The elimination of life without parole for murder defendants between the ages of 18 and 20 will have significant effects on the criminal justice system in Massachusetts. Specifically, it means that the Commonwealth now has less leverage over defendants within this age bracket as they approach a major choice: Pleading guilty or heading to trial. While this choice is important for virtually any defendant, the stakes are obviously much higher if a defendant stands to lose any hope of ever being released. The exact effects of this change in the criminal justice system are somewhat nuanced.
Commonwealth vs. Sheldon Mattis
In January of 2024, the Commonwealth confirmed that mandatory life imprisonment without parole is unconstitutional for juveniles. Referring to a previous case in 2013 (Diatchenko I), the Supreme Judicial Court found that this protection against mandatory life imprisonment should extend to “emerging adults.” The court defines emerging adults as those who were 18, 19, or 20 at the time they committed their crimes. In Commonwealth vs. Sheldon Mattis, the defendant successfully challenged the constitutionality of his sentence of life without parole, and this argument was successful.
The case revolves around a shooting incident that occurred at a parking lot. While the defendant did not pull the trigger, he was accused of handing his codefendant a weapon and telling him to “handle that” – referring to the presence of two individuals nearby. One victim survived the shooting, while the other succumbed to their wounds. Part of the trial was devoted to the subject of neurological development among teens, and it included testimony from medical experts.
The issue at hand was whether "emerging adults" are capable of making informed decisions due to their brain development process and whether this should represent a mitigating factor for criminal offenses such as murder. The defendant was 18 at the time of the shooting. Ultimately, the defense counsel’s arguments proved was rejected by the trial court, and the defendant was sentenced to life without the possibility of parole. The defendant filed a motion for a new trial, arguing that the sentence violated constitutional prohibitions on cruel or unusual punishments.
However, the courts denied all of these efforts and upheld the sentence. In the following years, however, the subject of neurological development among teens continued to take center stage, with a different Superior Court judge stating that emerging adults are “less able to control their impulses.”
What This Decision Means
Before this case, an "emerging adult" was forced to choose between a trial and a plea deal. The trial came with significant risks, as there was a serious chance of never being released. On the other hand, a plea deal guarantees at least the possibility of release. Now, the prospect of life without parole has been eliminated – giving defendants more autonomy to make a choice that aligns with their values and priorities.
Some speculate that some day the SJC may decide to extend the rule against life without parole to adults. It seems unlikely to happen in our lifetime, but it is cerainly possible. in particular, the SJC in this case decided to take the statute fixing a term for parole between 20 and 30 years. It could have, instead, found unconstitutional the provision making life without parole mandatory, and thereby allowed people to be sentenced to life without parole but making the choice discretionary. This is how it works for juveniles in many states, and may be the next reform that Massachusetts sees towards the elimination of life without the possibility of parole.