When deciding whether a criminal fine is disproportionate to the gravity of a defendant's crime, and thereby unconstitutional under the Eighth Amendment, may a reviewing court look beyond and consider more than the four factors identified in United States v. Bajakajian, 118 S. Ct. 2028 (1998); that is, are the Bajakajian factors exhaustive, such that a reviewing court is strictly limited to a narrow comparison between the amount of a fine and the characteristics of the offense; or, may a reviewing court accept, entertain, and consider other matters in addition to the enumerated Bajakajian factors when answering an Eighth Amendment challenge to a fine as excessive?

Whether a reviewing court may consider factors beyond those identified in United States v. Bajakajian when determining if a criminal fine is disproportionate under the Eighth Amendment