“In Bell v. Ohio and Lockett v. Ohio the United States Supreme Court found the sentencing provisions of the Ohio capital punishment statute to be incompatible with the eighth and fourteenth amendments which prohibit cruel and unusual punishment. These two opinions represent the most recent attempt by the Supreme Court to explain what elements must be included in a constitutionally valid capital punishment statute.”
Ellerhorst, James C.
"Death Penalty; Cruel and Unusual Punishment; Individualized Sentencing Determination; Lockett v. Ohio; Bell v. Ohio,"
Akron Law Review: Vol. 12
, Article 11.
Available at: http://ideaexchange.uakron.edu/akronlawreview/vol12/iss2/11