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Some young adults can no longer be sentenced to life without the possibility of parole if convicted of first-degree murder, court rules

Update: Some 70 people convicted in Suffolk County could have their sentences changed to add the possibility of parole based on the rulings, the Suffolk County DA's office reports.

The Supreme Judicial Court today extended a ban on automatic parole-less life sentences for teens convicted of first-degree murder to people as old as 20.

The ruling comes in two Boston cases involving men who were 18 and 19 at the time of the murders they were convicted of participating in - the murder of an adult man in Brighton in 2000 and the murder of a 16-year-old in Dorchester in 2011 . The ruling does not mean they go free, but that judges in Superior Court will have to hold hearings to determine when they should become eligible for consideration of parole.

In a third, related case, a man convicted on first-degree murder in the Dorchester case will get a new trial because his lawyer slept through key parts of his trial, the court ruled.

The age rulings stem from a 2013 case in which the state's highest court ruled that automatically sentencing people convicted of first-degree murders committed when they were 18 or younger to life without parole was cruel and unusual punishment, which is unconstitutional. "Based on precedent and contemporary standards of decency in the Commonwealth and elsewhere," people who are 19- or 20-year-old "emerging adults" deserve the same consideration, the court said today.

The court constructed its new legal framework for first-degree murder convictions in detail in the case of Sheldon Mattis, who was convicted, along with Nyasani Watt, for gunning down 16-year-old Jaivon Blake outside a convenience store on Geneva Avenue in Dorchester in September, 2011.

Watt shot Blake to death after Mattis handed him a gun and told him to "go handle that," referring to Blake and another teen Blake was with. Watt rode up behind them on a bicycle and opened fire, killing Blake and wounding the other teen. At the time of the murder, Mattis was 18 and Watt 17, but just days from his 18th birthday. Mattis was sentenced to life without parole, Watt, because he was still 17, got life, but with the possibility of parole after 15 years.

The court initially denied Mattis's request for reconsideration of his sentence, but sent the case back to Suffolk Superior Court for hearings on whether the immature brains of young people meant a lifelong prison term was unfair. And, the court concluded, in agreement with a Superior Court judge that it is:

Advancements in scientific research have confirmed what many know well through experience: the brains of emerging adults are not fully mature. Specifically, the scientific record strongly supports the contention that emerging adults have the same core neurological characteristics as juveniles have. As the Superior Court judge noted, "Today, neuroscientists and behavioral psychologists know significantly more about the structure and function of the brains of [eighteen] through [twenty year olds] than they did [twenty] years ago . . . ." This is the result of years of targeted research and greater access to relatively new and sophisticated brain imaging techniques, such as structural magnetic resonance imaging (sMRI) and functional magnetic resonance imaging (fMRI). From the detailed evidence produced in the record, the judge made four core findings of fact regarding the science of emerging adult brains: emerging adults (1) have a lack of impulse control similar to sixteen and seventeen year olds in emotionally arousing situations,15 (2) are more prone to risk taking in pursuit of rewards than those under eighteen years and those over twenty-one years, (3) are more susceptible to peer influence than individuals over twenty-one years, and (4) have a greater capacity for change than older individuals due to the plasticity of their brains. The driving forces behind these behavioral differences are the anatomical and physiological differences between the brains of emerging and older adults. See Steinberg, A Social Neuroscience Perspective on Adolescent Risk-Taking. These structural and functional differences make emerging adults, like juveniles, "particularly vulnerable to risk-taking that can lead to poor outcomes."

The justices noted that the state legislature has long made 21 the cut-off for other activities, for example, being allowed into a casino. In a concurring opinion, Justice Dalila Argaez Wendlandt wrote that after reviewing, among other things, state statutes, the scientific record and common sense:

I conclude that they confirm what any parent of adult children can tell you: a child does not go to bed on the eve of her eighteenth birthday and awaken characterized by a lessened "transient rashness, proclivity for risk, and inability to assess consequences." Miller v. Alabama, 567 U.S. 460, 472 (2012). In recognition of this indisputable fact, society does not treat the transition from childhood to adulthood as a binary act accomplished at age eighteen; becoming an adult is much more fluid, with development continuing long after a child's eighteenth birthday. In the ways that matter for the Commonwealth's harshest punishment, young adults of the ages of eighteen, nineteen, and twenty share key characteristics with their under-eighteen year old peers; they "have diminished culpability and greater prospects for reform" than older adults and "are less deserving of the most severe punishments." ... For this reason, 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 court also ordered a new sentencing hearing for Jason Robinson, in prison for his part in the murder of Iman Yazbek, a 35-year-old landscaper shot point-blank in the head in a robbery arranged by the man's teen-age girlfriend at the Faneuil housing development in Brighton in March, 2000. The court rejected Robinson's arguments that he got an unfair argument, but said that because of his age at the time of the killing, he should not automatically be forced to spend the rest of his life in prison.

In a separate ruling, the court concluded that Watt, who pulled the trigger on the two teens in Dorchester, deserves an entirely new trial, not because of his age, but because his lawyer was asleep during significant parts of the trial - way more so than could be attributed to a lawyerly closed eyes as a way of showing disdain for his opponent's arguments:

Based on the affidavits, multiple people had observed trial counsel sleeping during trial. The defendant asserts that trial counsel slept recurrently and during significant moments, such as jury selection and the testimony of two witnesses, possibly including Jeremiah Rodriguez, a central prosecution witness. Codefendant Mattis confirmed that the defendant's trial counsel slept repeatedly during trial, naming two specific occasions, including the testimony of an emergency medical technician and the victim's younger brother. One of the prosecutors at trial had contemporaneously discussed with a colleague and one of codefendant's counsel that trial counsel slept on several distinct occasions, including one where the prosecutor had to rouse trial counsel to review a photograph before it was shown to the testifying witness. One attorney for the codefendant confirmed that trial counsel slept at least once during testimony; the other attorney for the codefendant stated that trial counsel's eyes were closed several times throughout the trial. The defendant's mother also confirmed the repetitiveness of trial counsel's sleeping during trial.

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PDF icon Complete Mattis ruling472.52 KB
PDF icon Conmplete Robinson ruling141.38 KB
PDF icon Complete Watt ruling118.58 KB


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Parole Board is still the gatekeeper and can keep them locked up for their natural lives.

Voting closed 1

And they should! Have yet to hear one of these sob-stories that made me feel for the murderer.

Voting closed 2

Do you go to a lot of Parole Board hearings?

Voting closed 1

But not with this ruling. The frontal cortex doesn’t full mature until about 25. But the 18 year old brain is mature enough to know that murder is wrong. We entrust 18 year olds with guns to shoot enemies and not shoot civilians in wars.

Voting closed 1

We entrust 18 year olds with guns to shoot enemies and not shoot civilians in wars

Ever consider that the inability to say no to carrying out such orders/shooting at specific (and nonspecficic) groups of people when told to without considering the implications is why 18 year olds are recruited for such tasks?

Voting closed 2

With a gun with the intent to murder is wrong by 18. Your parents have failed you and you’re no longer a productive member of society.

Voting closed 1

In the case of one who is engaged in state-sponsored killings (i.e., cops, military), do brains magically mature before the age of 25?

Voting closed 1