What is the test for determining whether a defendant's sentence is proportionate to his individual culpability?

It is equally clear that our state constitutional proscription against cruel or unusual punishment (Cal. Const., art. I, 17) requires a determination whether the punishment in this case is proportionate to the defendant's individual culpability. However, to do so may require a comparison of defendant's conduct with that of others involved in the same venture, i.e., intracase proportionality. We conducted that type of analysis in People v. Dillon (1983) 34 Cal.3d 441, 488, 194 Cal.Rptr. 390, 668 P.2d 697: "In short, defendant received the

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I also recently urged intracase proportionality review in People v. Adcox (1988) 47 Cal.3d 207, 276-277, 253 Cal.Rptr. 55, 763 P.2d 906. There three persons, in my view equally responsible for the death of the victim, received widely disparate sentences.