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Nomos and Nullification: A Coverian View of New York's Habitual Offender Law, 1926 to 1936
American Criminal Law Review  (IF3.455),  Pub Date : 2019-03-01, DOI:
Caleb J. Stevens

In 1926, New York passed a habitual offender law that mandated life sentences for a fourth felony conviction, regardless of severity. Called the Baumes Law, after its principal author and advocate New York Senator Caleb Baumes, the law remains one of the harshest habitual offender laws ever passed in the United States. Until its amendment in 1936, the law launched an intense policy debate that in many ways reflects the contemporary debate over Three Strikes legislation and high U.S. incarceration rates.