Three-strikes law

Last updated

In the United States, habitual offender laws [1] (commonly referred to as three-strikes laws) have been implemented since at least 1952, [2] and are part of the United States Justice Department's Anti-Violence Strategy. [3] [4] These laws require a person who is convicted of an offense and who has one or two other previous serious convictions to serve a mandatory life sentence in prison, with or without parole depending on the jurisdiction. [5] [6] The purpose of the laws is to drastically increase the punishment of those who continue to commit offenses after being convicted of one or two serious crimes. [7]


Twenty-eight states have some form of a "three-strikes" law. A person accused under such laws is referred to in a few states (notably Connecticut and Kansas) as a "persistent offender", while Missouri uses the unique term "prior and persistent offender". In most jurisdictions, only crimes at the felony level qualify as serious offenses. And it may turn on which felonies are defined as being serious, which may vary depending on the jurisdiction, in particular, whether a subject felony must include violence or not.

The three-strikes law significantly increases the prison sentences of persons convicted of a felony who have been previously convicted of two or more violent crimes or serious felonies, and limits the ability of these offenders to receive a punishment other than a life sentence.

The expression "Three strikes and you are out" is derived from baseball, where a batter against whom three strikes are recorded strikes out.


The practice of imposing longer prison sentences on repeat offenders (versus first-time offenders who commit the same crime) is present throughout most of American history, as judges often take into consideration prior offenses when sentencing. However, there is a more recent history of mandatory prison sentences for repeat offenders. [8] For example, New York State had a long-standing Persistent Felony Offender law dating back to the early 20th century [9] (partially ruled unconstitutional in 2010, [10] [11] but reaffirmed en banc shortly after [12] [13] ). But such sentences were not compulsory in each case, and judges had much more discretion as to what term of incarceration should be imposed.

During Prohibition the state of Michigan enacted one of the harshest laws against bootlegging in the nation. The law required a life sentence for those violating liquor laws for the fourth time. [14] In late 1928 Etta Mae Miller, a mother of four was found guilty under this law, sparking outrage. [15]

The first true "three-strikes" law was passed in 1993, when Washington voters approved Initiative 593. California passed its own in 1994, when their voters passed Proposition 184 [16] by an overwhelming majority, with 72% in favor and 28% against. The initiative proposed to the voters had the title of Three Strikes and You're Out, referring to de facto life imprisonment after being convicted of three violent or serious felonies which are listed under California Penal Code section 1192.7. [17]

The concept swiftly spread to other states, but none of them chose to adopt a law as sweeping as California's. By 2004, twenty-six states and the federal government had laws that satisfy the general criteria for designation as "three-strikes" statutes—namely, that a third felony conviction brings a sentence of 20 to life where 20 years must be served before becoming parole eligible. A 1997 study found that in California, "the three-strikes law did not decrease serious crime or petty theft rates below the level expected on the basis of preexisting trends." [18]

Three-strikes laws have been cited as an example of the McDonaldization of punishment, in which the focus of criminological and penological interest has shifted away from retribution and treatment tailored to the individual offender and toward the control of high-risk groups based on aggregations and statistical averages. A three-strikes system achieves uniformity in punishment of criminals in a certain class (viz., three-time offenders) in a way that is analogous to how a fast food restaurant achieves uniformity of its product. [19]

Enactment by states

The following states have enacted three-strikes laws:

Georgia, South Carolina and Tennessee are the only states in the United States to date that have "two strikes" laws for the most serious violent crimes, such as murder, rape, serious cases of robbery, etc. and they all mandate a sentence of life imprisonment without parole for a conviction of any such crimes a second time around.


The exact application of the three-strikes laws varies considerably from state to state, but the laws call for life sentences for at least 25 years on their third strike. In the state of Maryland, any person who receives their fourth strike for any crime of violence will automatically be sentenced to life imprisonment without parole.

