Campbell v. Ohio, 138 S.Ct. 1059

Glen Campbell pleaded guilty to aggravated murder in Ohio and was sentenced to life imprisonment without parole under Ohio law.
Ohio law (§2929.03(A)(1)) permits sentencing alternatives including life with parole eligibility after 20, 25, or 30 years, or life without parole.
Campbell appealed, arguing the trial court failed to balance statutory aggravating and mitigating factors (§2929.12) and raised constitutional claims (due process and equal protection) about lack of meaningful appellate review.
Ohio appellate court relied on §2953.08(D)(3), which states sentences for murder/aggravated murder are not subject to review, and on State v. Porterfield holding that provision unambiguous and bars review.
Justice Sotomayor concurred in the denial of certiorari because Campbell inadequately presented his claims to state courts but wrote separately expressing serious constitutional concerns about shielding life-without-parole sentences from appellate scrutiny.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §2953.08(D)(3) bars meaningful appellate review of life-without-parole sentences, violating due process/other constitutional protections	Campbell: statute denies meaningful review of an irrevocable sentence and may permit arbitrary, biased, or freakish imposition	Ohio: statute is unambiguous; sentences for murder/aggravated murder are not reviewable under §2953.08(D)(3)	Certiorari denied; Sotomayor: case not properly presented, but statute raises serious constitutional questions about shielding LWOP from review
Whether a defendant can raise judicial-bias claims or similar constitutional claims when §2953.08(D)(3) precludes ordinary appellate review	Campbell: inability to obtain appellate review bars consideration of bias or individualized sentencing concerns	State: postconviction procedures exist but are limited (e.g., require pattern-based bias showing under §2953.21(A)(5))	Sotomayor notes limits of state remedies and questions adequacy of those avenues but did not reach a decision; highlights potential due process concerns

Harmelin v. Michigan, 501 U.S. 957 (1991) (life without parole is a severe, irrevocable penalty)
Graham v. Florida, 560 U.S. 48 (2010) (life-without-parole sentences share distinctive features with death sentences; categorical rule for juveniles who did not commit homicide)
Miller v. Alabama, 567 U.S. 460 (2012) (imported individualized-sentencing Eighth Amendment principles for juveniles facing life sentences)
Eddings v. Oklahoma, 455 U.S. 104 (1982) (capital sentencing requires consideration of mitigating evidence for fairness)
Parker v. Dugger, 498 U.S. 308 (1991) (avoiding arbitrary or irrational imposition of capital punishment)
Clemons v. Mississippi, 494 U.S. 738 (1990) (meaningful appellate review promotes reliability and consistency in death-penalty cases)
Gregg v. Georgia, 428 U.S. 153 (1976) (meaningful appellate review as a safeguard against capricious imposition of capital punishment)