Friday, January 19, 2024
Massachusetts Supreme Judicial Court’s decision bans life without parole sentences for people under age 21
By Noelle Gulick, 3L Northeastern Law
On Thursday January 11, 2024, the Massachusetts Supreme Judicial Court (SJC) released an important decision stating that life without parole (LWOP) sentences for people under 21-years-old are unconstitutional. The case is Commonwealth v. Sheldon Mattis, and the court raised the minimum age that a person can be sentenced to LWOP to 21-years-old. Before this decision, the age was 18-years-old. Extending the decision to those who are 18-, 19-, and 20-years-old is a strong step in the right direction of protecting the human rights and dignity of these people.
In this case, Mattis argued that his mandatory sentence of life without parole violated the Massachusetts state constitution’s article 26 which prohibits cruel and unusual punishment. He argued that it is cruel and unusual to expect someone, especially a child or “emerging adult”, to spend the rest of their life in prison without any possibility of being released even on parole.
The court looked at new research on brain development after the age of 17, diminished culpability, social science, susceptibility to peer influence, and the greater capacity for change that younger people have. The court stated that this category of “emerging adults” (18-, 19-, and 20-year-olds) have many of the same “neurological characteristics” as kids under 18-years-old have.
It has been accepted that LWOP nationwide is not a suitable sentence for kids under 18. However, Massachusetts is the first state in the United States to ban life without parole sentences for people under 21, following the lead of other nations, international standards, and human rights law.
The court’s analysis included a look at other nations’ decisions and international statutes, noting that the UK has banned life without parole for anyone under 21 at the time of the offense. It also noted that Canada has ruled that life without parole is unconstitutional for anyone, no matter the age. Life without parole sentences, particularly for young people, are widely condemned under international law. One of the concurring opinions in this case cited the Convention on the Rights of the Child. There are several human rights treaties that condemn juvenile life without parole including the International Covenant on Civil and Political Rights, the Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, the Convention on the Elimination of All Forms of Racial Discrimination, and the Convention on the Rights of the Child.
The ruling is retroactive, which means that people who have already been sentenced to life without parole for something that occurred when they were 18-20-years-old will soon be eligible to apply for parole. This means that about 70 people who were convicted in Suffolk County will become eligible for parole.
This decision is a step towards limiting the large number of life without parole sentences that are given in the United States, protecting the human rights of people facing these sentences, and to the United States following international legal norms.
https://lawprofessors.typepad.com/human_rights/2024/01/massachusetts-supreme-judicial-courts-decision-bans-life-without-parole-sentences-for-people-under-a.html