Most states require one or more of the three felony convictions to be for violent crimes in order for the mandatory sentence to be pronounced. Crimes that fall under the category of "violent" include: murder, kidnapping, sexual abuse, rape, aggravated robbery, and aggravated assault. [29]

Some states include additional, lesser offenses that one would not normally see as violent. [30] For example, the list of crimes that count as serious or violent in the state of California is much longer than that of other states, and consists of many lesser offenses that include: firearm violations, burglary, simple robbery, arson, and providing hard drugs to a minor, and drug possession. [31] As another example, Texas does not require any of the three felony convictions to be violent, but specifically excludes certain "state jail felonies" from being counted for enhancement purposes. [32]

One application of a three-strikes law was the Leonardo Andrade case in California in 2009. In this case, Leandro Andrade attempted to rob $153 in videotapes from two San Bernardino K-Mart stores. He was charged under California's three-strikes law because of his criminal history concerning drugs and other burglaries. Because of his past criminal records, he was sentenced to 50 years in prison with no parole after this last burglary of K-Mart. Although this sentencing was disputed by Erwin Chemerinsky, who represented Andrade, as cruel and unusual punishment under the 8th Amendment, the Supreme Court ruled in support for the life sentencing. [33]

In 1995, Sioux City, Iowa native Tommy Lee Farmer, a professional criminal who had served 43 years in prison for murder and armed robbery was the first person in the United States to be convicted under the federal three-strikes law when he was sentenced to life in prison for an attempted robbery at an eastern Iowa convenience store. He was prosecuted by Stephen J. Rapp, a US Attorney appointed by Clinton. [34] The sentencing was considered so significant that President Bill Clinton interrupted a vacation to make a press statement about it. [35]

Another example of the three-strikes law involves Timothy L. Tyler who, in 1992 at age 24, was sentenced to life in prison without parole when his third conviction (a federal offense) triggered the federal three-strikes law, even though his two prior convictions were not considered violent, and neither conviction resulted in any prison time served.


United States

Analyzing the effect of the Three-Strikes legislation as a means of deterrence and incapacitation, a 2004 study found that the Three-Strikes Law did not have a very significant effect on deterrence of crime, [36] but also that this ineffectiveness may be due to the diminishing marginal returns associated with having pre-existing repeat offender laws in place. [37]

Another study found that arrest rates in California were up to 20% lower for the group of offenders convicted of two-strike eligible offenses, compared to those convicted of one-strike eligible offenses. The study concluded that the three-strikes policy was deterring recidivists from committing crimes. California has seen a reduction in criminal activity, and "Stolzenberg and D’Alessio found that serious crime in California’s 10 largest cities collectively had dropped 15% during the 3-year post-intervention period". [38]

A study written by Robert Parker, director of the Presley Center for Crime and Justice Studies at UC Riverside, states that violent crime began falling almost two years before California's three-strikes law was enacted in 1994. The study argues that the decrease in crime is linked to lower alcohol consumption and lower rates of unemployment. [39]

A 2007 study from the Vera Institute of Justice in New York examined the effectiveness of incapacitation under all forms of sentencing. The study estimated that if US incarceration rates were increased by 10 percent, the crime rate would decrease by at least 2 percent. However, this action would be extremely costly to implement. [40]

Another study found that three-strikes laws discourage criminals from committing misdemeanors for fear of a life prison sentence. Although this deters crime and contributes to lower crime rates, the laws may possibly push previously convicted criminals to commit more serious offenses. The study's author argues that this is so because under such laws, felons realize that they could face a long jail sentence for their next crime regardless of type, and therefore they have little to lose by committing serious crimes rather than minor offenses. Through these findings, the study weighs both the pros and cons for the law. [41]

A 2015 study found that three-strikes laws were associated with a 33% increase in the risk of fatal assaults on law enforcement officers. [42]

