In the United States, habitual offender laws (commonly referred to as three-strikes laws) have been implemented since at least 1952, and are part of the United States Justice Department's Anti-Violence Strategy. These laws require a person who is convicted of an offense and who has one or two other previous serious convictions to serve a mandatory life sentence in prison, with or without parole depending on the jurisdiction. The purpose of the laws is to drastically increase the punishment of those who continue to commit offenses after being convicted of one or two serious crimes. Twenty-eight states have some form of a "three-strikes" law. A person accused under such laws is referred to in a few states (notably Connecticut and Kansas) as a "persistent offender", while Missouri uses the unique term "prior and persistent offender". In most jurisdictions, only crimes at the felony level qualify as serious offenses. And it may turn on which felonies are defined as being serious, which may vary depending on the jurisdiction, in particular, whether a subject felony must include violence or not. The three-strikes law significantly increases the prison sentences of persons convicted of a felony who have been previously convicted of two or more violent crimes or serious felonies, and limits the ability of these offenders to receive a punishment other than a life sentence. The expression "Three strikes and you are out" is derived from baseball, where a batter against whom three strikes are recorded strikes out. The practice of imposing longer prison sentences on repeat offenders (versus first-time offenders who commit the same crime) is present throughout most of American history, as judges often take into consideration prior offenses when sentencing. However, there is a more recent history of mandatory prison sentences for repeat offenders. For example, New York State had a long-standing Persistent Felony Offender law dating back to the early 20th century (partially ruled unconstitutional in 2010, but reaffirmed en banc shortly after).