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Adults younger than 21 cannot be sentenced to life without parole, Mass. high court rules

The John Adams Courthouse in Boston, home of the Mass. Supreme Judicial Court.
Robin Lubbock
The John Adams Courthouse in Boston, home of the Mass. Supreme Judicial Court.

In a landmark split ruling, Massachusetts' highest court declared it unconstitutional for judges to sentence anyone under the age of 21 to life in prison without the possibility of parole.

The closely watched case is believed to make Massachusetts the first state in the country to eliminate such sentences for people considered "emerging adults."

Prior to this ruling, the state prohibited only under the age of 18 from being sentenced to life in prison without the opportunity for parole.

"The court is courageous," said attorney Ruth Greenberg who brought the case to the state Supreme Judicial Court. "We are the first court in the country where a punishment of life without parole is categorically prohibited for people under 21. It was a carefully considered opinion. The court followed the science and did the right thing — and other courts, I'm confident, will follow."

The case involved Sheldon Mattis, who is serving a life sentence for his role in the 2011 fatal shooting of Jaivon Blake in Dorchester. Mattis was 18 at the time of the shooting. He had given a gun to Nyasani Watt, who shot Blake. Both defendants were convicted of first-degree murder, but because Watt was then under 18, he was deemed eligible for parole after 15 years. Watt was sentenced to life without the possibility of parole.

In Thursday's 4-3 ruling, the justices cited several factors underlying the court's decision. Chief among them was discussion of scientific data and evidence that supports the idea that young adult brains are still developing.

"Advancements in scientific research have confirmed what many know well through experience: the brains of emerging adults are not fully mature," the justices wrote. "Specifically, the scientific record strongly supports the contention that emerging adults have the same core neurological characteristics as juveniles have."

The ruling said the justices "do not diminish the severity of the crime of murder in the first degree, because it was committed by an emerging adult."

But, they argued, young adults should have an opportunity for release because courts must recognize the "unique characteristics" of emerging adults that render them "constitutionally different" from adults when it comes to sentencing, and grant them the opportunity to obtain release "based on maturity and rehabilitation."

Writing in dissent, Justice David Lowy said lawmakers, not the judiciary, should draw the line at who is considered an adult.

"Where punishment is involved, we must look to society and the Legislature to determine where the appropriate line is and where it should be," Lowy wrote.

Lowy said that, although the high court ruled that automatic sentences of life in prison without parole were not constitutional for those under 18 years old, the justices followed agreed upon definitions regarding the age of adulthood. He also pointed out that the court's 2013 ruling against such sentences for juveniles followed a similar U.S. Supreme Court ruling.

Also dissenting was Justice Elspeth Cypher, who expressed concerns about violating the separation of powers between the legislative and judicial branches of government.

"Neither the parties, nor the court, have pointed to a single instance in which the judiciary has taken it on itself to make such a distinction between individuals in the newly minted "emerging adult" category and adults, as it seeks to do here," she wrote.

In a concurring opinion, Justice Scott Kafker pointed out that legislation already makes distinctions for those in late adolescence, pointing to laws such as those regulating the age for alcohol use and gambling.

"We should not defer to the Legislature when it recognizes the distinctive characteristics of the eighteen through twenty year old defendants at issue and treats them differently from those twenty-one and over in many ways, but then disregards those differences for our most severe criminal punishments," Kafker wrote.

It's estimated that at least 100 people could be immediately eligible for parole because of Thursday's ruling. Under a system Massachusetts adopted in 2014, young people convicted of first-degree murder can become parole eligible after serving 15 years in prison.

Suffolk County District Attorney Kevin Hayden said his office has identified 70 prisoners in his jurisdiction who will now be eligible for parole. His office is advising those affected by homicides committed by young people to contact them for more information.

"We know this decision will generate questions among the survivors of homicide victims of both the immediate and distant past, and we want to make sure that those survivors get accurate information about the ruling," Hayden said.

In another ruling Thursday, the justices cited the Mattis case in a decision allowing re-sentencing for the first-degree murder conviction of Jason Robinson. He was 19 years old when he was charged in the shooting death of Inaam Yazbek in 2000. The justices said that because of the decision in Mattis, "the defendant's sentence of life without the possibility of parole is unconstitutional" and remanded Robinson's case "to the Superior Court for resentencing on the charge of murder in the first degree in accordance with that decision."

Robinson's attorney Rosemary Scapicchio said the decision means her client is immediately eligible for parole.

"We're very happy that we've breathed life into hundreds of people who before today were serving life sentences without any possibility of going before a parole board. So they now will have the opportunity to go before the parole board and prove that they are rehabilitated and hopefully are able to rejoin society," Scapicchio said.

According to the Emerging Adult Justice Project at Columbia University, the Massachusetts ruling is unprecedented. It says two other states have taken steps to change the laws regarding older adolescents convicted of murder, but Massachusetts is unique in not allowing mandatory life without parole sentences for those under 21.

The Project's Executive Director Lael Chester said after Massachusetts banned such sentences for those under 18, almost three quarters of the young people sentenced have been released and most have matured and not continued their criminal behavior.

"The court is granting emerging adults an opportunity to someday demonstrate to a parole board that they have matured and changed for the better," Chester said. "Science and justice are both clear that this is the minimum they deserve."

Calling the high court a "national leader on many different systemic issues," Anthony Benedetti, chief counsel for the Committee for Public Counsel Services, wrote in an email to WBUR that the opinion "does not mandate release," but it does require parole boards to consider release under supervision for people who committed crimes as young adults. He added that public defenders "stand ready to represent those who are eligible for parole and give our clients a chance to be productive members of society."

Correction: Due to an editing error, an earlier version of this story's headline contained an error. It has been updated to reflect that the ruling only applies to people convicted of crimes younger than age 21 — and not 21 year olds. The headline has been updated. We regret the error.

This story was originally published by WBUR. It was shared as part of the New England News Collaborative.

Updated: January 11, 2024 at 6:50 PM EST
This story has been updated to include additional information and reaction to the ruling.