New Zealand

In 2010, New Zealand enacted a similar three-strikes law called the Sentencing and Parole Reform Act 2010. [43] The bill was sponsored by Police and Corrections Minister Judith Collins from the ruling National Party. It was passed into law by the National and ACT parties but was opposed by the opposition Labour and Green parties, and National's support partner, the Māori Party. [44] While the Sentencing and Parole Act was supported by conservative groups such as the Sensible Sentencing Trust, critics attacked the law for promoting penal populism and disproportionately targeting the Māori community. [45] [46]

In early June 2018, an attempt by the Labour-led coalition government to overturn the Sentencing and Parole Act was blocked by Labour's support partner New Zealand First and the opposition National and ACT parties. NZ First had indicated its opposition to overturning the three-strikes bill, prompting Justice Minister Andrew Little to abandon the attempt. [47] [48] [49]

On 11 November 2021, the Minister of Justice Kris Faafoi announced that the Government was introducing legislation to repeal the Sentencing and Parole Reform Act. [50] On 9 August 2022, the New Zealand Parliament passed the Three Strikes Legislation Repeal Bill, which repealed the Sentencing and Parole Reform Act. The repeal legislation was supported by the Labour, Green, and Māori parties but was opposed by the National and ACT parties, who stated that they would reinstate three-strikes legislation if re-elected in 2023. [51] [52]


Some criticisms of three-strikes laws are that they clog the court system with defendants taking cases to trial in an attempt to avoid life sentences, and clog jails with defendants who must be detained while waiting for these trials because the likelihood of a life sentence makes them a flight risk. Life imprisonment is also an expensive correctional option, and potentially inefficient given that many prisoners serving these sentences are elderly and therefore both costly to provide health care services to and statistically at low risk of recidivism. Dependents of prisoners serving long sentences may also become burdensome on welfare services.

Prosecutors have also sometimes evaded the three-strikes laws by processing arrests as parole violations rather than new offenses, or by bringing misdemeanor charges when a felony charge would have been legally justified. There is also potential for witnesses to refuse to testify, and juries to refuse to convict, if they want to keep a defendant from receiving a life sentence; this can introduce disparities in punishments, defeating the goal of treating third-time offenders uniformly. Sometimes a non-violent felony also counts as a third strike, which thus would result in a disproportionate penalty. Three-strikes laws have thus also been criticized for imposing disproportionate penalties and focusing too much on street crime rather than white-collar crime. [19]

See also

Related Research Articles

A felony is traditionally considered a crime of high seriousness, whereas a misdemeanor is regarded as less serious. The term "felony" originated from English common law to describe an offense that resulted in the confiscation of a convicted person's land and goods, to which additional punishments including capital punishment could be added; other crimes were called misdemeanors. Following conviction of a felony in a court of law, a person may be described as a felon or a convicted felon.

Life imprisonment is any sentence of imprisonment for a crime under which convicted criminals are to remain in prison for the rest of their natural lives. Crimes that warrant life imprisonment are extremely serious and usually violent. Examples of these crimes are murder, torture, terrorism, child abuse resulting in death, rape, espionage, treason, Illegal drug trade, human trafficking, severe fraud and financial crimes, aggravated Property damage, arson, hate crime, kidnapping, burglary, and robbery, piracy, aircraft hijacking, and genocide.

<span class="mw-page-title-main">1994 Oregon Ballot Measure 11</span> Citizens initiative passed in 1994

Measure 11, also known as "One Strike You're Out", was a citizens' initiative passed in 1994 in the U.S. State of Oregon. This statutory enactment established mandatory minimum sentencing for several crimes. The measure was approved in the November 8, 1994 general election with 788,695 votes in favor, and 412,816 votes against.

Probation in criminal law is a period of supervision over an offender, ordered by the court often in lieu of incarceration.

Felony petty theft is the colloquial term for a statute in the California Penal Code that makes it possible for a person who commits the crime of petty theft to be charged with a felony rather than a misdemeanor if the accused had previously been convicted of a theft-related crime at any time in the past. The technical name for the charge is petty theft with a prior.

