<Ul> <Li> New York has employed a habitual felon statute since 1797 . </Li> <Li> Texas has had a three - strikes with mandatory life sentence since at least 1952 . <Ul> <Li> In Rummel v. Estelle (1980), the US Supreme Court upheld Texas' statute, which arose from a case involving a refusal to repay $120.75 paid for air conditioning repair that was, depending on the source cited, either considered unsatisfactory or not performed at all, where the defendant had been convicted of two prior felony convictions, and where the total amount involved from all three felonies was around $230 . </Li> </Ul> </Li> <Li> In 1993: Washington </Li> <Li> In 1994: California, Colorado, Connecticut, Indiana, Kansas, Maryland, New Mexico, North Carolina, Virginia, Louisiana, Wisconsin, Tennessee, and Georgia </Li> <Li> In 1995: Arkansas, Florida, Montana, Nevada, New Jersey, North Dakota, Pennsylvania, South Carolina, Utah, and Vermont </Li> <Li> In 2006: Arizona </Li> <Li> In 2012: Massachusetts </Li> </Ul> <Li> New York has employed a habitual felon statute since 1797 . </Li> <Li> Texas has had a three - strikes with mandatory life sentence since at least 1952 . <Ul> <Li> In Rummel v. Estelle (1980), the US Supreme Court upheld Texas' statute, which arose from a case involving a refusal to repay $120.75 paid for air conditioning repair that was, depending on the source cited, either considered unsatisfactory or not performed at all, where the defendant had been convicted of two prior felony convictions, and where the total amount involved from all three felonies was around $230 . </Li> </Ul> </Li> <Ul> <Li> In Rummel v. Estelle (1980), the US Supreme Court upheld Texas' statute, which arose from a case involving a refusal to repay $120.75 paid for air conditioning repair that was, depending on the source cited, either considered unsatisfactory or not performed at all, where the defendant had been convicted of two prior felony convictions, and where the total amount involved from all three felonies was around $230 . </Li> </Ul>

Who came up with the three strikes law