State v. Alford

The defendant, who had three prior DUI convictions when he was stopped for speeding, entered a plea agreement that required he serve thirteen months in the state’s Department of Corrections. Two months later, the Montana Supreme Court held in State v. Gibbons that mandatory minimum fines for multiple-offense DUIs were unconstitutiuonal. The defendant subsequently challenged his sentence, arguing that the mandatory minimum custodial sentence of thirteen months was unconstitutional. The court disagreed, facially upholding Article II, Section 22 of the Montana Constitution under the states’s Cruel and Unusual Punishment Clause because it is rationally related to the state legislature’s sentencing objectives and is appropriately commensurate with the gravity of the offense.