Mississippi requires the defendant to have served prison time for each prior conviction that was brought and tried separately. Mississippi courts routinely conduct proportionality review of life sentences and find them appropriate only when crimes of violence are involved. Montana Mont. Code Ann. Nebraska Neb. Rev. Stat. Nevada Nev. Rev. Stat.
New Jersey has a ten year wash-out period.
New Mexico N.M. Stat. North Carolina N.C. Gen. Stat. Oklahoma Okla. Stat. Oklahoma also provides for a 10-year washout period for prior felonies. Pennsylvania Pa. Cons.