The highest court in Massachusetts ruled last Thursday that individuals under the age of 21 cannot be sentenced to life without parole. Notably, Massachusetts is the first state to adopt this legal stance. This 4-3 decision effectively raises the minimum age for the sentence from 18 to 21. The rationale cited for this decision was a combination of brain development science and the principles outlined in the Massachusetts Constitution.
The ruling originated from the case, Commonwealth v. Sheldon Mattis. Sheldon Mattis, who was convicted for the 2011 shooting death of Javion Blake when he was 18, was sentenced to life without parole. His co-defendant, who was 17 at the time, received a 15-year sentence with the possibility of parole. This case was instrumental in prompting the decision.
The Massachusetts Supreme Judicial Court, concluding their decision, commented that “emerging adults, who are 18, 19, or 20, are not fully mature.” This verdict leaned heavily on available scientific research, which firmly suggested that these emerging adults share the same core neurological characteristics as juveniles. With these factors in mind, the court declared it unconstitutional to sentence underage individuals to life without parole, seeing it as a direct violation of both Article 26 of the Massachusetts Declaration of Rights and the Eighth Amendment of the US Constitution, which protects against cruel and unusual punishment.
The scientific evidence presented during the case showed that “emerging adults” had deficient impulse control. Such tendencies were more similar to 16 and 17-year-olds rather than older adults, and were attributed to their undeveloped prefrontal cortex that regulates impulse.
Massachusetts is reportedly one of only ten states where 18 to 21-year-olds convicted for first-degree murder are required to face life sentences without parole. The decision will now alter this, allowing those who have been sentenced to life without parole before the newly initiated parole system introduced in 2014 for minors convicted of first-degree murder to become eligible for parole after serving 15 years. Furthermore, such individuals will be resentenced in line with this new ruling. For crimes committed after this date, however, a sentence of 20-35 years will have to be served before parole consideration becomes available.
Ruth Greenberg, the attorney representing Mattis, hailed the decision as “courageous,” noting that the Supreme Judicial Court has set an impressive precedent for the broader U.S legal environment with this landmark decision.