Lockett v. Ohio

Sandra Lockett (defendant) helped plan a pawnshop robbery in which she drove the getaway car while her accomplice Parker entered and, during a struggle over the gun, accidentally shot and killed the shop owner; Lockett then drove Parker away and helped hide him and another accomplice from police. Convicted of aggravated murder and aggravated robbery, Lockett faced an Ohio law requiring the judge to impose death unless the victim contributed to the offense, the defendant acted only under duress, or the crime stemmed primarily from mental deficiency or psychosis - none of which applied to Lockett despite her comparatively minor, non-triggering role - so the judge sentenced her to death. The Supreme Court granted certiorari to decide whether Ohio's narrow mitigating-factor scheme unconstitutionally limited the sentencer's ability to weigh the defendant's character or the crime's circumstances.