State v. Lawson, 2016 Ohio 7607

Pamela A. Lawson pleaded guilty to one count of aggravated murder with a three-year firearm specification for recruiting a codefendant to kill her former boyfriend while she and children (including the victim's disabled child) were present.
The trial court sentenced Lawson to life imprisonment with parole eligibility after serving 30 full years.
Lawson appealed, arguing the trial court failed to conduct an individualized sentencing hearing and did not properly consider mitigating factors under R.C. 2929.12, and that her sentence was disproportionate to her codefendant’s.
Lawson conceded her sentence was within the statutory range for aggravated murder but contended the court ignored mitigating evidence and constitutional protections (Sixth, Eighth, Fourteenth Amendments; Ohio Const. art. I, § 10).
The State defended the sentence as lawful and pointed to statutory limits on appellate review of aggravated-murder sentences.
The appellate court affirmed, holding it lacked statutory authority to review the sentence on the evidentiary/mitigation arguments presented.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an appellate court may review a trial court's consideration of mitigating factors when imposing a sentence for aggravated murder	Rely on R.C. 2953.08(D)(3): aggravated-murder sentences are exempt from review	Trial court failed to give individualized sentencing and consider mitigating factors; sentence unconstitutional and disproportionate	R.C. 2953.08(D)(3) bars evidentiary appellate review of aggravated-murder sentences; court lacked authority to reweigh mitigation; sentence affirmed

State v. Hollingsworth, 143 Ohio App.3d 562 (8th Dist. 2001) (aggravated murder governed by special statutory scheme and exempt from general felony sentencing provisions)
State v. Porterfield, 106 Ohio St.3d 5 (Ohio 2005) (statutory bar in R.C. 2953.08(D)(3) unambiguous; aggravated-murder sentences imposed under R.C. 2929.02–2929.06 cannot be reviewed)