Clemency is a way to bring into harmony the goals of law enforcement and justice; of mitigating disparities in punishment arising from rigidity and flexibility inherent in a discretionary penal system. The executive power of clemency, while legal in the sense that it is constitutionally granted, is also political inasmuch as it allows the executive to consider factors that judges and juries cannot. The power to review cases and grant clemency is routine in penal governance, and is a proper means of addressing wrongful convictions or overly severe sentences imposed against women who defended themselves against their batterers.

Citing two acts on December 21, 1990, and January 11, 1991, by then-Ohio Governor Richard F. Celeste granting clemency to twenty- seven women, Professor Ammons argues that Celeste properly granted clemency in these cases. Law and society have traditionally exhibited gender bias when dealing with battered women who kill their abusers, and it is proper and reasonable for a governor to consider these and other factors when reviewing a petition for clemency and determining whether to intervene to mitigate the harsh and unjust consequences of the law.