Mandatory sentencing requires that offenders serve a predefined term of imprisonment for certain crimes, commonly serious or violent offenses. Judges are bound by law; these sentences are produced through the legislature, not the judicial system. They are instituted to expedite the sentencing process and limit the possibility of irregularity of outcomes due to judicial discretion. Mandatory sentences are typically given to people who are convicted of certain serious and/or violent crimes, and require a prison sentence. Mandatory sentencing laws vary across nations; they are more prevalent in common law jurisdictions because civil law jurisdictions usually prescribe minimum and maximum sentences for every type of crime in explicit laws.

A habitual offender, repeat offender, or career criminal is a person convicted of a crime who was previously convicted of other crimes. Various state and jurisdictions may have laws targeting habitual offenders, and specifically providing for enhanced or exemplary punishments or other sanctions. They are designed to counter criminal recidivism by physical incapacitation via imprisonment.

Ewing v. California, 538 U.S. 11 (2003), is one of two cases upholding a sentence imposed under California's three strikes law against a challenge that it constituted cruel and unusual punishment in violation of the Eighth Amendment. As in its prior decision in Harmelin v. Michigan, the United States Supreme Court could not agree on the precise reasoning to uphold the sentence. But, with the decision in Ewing and the companion case Lockyer v. Andrade, the Court effectively foreclosed criminal defendants from arguing that their non-capital sentences were disproportional to the crime they had committed.

Lockyer v. Andrade, 538 U.S. 63 (2003), decided the same day as Ewing v. California, held that there would be no relief by means of a petition for a writ of habeas corpus from a sentence imposed under California's three strikes law as a violation of the Eighth Amendment's prohibition of cruel and unusual punishments. Relying on the reasoning of Ewing and Harmelin v. Michigan, the Court ruled that because no "clearly established" law held that a three-strikes sentence was cruel and unusual punishment, the 50-years-to-life sentence imposed in this case was not cruel and unusual punishment.

In the United States, life imprisonment is the most severe punishment provided by law in states with no valid capital punishment statute, and second-most in those with a valid statute. According to a 2013 study, 1 of every 2 000 inhabitants of the U.S. were imprisoned for life as of 2012.

Rummel v. Estelle, 445 U.S. 263 (1980), was a United States Supreme Court case in which the Court upheld a life sentence with the possibility of parole under Texas' three strikes law for a felony fraud crime, where the offense and the defendant's two prior offenses involved approximately $230 of fraudulent activity.

<span class="mw-page-title-main">Armed Career Criminal Act</span> 1984 United States federal law

The Armed Career Criminal Act of 1984 (ACCA) is a United States federal law that provides sentence enhancements for felons who commit crimes with firearms if they are convicted of certain crimes three or more times. Pennsylvania Senator Arlen Specter was a key proponent for the legislation.

Indefinite imprisonment or indeterminate imprisonment is the imposition of a sentence of imprisonment with no definite period of time set during sentencing. It was imposed by certain nations in the past, before the drafting of the United Nations Convention against Torture (CAT). The length of an indefinite imprisonment was determined during imprisonment based on the inmate's conduct. The inmate could have been returned to society or be kept in prison for life.

Life imprisonment in Canada is a criminal sentence for certain offences that lasts for the offender’s life. Parole is possible, but even if paroled, the offender remains under the supervision of Corrections Canada for their lifetime, and can be returned to prison for parole violations.

In the United States, the law for murder varies by jurisdiction. In many US jurisdictions there is a hierarchy of acts, known collectively as homicide, of which first-degree murder and felony murder are the most serious, followed by second-degree murder and, in a few states, third-degree murder, which in other states is divided into voluntary manslaughter, and involuntary manslaughter such as reckless homicide and negligent homicide, which are the least serious, and ending finally in justifiable homicide, which is not a crime. However, because there are at least 52 relevant jurisdictions, each with its own criminal code, this is a considerable simplification.

