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  • Constantino Themelis

Mass Supreme Court Raises Life without Parole Sentencing from 18 to 21  

Courtesy of Blogtrepreneur

January 15, 2024, marked a revolutionary day in the world of juvenile justice. The Supreme Judicial Court of Massachusetts (SJC) ruled 4-3 in favor of changing the age at which one can be sentenced to life without parole from 18 to 21, a ruling that has sent waves throughout the nation. The one-of-a-kind case has been a unique fusion of law, neuroscience, and critical theory. Most importantly, it may be the pioneering ruling of cases aiming to limit incarcerated young adults in the United States.  It dates back to an incident in Dorchester, Boston, and a following trial in Suffolk County over ten years ago. 

On September 25, 2011, 18-year-old Sheldon Mattis handed 17-year-old Nyasani Watt a handgun telling him to go handle that. He was referring to Javion Blake and his friend Kimoni Elliott who were outside of a convenience store. Watt opened fire on the two boys. Elliott survived his wounds while Blake passed away. 

At his trial in 2013, Mattis was sentenced to life without parole on the charge of first-degree murder. The co-defendant, Watt, just a year younger, was given an opportunity for parole after 15 years. The case has returned to the spotlight due to recent research on young adult brain development. 

For some, the spotlight never went away. Ruth Greenberg, an attorney from Swampscott, Massachusetts, has been working on the case for over a decade. Greenburg saw the potential impact that overturning the case may have in allowing incarcerated people a second chance. “People who were entire without hope, who have reformed themselves, now have an opportunity to return to the world to show the Parole Board what they've done and who they are, and that they are better than they were on their worst day,” she told GBH News.

After going through the Massachusetts appellate courts, the case made it to the Supreme Judicial Court. The ultimate legal question in the case was whether or not young adults being sentenced to life without parole violated the Eighth Amendment which bans cruel and unusual punishment.

The legal argument by those representing Mattis was centered upon Commonwealth v. Diatchenko (2013), the precedent case that barred juvenile life without parole sentences. This case acknowledged a “lack of maturity and an underdeveloped sense of responsibility” in juveniles. Using this and multiple amicus briefs from top local brain scientists and criminal justice researchers, Mattis’ attorneys successfully convinced the court that “the brains of emerging adults are similar to those of juveniles.” 

Antiracist reasoning was also cited ina separate amicus brief created by the Boston University Center for Antiracist Research, and the Criminal Justice Institute at Harvard Law School, among others. The brief highlighted that Black people are overrepresented in Massachusetts prisons and that Black 18-20 year-olds are far more likely than White 18-20 year-olds to be sentenced to die in prison. To them, this ruling was not only scientifically founded but provided an opportunity for the court to avoid a process that would be destined to repeat, i.e young Black children being incarcerated during a time when they are not, in the words of Chief Justice Kimberly Budd, irretrievably depraved”. 

The “arbitrariness”, as the group of antiracist researchers described it, was agreed upon by the concurring judges. Judge Dalia Argaez Wedlandt argued in her dissent that, “condemning a person in the process of ‘growing up’ to die in prison on the basis that she falls on the ‘wrong’ side of an arbitrary line drawn at age eighteen is inconsistent with ‘the evolving standards of decency that mark the progress of a maturing society"’.

The issue of arbitrary age-based sentencing resides within the Mattis case itself. Nyasani Watts, Mattis’ accomplice, was only a few months younger than him and received parole after 15 years. Could there be so much of a developmental difference between the two that Mattis could make a better decision while Watts could not?

Not all have been singing praises of the ruling, however. Many worry about the ramifications of allowing a court to make such a huge decision. Justice David A Lowy of the SJC offered a different opinion in his dissent, claiming that it is not the job of the Massachusetts High Court to determine what is “cruel or unusual”. That job is an “exclusively legislative function”, according to Lowy. Sentencing, punishment practices, and personal sanctions are all functions of the legislature on the federal and local levels. The Supreme Court can intervene when this is done unconstitutionally, Lowy says, but infringing on the power of the legislative branch poses an issue to the balance of power in our three-branch government. 

The legislature in Massachusetts had previously established that for those over 18, life without parole was the standard. The SJC examines the constitutionality of how the legislature acts, but can only overturn a “cruel and unusual”  if it is "so disproportionate" that it "shocks the conscience and offends fundamental notions of human dignity" (see Cepulonis v.Commonwealth). The level of cruelty was not enough for Lowy to consider making the momentous decision of overturning the established precedent. Exercising restraint and upholding the Massachusetts Declaration of Rights and Eighth Amendment was too important and the case did not break the basis of human decency to the extent needed to do so. 

The case is sure to cause a rumbling all over the nation and invigorate those looking to overturn similar sentencing laws for young developing people.

Attorney Greenberg put it best when describing what this ruling could mean for other states, “It’ll be like little popcorn going off, first the other bifurcated states, then the non-bifurcated states, then the federal Constitution”. Similar to the way Miller v. Alabama (2012) opened up petitions for resentencing by those given life without parole as juveniles, the Mattis case may serve as a valuable precedent for others looking to get sentences reduced and the points made by the attorney group of Mattis are likely to be used by many. While some view this as a victory of science and reason over archaic cruelty, those like Justice Lowy worry about the increasing judicial power in the United States. From the Mattis case to the overturning of Roe v. Wade (1973), the high court systems seem to be exerting a disproportionately large amount of influence on policy and morality throughout the nation. 

Affording a second chance to those who simply hadn’t developed enough at the time of offending may be an honorable cause for some, but will we put too much political power in the hands of the Supreme Court system by doing so?


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