Youth Matters

In one of the most anticipated opinions of recent years, the Massachusetts Supreme Judicial Court recently considered whether sentencing 18–20-year-olds convicted of first-degree murder to mandatory life in prison without the possibility of parole constitutes “cruel or unusual punishment.” They ruled that it does.

The case involved Sheldon Mattis, who was 18 when he was involved in the shooting death of a 14-year-old boy in Boston. Mattis was convicted of first-degree murder and given the mandatory sentence of life without parole. On appeal, Mattis argued the sentence was unconstitutional as applied to 18–20-year-olds based on research showing their brains are still developing.

The seeds of this decision were sown by a 2013 ruling in Commonwealth v. Diatchenko, in which the court held that Juvenile homicide offenders cannot be sentenced to life in prison without the possibility of parole. If convicted, a juvenile offender could be sentenced to life in prison, but a statute that made parole impossible in cases of murder, could not be applied to juvenile offenders. The court relied on the “unique characteristics of juvenile offenders” and prior rulings to conclude that juvenile homicide offenders must be given a meaningful opportunity for release based on demonstrated maturity and rehabilitation.

In Commonwealth v. Mattis, the SJC extended its Diatchenko, ruling that the “unique characteristics” of 18 – 20-year-olds, including impulsivity, susceptibility to peer pressure, and capacity for change, make the harsh sentence disproportionate.

Chief Justice Kimberly Budd opened her opinion with a powerful statement of the court, “When it comes to determining whether a punishment is (cruel or unusual), youth matters. The court relied on scientific research showing the brains of 18–20-year-olds are more like juveniles than fully mature adults.

Experts testified that key areas of the brain governing impulse control and decision-making do not fully develop until the mid-20s. The court also cited state laws that treat 18–20-year-olds as an intermediate category between juveniles and adults.

While acknowledging the legislature has the authority to set punishment, the court said it must ensure sentences comply with the state constitution. It concluded contemporary standards of decency do not support imposing the harshest sentence on 18–20-year-olds. Only 10 other states still mandate life without parole starting at 18.

The court did not categorically ban life without parole for 18–20-year-olds but said the legislature must provide parole eligibility. For those like Mattis sentenced before 2014, eligibility will be after 15 years.

The decision brings Massachusetts in line with a small but growing number of states reconsidering harsh sentences for young adult offenders.