The project is based upon research of Tessler et al. (1994) on an improved variational formulation for post-processing stress predictions in Finite Element Analysis. The methodology, called Smoothing Element Analysis (SEA), employs a three-node smoothing finite element. The present effort focused on verifying the basic constant strain criterion for the three-node smoothing element subject to a set of internal penalty constraints. The convergence characteristics of the element are assessed by first deriving the constrained form of the assumed element stress and stress gradient fields, and then by verifying the validity of the constant strain criterion once the element penalty constraints are explicitly imposed. The analytical investigation is carried out with the use of the symbolic manipulation code 'Mathematica'.