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Massachusetts Supreme Court Rules No One Under 21 Can Be Sentenced to Life Without Parole

The court found that the brains of 'emerging adults' are more similar to juveniles than adult offenders


Massachusetts Supreme Court Rules No One Under 21 Can Be Sentenced to Life Without Parole

The highest court in Massachusetts has ruled that no one under the age of 21 can be sentenced to life in prison without the possibility of parole.


The minimum age at which an offender can receive that sentence in the state is currently 18. The court found 4-3 on Jan. 11 that such a policy was unconstitutional. 

The case at the center of the ruling involves Sheldon Mattis, who was convicted of first-degree murder in 2011 at the age of 18. He challenged the constitutionality of his life without parole sentence during his appeals, arguing that he was entitled to the same protections as a juvenile offender. 

The court found that sentencing protection for juvenile offenders (those who commit crimes between the ages of 14 and 17) should apply to “emerging adults” – offenders between the ages of 18 and 20. 

“Advancements in scientific research have confirmed what many know well through experience: the brains of emerging adults are not fully mature,” wrote Chief Justice Kimberly Budd in the court’s opinion. “Specifically, the scientific record strongly supports the contention that emerging adults have the same core neurological characteristics as juveniles have.”

“Because we have determined that it is unconstitutional to sentence emerging adults to life without the possibility of parole, we invalidate those provisions of our criminal code that deny the possibility of parole to this cohort,” Budd subsequently wrote.

Before now, it was mandatory in Massachusetts and nine other states that anyone convicted of first-degree murder between the ages of 18 and 20 be sentenced to life without parole.

Because of the court’s ruling “emerging adults” who were convicted in Massachusetts between the ages of 18 to 20 and sentenced to life without parole before July 25, 2014 will now be sentenced to life with the possibility of parole after 15 years. 

Ruth Greenberg, an attorney for Mattis, praised the court’s decision.

“People who are 18 are more like people who are 17 than people who are 35. They are capable of change, and often their decisions at that young age were not entirely their own,” she told AP News. “It is courageous and it is correct, and other courts will follow it.”

Mattis was convicted of murdering Jaivon Blake in Dorchester as part of a gang-related dispute. Nyasani Watt was also convicted of Blake’s murder and fired the fatal shot. However, because Watt was 17 at the time, he was able to apply for parole at 15 years. Mattis is eight months older than Watt. 

Justice David Lowy wrote the court’s dissenting opinion.

“Where punishment is involved, we must look to society and the Legislature to determine where the appropriate line is and where it should be,” he stated. “Nothing in the statutes that restrict certain activities to individuals over the age of twenty-one alters or changes the age at which the Legislature has determined adulthood begins.”

“Children in Massachusetts know that their legal rights and responsibilities forever are altered on turning eighteen. Indeed, knowledge of this situation becomes largely unavoidable for adolescents in the years leading up to their eighteenth birthday,” Lowy added. “On reaching our age of majority, adults in Massachusetts inherit the largest bundle of rights they ever will receive; conversely, they know that they also are exposed to the full consequences of their criminal acts in adult courts.”

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