Lockett v. Ohio

1978-07-03

Headline: Ohio death-penalty law blocked for barring judges from weighing a defendant’s character and other mitigating evidence, reversing a death sentence and letting defendants present personal factors at sentencing.

Holding: The Court held that Ohio’s death-penalty law violated the Eighth and Fourteenth Amendments because it barred the judge or sentencing panel from considering any mitigating aspect of the defendant’s character, record, or offense, and reversed the death sentence.

Real World Impact:

Stops states from excluding nonstatutory mitigating evidence at capital sentencing.
Requires judges or panels to consider any mitigating factor a defendant offers.
Reverses death sentences imposed under statutes that narrowly limit mitigation.

Topics: death penalty, mitigating evidence, capital sentencing, aiding and abetting, criminal sentencing

Summary

Background

Sandra Lockett, a 21-year-old woman, was convicted after a pawnshop robbery in which a co-participant fired a fatal shot. She waited in the getaway car, handled the gun afterward, and was tried under Ohio law that treated aiders and abettors as principals. The trial judge reviewed psychological and presentence reports but, under the Ohio statute, could impose death unless the judge found one of only three narrow mitigating circumstances.

Reasoning

The Court asked whether Ohio’s statute violated the Eighth and Fourteenth Amendments by preventing the sentencer from considering broader mitigating evidence. Looking to earlier death-penalty decisions, the plurality concluded that when a State allows individualized sentencing the decisionmaker must be able to consider any aspect of the defendant’s character, record, or the offense offered in mitigation. Because Ohio’s law limited mitigation to three specified factors and barred other relevant evidence, it risked imposing death despite mitigating circumstances and therefore failed constitutional requirements. The Court reversed the part of the Ohio judgment that sustained the death sentence and remanded for further proceedings.

Real world impact

Going forward, judges or sentencing panels must be permitted to hear and give weight to any mitigating evidence a defendant offers. Statutes that narrowly list or exclude mitigating factors will be open to constitutional attack. This ruling vacates Lockett’s death sentence and sends the case back for further proceedings under the Court’s rule.

Dissents or concurrances

Some Justices wrote separately. Justice Blackmun urged allowing consideration of the defendant’s role and mens rea; Justice White argued the death penalty should require a finding of intent to kill; Justice Marshall reiterated opposition to capital punishment.