<span class="mw-page-title-main">10-20-Life</span> Mandatory minimum sentencing law

The Florida Statute 775.087, known as the 10-20-Life law, is a mandatory minimum sentencing law in the U.S. state of Florida. The law concerns the use of a firearm during the commission of a forcible felony. The Florida Statute's name comes from a set of three basic minimum sentences it provides for. A public service announcement campaign accompanied the law after its passage under the slogan "Use a gun, and you're done."

<span class="mw-page-title-main">2012 California Proposition 36</span> Passed proposition to change the three-strikes law

Proposition 36, also titled A Change in the "Three Strikes Law" Initiative, was a California ballot measure that was passed in November 2012 to modify California's Three Strikes Law. The latter law punishes habitual offenders by establishing sentence escalation for crimes that were classified as "strikes", and requires a mandatory minimum sentence of 25 to life for a "third-strike offense."

<span class="mw-page-title-main">Criminal justice reform in the United States</span> Reforms seeking to address structural issues in criminal justice systems of the United States

Criminal justice reform seeks to address structural issues in criminal justice systems such as racial profiling, police brutality, overcriminalization, mass incarceration, and recidivism. Reforms can take place at any point where the criminal justice system intervenes in citizens’ lives, including lawmaking, policing, sentencing and incarceration. Criminal justice reform can also address the collateral consequences of conviction, including disenfranchisement or lack of access to housing or employment, that may restrict the rights of individuals with criminal records.

<span class="mw-page-title-main">Sentencing and Parole Reform Act 2010</span>

The Sentencing and Parole Reform Act 2010, now repealed, was an Act of Parliament in New Zealand that denied parole to repeat violent offenders, and imposed maximum terms of imprisonment on repeat offenders who commit three serious violent offences - unless it would be manifestly unjust. The law was known informally in New Zealand public, media and government circles as the "three-strikes law".

Sentencing reform is the effort to change perceived injustices in the lengths of criminal sentences. It is a component of the larger concept of criminal justice reform. In the U.S. criminal justice system, sentencing guidelines are criticized for being both draconian and racially discriminatory. Additionally, they are cited as the main contributor to the growing and excessive prison population known as mass incarceration.


