Its hardly an arcane reference, you know the California three strikes rule. Clearly this guy is a loon because his third crime was to steal a toy
From wiki:
Curtis Wilkerson stole a pair of socks worth $2.50 in 1995. As he had had two prior convictions for robbery in 1981, aged 19, this theft was considered a third strike. He was convicted and received a life sentence
Issac Ramirez stole a VCR worth $199 from a Sears in Los Angeles, and was arrested as he was walking out of the store. Having previously been convicted of two previous shoplifting related robberies, Ramirez was sentenced to a prison term of 25 years to life
So we're comparing apples and oranges: a recidivist offender sentencing provision, and the sentence of a first-time offender.
I don't like the California three strikes, but we don't do ourselves any favors over here when we compare Ulbricht's sentences to those.