Facts of the Case

An Ohio law required that individuals found guilty of aggravated murder be given the death penalty. The death penalty was mandatory unless: 1) the victim had induced the offense, 2) the offense was committed under duress or coercion, or 3) the offense was a product of mental deficiencies. Sandra Lockett, who had encouraged and driven the getaway car for a robbery that resulted in the murder of a pawnshop owner, was found guilty under the statute and sentenced to death.

Question

Did the Ohio law violate the Eighth and Fourteenth Amendments by limiting the consideration of mitigating factors?

Conclusion

Yes. The Court held that the Eighth and Fourteenth Amendments required, in all but the rarest capital cases, that sentencers not be precluded from considering a range of mitigating factors before imposing the death penalty. These factors included any aspect of a defendant's character or record and any circumstances of the offense proffered as a reason for a sentence less than death. The Court held that the Ohio statute did not permit the type of individualized consideration of mitigating factors required by the Constitution.