  1. White, Ahmed (2006). "The Juridical Structure of Habitual Offender Laws and the Jurisprudence of Authoritarian Social Control" . Retrieved 2019-04-07.
  2. 1 2 Spencer v. Texas,385U.S.554(1967)("Article 63 provides: "Whoever shall have been three times convicted of a felony less than capital shall on such third conviction be imprisoned for life in the penitentiary."").
  3. "Anti-Violence Strategy | USAO | Department of Justice". Retrieved 2017-03-23.
  4. "1032. Sentencing Enhancement – "Three Strikes" Law – USAM – Department of Justice". 2015-02-20. Retrieved 21 March 2018.
  5. "1032. Sentencing Enhancement – "Three Strikes" Law | USAM | Department of Justice". 2015-02-20. Retrieved 2017-03-23.
  6. Meese, Edwin (1994-01-01). "Three-Strikes Laws Punish and Protect". Federal Sentencing Reporter. 7 (2): 58–60. doi:10.2307/20639746. JSTOR   20639746.
  7. "Three Strikes Law – A General Summary". Retrieved 2017-03-23.
  8. Zimring, Franklin E.; Hawkins, Gordon; Kamin, Sam (2001). Punishment and Democracy: Three Strikes and You're Out in California . New York: Oxford University Press. p.  4. ISBN   978-0-19-513686-9.
  9. Katkin, Daniel (1971–1972). "Habitual Offender Laws: A Reconsideration". Buffalo Law Review. 21 (3): 99–120. Retrieved May 1, 2013.
  10. Portalatin v. Graham, 478F.Supp.2d69 (E.D.N.Y.2007).
  11. Bessler v. Walsh,601F.3d163(2nd Cir2010).
  12. Clarke, Matt (2015-03-15). "Second Circuit: New York's Persistent Felony Offender Statute Held Constitutional in En Banc Ruling". Prison Legal News.
  13. Portalatin v. Graham, 624F.3d69 (2d Cir2010).
  14. Okrent, Daniel (11 May 2010). Last Call: The Rise and Fall of Prohibition . Scribner. loc 6011(Kindle). ISBN   978-0743277020.
  15. "TERM IN MICHIGAN; Fouth [sic] Liquor Law Violation Gets Conviction by Jury--Counsel Plans Appeal". New York Times. 12 December 1928. Retrieved 9 March 2020.
  16. "California Proposition 184, Three Strikes Sentencing Initiative (1994)". Retrieved 21 March 2018.
  17. The substantive provisions of Proposition 184 are codified in California Penal Code Sections 667(e)(2)(A)(ii) and 1170.12(c)(2)(A)(ii).
  18. Stolzenberg, Lisa; Stewart J. D'Alessio (1997). ""Three Strikes and You're Out": The Impact of California's New Mandatory Sentencing Law on Serious Crime Rates". Crime and Delinquency. 43 (4): 457–69. doi:10.1177/0011128797043004004. S2CID   146715051.
  19. 1 2 Shichor, David (October 1997). "Three Strikes as a Public Policy: The Convergence of the New Penology and the McDonaldization of Punishment". Crime & Delinquency. 43 (4): 470–492. doi:10.1177/0011128797043004005. S2CID   145111157.
  20. Arrigo, Bruce A. (2014). Encyclopedia of Criminal Justice Ethics. SAGE Publications. ISBN   9781483346588.
  21. "FindLaw's United States Supreme Court case and opinions". Findlaw. Retrieved 21 March 2018.
  22. Rummel was released a few months later, after successfully challenging his sentence for ineffective assistance of counsel and pleading guilty in a subsequent plea bargain. Solem v. Helm, 463 U.S. 277 Footnote 8, 28 June 1983
  23. Texas would later amend its Penal Code to remove the mandatory life requirement for a habitual offender, changing the sentence to 25–99 years or life Texas Penal Code Section 12.42(d).
  24. Brown, Brian; Jolivette, Greg (October 2005). "A Primer: Three Strikes – The Impact After More Than a Decade". California Legislative Analyst's Office . Retrieved 28 October 2012.
  25. Reynolds, Mike. "States That Have Some Form of Three-Strikes Law" . Retrieved May 1, 2013.
  26. Austin, James (2000). "Three Strikes and You're Out: The Implementation and Impart of Strike Laws" (PDF).
  27. Glen Johnson; Brian R. Ballou (August 2, 2012). "Deval Patrick signs repeat offender crime bill in private State House ceremony". The Boston Globe. Archived from the original on December 16, 2017. Retrieved October 27, 2014.
  28. Jhon Freeman, Michigan's Justice System: Three Strikes and You’re Out
