What is the burden of proving that a habitual offender has not been sentenced to a life sentence?

Here, with respect to the first criterion, as we have explained in part III, ante, defendant's criminality was prolonged and consistent. His punishment was not grossly disproportionate in light of that record. (See People v. Poslof (2005) 126 Cal.App.4th 92, 109; People v. Meeks (2004) 123 Cal.App.4th 695, 709-710.)

With respect to the third criterion, most states have enhanced sentences for habitual offenders. (See People v. Martinez, supra, 71 Cal.App.4th at p. 1513.) Defendant bears the burden of proving "a significant disproportion between a

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