Published on: Thursday, January 11, 2024

The Massachusetts Supreme Judicial Court ruled Thursday that anyone under the age of 21 cannot be sentenced to life in prison without the possibility of parole, finding such a sentence constitutes “cruel or unusual punishment” under the Massachusetts Constitution. (article available here).

The court had previously ruled in 2013 that defendants under 18 could not be sentenced to life without parole based on the notion that “it is not possible to demonstrate that a juvenile offender is ‘irretrievably depraved,’” thus any such sentence is “cruel or unusual as imposed on a juvenile in any circumstance.” Thursday’s ruling in Commonwealth v. Sheldon Mattis essentially extends that finding up to age 21.

“The judge’s findings in this case ... confirm that the brains of emerging adults are similar to those of juveniles,” Supreme Judicial Court Chief Justice Kimberly S. Budd wrote in the ruling.

In 2013, Mattis was convicted of murder in the shooting death of Jaivon Blake in 2011 — when Mattis was 18. He was sentenced to life without parole. His co-defendant, who was 17, was sentenced to 15 years.

With this decision, Massachusetts became the first state to forbid life sentences without the possibility of parole for people under 21.

Those convicted while under 21 will still be required to serve 15 years or a minimum term and make their case to the parole board for a chance to serve the rest of their sentence outside bars.

In the leadup to the decision, some also focused on the racial justice component that such a ruling would have. Researchers filed an amicus brief, finding that, in Massachusetts, "Black people are serving [life without parole] for offenses at ages 18-20 at a rate more than sixteen times the rate for White people."