  29. California, State of. "Department of Corrections and Rehabilitation". Retrieved 2017-05-02.
  30. Marvell, Thomas B.; Carlisle E. Moody (2001). "The Lethal Effects of the Three Strikes Laws". The Journal of Legal Studies. 3 (1): 89. doi:10.1086/468112. S2CID   153684944 . Retrieved May 2, 2013.
  31. Males, Mike; Dan Macallair (1999). "Striking Out: The Failure of California's "Three-Strikes You're Out" Law". Stanford Law and Policy Review. 11 (1): 65. Retrieved May 2, 2013.
  32. "Penal Code Chapter 12. Punishments". Retrieved 21 March 2018.
  33. "Cases Show Disparity Of California's 3 Strikes Law". Retrieved 2017-05-02.
  34. Butterfield, Fox (1995-09-11). "In for Life: The Three-Strikes Law -- A special report.; First Federal 3-Strikes Conviction Ends a Criminal's 25-Year Career". The New York Times. ISSN   0362-4331 . Retrieved 2019-07-05.
  35. Butterfield, Fox (11 September 1995). "In for Life: The Three-Strikes Law – A special report; First Federal 3-Strikes Conviction Ends a Criminal's 25-Year Career". The New York Times.
  36. Worrall, John L. (2004). "The Effect of Three-Strikes Legislation on Serious Crime in California". Journal of Criminal Justice. 32 (4): 283–96. doi:10.1016/j.jcrimjus.2004.04.001.
  37. Stolzenberg, Lisa; Stewart J. D' Alessio (1997). ""Three Strikes and You're Out": The Impact of California's New Mandatory Sentencing Law on Serious Crime Rates". Crime & Delinquency. 43 (4): 457–69. doi:10.1177/0011128797043004004. S2CID   146715051.
  38. Helland, Eric; Tabarrok, Alexander (2007). "Does Three Strikes Deter?". Journal of Human Resources. XLII (2): 309–30. doi:10.3368/jhr.XLII.2.309. S2CID   17236511.
  39. "Evidence does not support three-strikes law as crime deterrent". News. Retrieved 2022-09-27.
  40. Stemen, Don (January 2007). "Reconsidering Incarceration: New Directions for Reducing Crime" (PDF). Vera Institute of Justice. p. 2. Archived from the original (PDF) on 11 June 2016. Retrieved 26 January 2016.
  41. Iyengar, Radha (February 2008). "I'd rather be Hanged for a Sheep than a Lamb: The Unintended Consequences of 'Three-Strikes' Laws". NBER Working Paper No. 13784. doi: 10.3386/w13784 .
  42. Crifasi, Cassandra K.; Pollack, Keshia M.; Webster, Daniel W. (2015-12-30). "Effects of state-level policy changes on homicide and nonfatal shootings of law enforcement officers". Injury Prevention. 22 (4): injuryprev–2015–041825. doi:10.1136/injuryprev-2015-041825. ISSN   1475-5785. PMID   26718550. S2CID   206980841.
  43. "Sentencing and Parole Act 2010". New Zealand Legislation. Parliamentary Counsel Office . Retrieved 22 June 2018.
  44. "Controversial 'three strikes' bill passes". New Zealand Herald . New Zealand Press Association. 25 May 2010. Retrieved 22 June 2018.
  45. "Three Strikes". Sensible Sentencing Trust . Retrieved 22 June 2018.
  46. Rumbles, W. (2011). ""Three Strikes" sentencing: Another blow for Māori". Waikato Journal of Law. 19 (2): 108–116. Retrieved 22 June 2018.
  47. Walters, Laura; Moir, Jo (11 June 2018). "Government's three strikes repeal killed by NZ First". Stuff . Retrieved 22 June 2018.
  48. "No support from New Zealand First to repeal 'three strikes' law". New Zealand Herald . 12 June 2018. Retrieved 22 June 2018.
  49. Walters, Laura (1 June 2018). "National would reinstate three strikes, retrospectively punish offenders". Stuff . Retrieved 22 June 2018.
  50. "Three strikes law - you're out: Justice Minister to repeal". Radio New Zealand . 11 November 2021. Archived from the original on 3 December 2021. Retrieved 11 November 2021.
  51. Huang, Christina (9 August 2022). "Parliament votes to scrap three strikes law". 1 News . TVNZ. Archived from the original on 10 August 2022. Retrieved 10 August 2022.
  52. Neilson, Michael (9 August 2022). "Three strikes law gone: Labour fulfils 2017 campaign promise, Nats and Act rail against move". The New Zealand Herald . Archived from the original on 9 August 2022. Retrieved 10 August 2022.