Abstract
"Three strikes" laws have been a source of great debate since their inception. The recent Supreme Court decision in Ewing v. California (2003), upholding California's three strikes laws will undoubtedly have an effect on prison management as prison populations continue to rise and correctional budgets continue to decrease. This paper examines the legal history of "three strikes" legislation and explores the impact these laws have on the criminal justice system, particularly prison populations and correctional budgets as well as the recent surge in the number of geriatric prisoners.

Kelly Ann Cheeseman
Old Dominion University
Kelly Cheeseman is an instructor of Criminal Justice at Old Dominion University. Kelly has published articles, in refereed journals such as Deviant Behavior, Corrections Management Quarterly and Criminal Law Bulletin. Her current research interests include institutional corrections, deviance, the death penalty, sexual offending, social policy, and women and crime. She has been employed with two major correctional systems: Texas and the Federal Bureau of Prisons.

Rolando V. del Carmen
Sam Houston State University
Rolando V. del Carmen is Distinguished Professor of Criminal Justice (Law) at Sam Houston State University. He has published several books and numerous articles in law. His areas of expertise are: criminal procedure, corrections law, juvenile law, legal liabilities of public officials, rights of public officials, and probation and parole law.

Robert Worley
Sam Houston State University
Robert Worley is an ABD at Sam Houston State University. He has published articles related to correctional officer-inmate inappropriate relationships, in journals such as Deviant Behavior and Crime and Justice International. Mr. Worley's current research interests include sex offender registration, family violence, and white collar-crime.