California, United States of America
The following excerpt is from People v. Zamora, 230 Cal.App.3d 1627, 282 Cal.Rptr. 100 (Cal. App. 1991):
Defendant contends his sentence is disproportionate to his culpability because he was at most a passive participant in his wife's illegal activities. Relying on People v. Dillon (1983) 34 Cal.3d 441, 194 Cal.Rptr. 390, 668 P.2d 697, defendant contends that, under the circumstances, his four-year, eight-month sentence constitutes cruel and unusual punishment. Although framed and presented as a constitutional issue, the essence [230 Cal.App.3d 1635] of defendant's argument is contained in the following passage from his opening brief:
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