In a landmark decision, the Massachusetts Supreme Judicial Court has ruled that sentencing individuals aged 18 to 20 to life without the possibility of parole is unconstitutional, violating Article 26 of the state’s Declaration of Rights. This ruling reflects a significant shift in the legal treatment of emerging adults in the criminal justice system.
The court’s decision was influenced, in part, by a comprehensive review of scientific research on brain development. It concluded that the brains of 18 to 20-year-olds are more similar to those of juveniles than to older adults. This similarity extends to characteristics like impulse control, risk-taking behavior, and susceptibility to peer influence.
Understanding the Emerging Adult Brain
The court’s decision was heavily influenced by research on the neurological development of emerging adults. Key aspects considered include:
- Impulse Control: Emerging adults exhibit impulse control more akin to teenagers than older adults. Their prefrontal cortex, responsible for regulating impulses, is not fully developed, leading to more impulsive decisions in emotionally charged situations.
- Risk-Taking Behavior: This age group is more prone to risk-taking, driven by increased activity in brain regions associated with sensation seeking. The tendency to engage in risky behaviors peaks in late adolescence to early adulthood and then declines.
- Susceptibility to Peer Influence: Research indicates that the mere presence of peers significantly increases the likelihood of adolescents engaging in risky behavior. This susceptibility to peer influence is a potent factor during adolescence and diminishes with age.
Legal precedents, both in Massachusetts and the U.S. Supreme Court, emphasize the importance of considering these youthful characteristics in sentencing. The decision aligns with contemporary standards of decency, both within the Commonwealth and in a broader context, indicating a trend away from the harshest sentences for young adults.
Mass Attorney General agrees with court ruling
Attorney General Andrea Joy Campbell issued the following statement on the Massachusetts Supreme Judicial Court’s decision in Commonwealth v. Mattis in which the court held that it is a violation of the state constitution to sentence adults under the age of 21 to life in prison without the possibility of parole.
“Today’s ruling underscores the importance of our legal system acknowledging the ongoing brain development of young people in order to improve public safety, reduce recidivism and deliver justice,” said AG Campbell. “The science emphatically demonstrates that young people have an extraordinary capacity to change and mature, and our justice system should provide them the invaluable opportunity to turn their lives around and fulfil their potential.”
Outcomes at the center of focus
In September 2023, AG Campbell testified in support of An Act to promote public safety and better outcomes for young adults, more commonly known as legislation to “Raise the Age”, reflecting the latest brain development science, aligning closely with today’s ruling. The legislation would raise the age of juvenile court jurisdiction to include 18-, 19-, and 20-year-olds over the course of five years, a move that would improve outcomes for young people and enhance overall public safety.
In terms of practical implications, the court specified that for emerging adults convicted of first-degree murder, parole eligibility would align with standards set for juvenile offenders. This adjustment means a minimum term of 20 to 30 years, depending on the nature of the crime, contrasting with the previous sentence of life without parole.
The ruling also has implications for those previously sentenced under the old statute. Emerging adults sentenced to life without parole before legislative changes in 2014 will now be eligible for resentencing, potentially reducing their terms to life with the possibility of parole after fifteen years.
Not a Get-Out-of-Jail-Free card
This decision does not diminish the severity of first-degree murder committed by emerging adults. Instead, it recognizes their unique developmental stage and potential for rehabilitation. The Massachusetts parole board will now evaluate these individuals based on their maturity and actions since their conviction, offering a meaningful opportunity for release.
Following the ruling by the Mass SJC, many long-time sentencing reform activists and justice workers were in a celebratory moom on Thursday. ACLU of Massachusetts attorney Jessica Lewis recommended that state legislators build upon the decision by elevating the juvenile court’s age jurisdiction, aiming to lower the number of youths prosecuted as adults.
“The Supreme Court is right: Sentencing an emerging adult to die in prison is cruel and unusual punishment,” Lewis wrote in a statement. “This decision is an important step for our criminal justice system – and a life-changing step for the many Bay Staters who are now eligible for parole.”
The court’s conclusion, requiring resentencing consistent with its opinion, marks a pivotal change in how the legal system views and treats emerging adults. It underscores the need for sentencing practices that consider the developmental differences and rehabilitation potential of this age group.
Capacity for Change
The Court also weighed research that suggests emerging adults have a significant ability to forge genuinely new paths for behavior and ability to establish mature, healthy patterns of interacting, The court found that emerging adults have a greater capacity for change than older individuals due to the plasticity of their brains during these years. This finding is robustly supported by the record.
Brain Plasticity: Plasticity refers to the brain’s ability to change in response to the environment. The brain experiences a significant wave of plasticity during adolescence, as explained by Dr. Adriana Galván. This is in contrast to adults, whose capacity for change is diminished due to the reduced malleability of a fully mature brain.
Maturation Timeline: Brain maturation is largely complete by as early as 22 years of age and possibly up to 25 years of age. Despite lifelong changes, the intensity of brain plasticity and the capacity for significant change are much higher in emerging adults.
Implications for Offending Behavior: The majority of adolescents, even those who commit serious crimes, will “age out” of offending and are unlikely to become career criminals. This aligns with research indicating that the impetuousness and recklessness of younger years often subside as individuals mature.
Future Implications
By setting a new standard in the sentencing of emerging adults, the Massachusetts Supreme Court’s decision in COMMONWEALTH vs. SHELDON MATTIS opens the door for similar reforms in other jurisdictions. This ruling underscores the importance of aligning legal practices with contemporary scientific understanding and societal norms, advocating for a system that offers young adults a chance for redemption and growth.
The court’s conclusion, requiring resentencing consistent with its opinion, marks a pivotal change in how the legal system views and treats emerging adults. It underscores the need for sentencing practices that consider the developmental differences and rehabilitation potential of this age group.
