83 N.Y.2d 477 (1994)
Mandatory minimum sentences for drug offenses are constitutional unless they are grossly disproportionate to the crime, considering the gravity of the offense and the character of the offender.
Summary
Angela Thompson, a 17-year-old, was convicted of selling cocaine and sentenced to 8 years to life. The trial court found that the mandatory minimum sentence of 15 years to life would be cruel and unusual punishment. The Appellate Division affirmed. The Court of Appeals reversed, holding that the mandatory minimum sentence did not constitute cruel and unusual punishment in this case because her actions indicated a high degree of culpability and the legislature’s sentencing decision was not irrationally severe.
Facts
Thompson, 17, sold 214 vials of cocaine to an undercover officer for $2,000 in a known drug location. The sale exceeded the threshold for a class A-I felony by a small amount (2.13 grams). She promised to “take care of” the officer the next time he came. Thompson’s uncle, Norman Little, was a major drug dealer, and Thompson was employed in his operation.
Procedural History
Thompson was indicted and convicted of a class A-I felony in Supreme Court, New York County. The trial court sentenced her to 8 years to life, finding the mandatory minimum of 15 years to life would be cruel and unusual punishment. The Appellate Division affirmed. The People appealed to the New York Court of Appeals.
Issue(s)
Whether imposing the mandatory minimum sentence of 15 years to life for a class A-I felony conviction on Thompson constitutes cruel and unusual punishment under the Eighth Amendment of the U.S. Constitution and Article I, Section 5 of the New York Constitution.
Holding
No, because the mandatory minimum sentence is not grossly disproportionate to the crime and does not constitute cruel and unusual punishment, considering the gravity of the offense and the character of the offender.
Court’s Reasoning
The Court relied on People v. Broadie, which upheld the facial and as-applied validity of mandatory sentences for drug offenses, while acknowledging rare cases where it might be unconstitutionally applied. The Court applied a gross disproportionality standard, considering the gravity of the offense and the character of the offender. Drug dealing is a grave offense because of its harm to society. The court considered that “drug-related crimes may be much more prevalent…requiring greater isolation and deterrence” (People v. Broadie, 37 N.Y.2d at 116). Thompson’s conduct showed significant culpability; she made a direct sale, haggled over the quantity, and promised future service, showing she was not an “accidental offender.” Although Thompson was young, the legislature consciously extended the A-I felony mandatory minimums to youths in her age category. The court distinguished Thompson’s direct sale of a significant quantity of drugs from the defendant in People v. Jones, who was merely a low-level “millhand.” The court stated that the legislature could rationally determine that teenage drug dealers pose a serious threat to society. The dissent argued for a more nuanced approach considering factors like the defendant’s role in the operation, her age, and the disparity between her sentence and that of her uncle. Ultimately, the majority deferred to the legislature’s judgment, holding that reform of sentencing policy should be legislative, not judicial.