What is the federal and federal standard for determining proportionality under the Eighth Amendment?

The federal standard is virtually identical: "[A] court's proportionality analysis under the Eighth Amendment should be guided by objective criteria, including (i) the gravity of the offense and the harshness of the penalty; (ii) the sentences imposed on other criminals in the same jurisdiction; and (iii) the sentences imposed for commission of the same crime in other jurisdictions." (Solem v. Helm (1983) 463 U.S. 277, 292 (Solem).) While Solem held "no one factor will be dispositive in a given case" (id. at p. 291, fn. 17), Justice Kennedy has suggested the latter two factors need only be considered if the defendant makes a threshold showing on the first factor that "comparison of the crime committed and the sentence imposed leads to an inference of

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