Sentences of Life Without Parole Held Unconstitutional for Adults Under 21

The Massachusetts Supreme Judicial Court issued a landmark decision yesterday in Commonwealth v. Mattis. The Court ruled that the imposition of life without parole for criminal defendants who committed their offenses between the ages of 18 to 20 is unconstitutional. The SJC drew on precedent in which they had held that life without parole sentences for juvenile offenders (under 18) violated Article 26 of the Mass Declaration of Rights, which prohibits cruel and unusual punishment. In that opinion (Diatchenko), the Court found that adolescent brain development distinguished juvenile offenders from adults who committed the same crime.

Sheldon Mattis was 18 years old when he committed a homicide. He was convicted of first degree murder and received a mandatory life without parole sentence. Lawyers representing him and other similarly situated offenders argued that the reasoning behind Diatchenko ruling should be extended to 18- to 20-years-olds (“emerging adults.”) Judge Robert Ullman of the Superior Court agreed with this argument and held that the imposition of life without parole, even if it were not mandatory, is unconstitutional to people in that age group. The judge heard testimony by experts in the fields of adolescent neurological and psychological development and made several important findings of fact that resulted in his ruling. Emerging adults, like juveniles, still have developing brains. The judge found that because certain regions of their brains have not yet fully developed, they are: 1) more impulsive than older individuals; 2) more prone to risk taking in pursuit of reward; 3) more susceptible to influence by peers; and 4) have a greater capacity for change compared to older individuals due to the plasticity of their brains. In a 4-3 ruling, the SJC accepted these findings ruling that emerging adults are more like juveniles than adults and extended the Diatchenko ruling to people in that age group.

Until this ruling, a person like Sheldon Mattis, who was convicted of first-degree murder for a death that occurred when he was 18 or older faced a mandatory sentence of life without the possibility of parole. Now, a life without parole sentence cannot be imposed against an individual who committed the murder between the ages of 18 to 20. The ruling is retroactive, meaning those already convicted for murders they committed when they were 18 to 20 will become eligible to apply for parole.

The Committee for Public Counsel Services (the public defender’s office) has informed the defense bar that the Parole Board is compiling a list of people eligible for relief from this ruling. Once CPCS receives that list they will begin notifying the people on the list and appointing lawyers for their representation at parole hearings. People seeking more information can call CPCS (617-482-6212) and ask for the Mattis Information Line.