Lockett v. Ohio

438 U.S. 586 (1978)

Facts and Procedural History:

Lockett was charged with aggravated murder and aggravated robbery and was sentenced to death.

Certiorari was granted to review the decision of the Ohio Supreme court and challenge the validity of her conviction, and the constitutionality of the death penalty statute on the ground, inter alia, that it does not give the sentencing judge a full opportunity to consider mitigating circumstances in capital cases as required by the Eighth and Fourteenth Amendments

Issue Presented to the Court:

Did Ohio violate the Eighth and Fourteenth amendments by sentencing Sandra Lockett to death pursuant to a statute that narrowly limits the sentencer's discretion to consider offender’s character, prior record, age, lack of specific intent to cause death and circumstances of the crime as mitigating factors?

Outcome of the Case:

Only the three factors specified in the statute can be considered in mitigation of the defendant's sentence, and once it is determined that none of those factors is present, the statute mandates the death sentence. To meet constitutional requirements, a death penalty statute must not preclude consideration of relevant mitigating factors.
Ohio death penalty statute did not permit the type of individualized consideration of mitigating factors required by Eighth and Fourteenth Amendments in capital cases.