was also charged as a parole violator" (Benekos & Merlo, 1995, p. 4).
Although Franklin and others estimate that the idea of three strikes had been floating around California for about a year prior to the Klaas murder, research shows that at least as early as 1986, the concept of "three strikes and you're out" was conceived as a way to get habitual offenders off the street (Shuit, 1986, p. I-32). But it would take the death of Polly Klaas to provide the catalyst just over seven years later, as the state legislature passed the Jones-Costa Three Strikes Bill (Harvard Law Review, 1994, p. 2123).
According to Ingley (1995), prior to 1994, many states had implemented various laws intended to create mandatory minimum sentences specifically for habitual offenders of violent crime. In 1994, however, three strikes became a particularly popular slogan among politicians of all persuasions. By October of that year, the federal government and 13 states--California, Colorado, Connecticut, Georgia, Indiana, Kansas, Louisiana, Maryland, New Mexico, North Carolina, Tennessee, Virginia, and Wisconsin--had enacted such legislation, joining the state of Washington (which implemented its law in December 1993). Similar legislation was pending just six months later in at least seven other states--Alaska, Illinois, New Jersey, Ohio, Pennsylvania, South Carolina, and Vermont (p. 24). Turner et al. (1995) conducted exhaustive research into three strikes legislative efforts and determined that at least 77 "three strikes and you're out" statutes had been proposed or enacted in 37 jurisdictions and that a total of 92 bills in 40 states included habitual offender provisions (p. 18).
But, as Turner and his colleagues point out, "although the three-strikes phrase is currently in vogue among legislators, the media, and the public, the details of these laws are not well known" (p. 16). Despite broad bipartisan support for such legislation, liberal ...