Mark Lawlor was convicted of capital murder and sentenced to death in the killing of Genevieve Orange, a tenant in a Fairfax County apartment complex where Lawlor worked as a leasing agent.
In recommending the death sentence, a jury found that it was likely Lawlor would commit additional violence “that would constitute a continuing serious threat to society.”
On Tuesday, a three-judge panel of the 4th U.S. Circuit Court of Appeals reversed the death sentence. The court found the state court wrongly excluded the testimony of an expert witness who would have testified that Lawlor had a very low risk of committing additional violence in prison.