Plane Sailing said:
I'm rather curious - how would you see someone paralysed by a Hold spell making a Reflex ST? Would you give them a -5 for having a temporary Dex of 0, and assume that it reflects how lucky they are?
That's how I would do it. A -5 penalty on top of a PC losing their bonus for Dex makes it very difficult for them to pass a DC 20 save anyway.
By making it 'no save', you also invalidate the effects of Cloaks of Resistance. Just because you're pinned, items like this suddenly stop working? That doesn't seem reasonable to me.
Simple way would be to allow a Saving Throw equal to Base Reflex Save, -5 for Dex 0, plus any modifiers from Cloaks of Resistance etc. The chances of success are small, but they're there. It's just luck, fate, or what have you.