contends the sentence is excessive given his rehabilitation prospects.	No; within statutory maximum and not grossly disproportionate.

State v. Iannarelli, 2008 S.D. 121, 759 N.W.2d 122 (S.D. 2008) (gross disproportionality review is highly deferential to legislature and sentencing court)
State v. Bonner, 1998 S.D. 30, 577 N.W.2d 575 (S.D. 1998) (threshold gross disproportionality rarely established; extensive rehabilitation considerations not required here)
State v. Ramos, 1996 S.D. 37, 545 N.W.2d 817 (S.D. 1996) (life sentence justified where rehabilitation unlikely)
State v. Milk, 2000 S.D. 28, 607 N.W.2d 14 (S.D. 2000) (address rehabilitation prospects only after ruling on disproportionality)