## Facts

- Sheldon Mattis was convicted in Massachusetts Superior Court of murder in the first degree and related offenses and received a mandatory sentence of life in prison without the possibility of parole (LWOP) under G. L. c. 265, § 2 (a), because he was 18 years old at the time of the offense.
- The offense occurred on September 25, 2011, when Mattis (18) and codefendant Nyasani Watt (17) targeted two young men, Jaivon Blake and Kimoni Elliott, after Mattis believed Elliott’s statement about being from “Everton” suggested a rival gang association.
- According to the record summarized in secondary sources, Mattis pointed out the victims to Watt and provided Watt with a bicycle and a gun; Watt approached the victims and fired multiple shots, killing Blake and wounding Elliott.
- Because Watt was 17 at the time of the crime, he was sentenced to life with the possibility of parole under Massachusetts law applicable to juvenile homicide offenders.
- On direct review, the Supreme Judicial Court (SJC) affirmed the convictions in *Commonwealth v. Watt*, 484 Mass. 742 (2020), but remanded for further findings on Mattis’s as-applied constitutional challenge to mandatory LWOP.
- After an evidentiary hearing, the Superior Court judge issued findings of fact and rulings of law rejecting Mattis’s claim that mandatory LWOP for an 18-year-old violates art. 26 of the Massachusetts Declaration of Rights.
- Mattis appealed again, and the full SJC considered whether Massachusetts may impose mandatory LWOP on “emerging adults” (offenders aged 18–20 at the time of the offense).

## Issues

1. Whether sentencing an offender who was 18 years old at the time of committing murder in the first degree to a mandatory term of life in prison without the possibility of parole violates art. 26 of the Massachusetts Declaration of Rights (cruel or unusual punishment).
2. If mandatory LWOP is unconstitutional for offenders aged 18–20, what remedy applies under Massachusetts sentencing statutes for first-degree murder.
3. Whether the constitutional rule announced applies to individuals already serving LWOP for crimes committed at ages 18–20.

## Decision

- The SJC held that sentencing “emerging adults”—persons aged 18, 19, or 20 at the time of the offense—to life in prison without the possibility of parole violates art. 26 of the Massachusetts Declaration of Rights.
- The court declared unconstitutional, as applied to offenders who were 18–20 at the time of the offense, the portions of G. L. c. 265, § 2 (a) and G. L. c. 127, § 133A that make first-degree murder sentences parole ineligible.
- The SJC extended its state constitutional rule from *Diatchenko v. District Attorney for the Suffolk Dist.*, 466 Mass. 655 (2013), which barred LWOP for those under 18, to cover the “emerging adult” group (18–20).
- For the remedy, the court looked to the next-most severe sentencing option within the statutory scheme and converted emerging-adult LWOP sentences to life with the possibility of parole, with parole eligibility determined by the applicable statutory minimum term.
- The court emphasized that parole eligibility does not guarantee release; it provides a meaningful opportunity to seek release based on maturity and rehabilitation, with the Parole Board evaluating the circumstances of the offense and the individual’s development and conduct since conviction.
- The ruling applies retroactively, affecting individuals already serving LWOP for first-degree murder committed when they were 18–20.

## Legal Principles

- Art. 26 of the Massachusetts Declaration of Rights can provide broader protection than the Eighth Amendment and forbids punishments that are “cruel or unusual” under contemporary standards of decency.
- Age is constitutionally significant in sentencing because late adolescents have reduced culpability and greater capacity for change than fully mature adults; these traits bear on proportional punishment.
- Mandatory LWOP is especially suspect because it removes any mechanism to consider youth-related mitigation and forecloses the possibility of release based on demonstrated rehabilitation.
- For emerging adults (18–20), the SJC treated developmental science and legal trends as supporting the conclusion that categorical parole ineligibility is disproportionate under art. 26.
- When a sentencing provision is unconstitutional as applied, the court may invalidate only the parole-ineligibility component for the affected class and apply the next-most severe lawful sentencing option to preserve the broader statutory framework.
- A constitutionally sufficient remedy for excessive punishment in this context is a parole-eligible life sentence that provides a real opportunity to seek release based on maturity and rehabilitation, while leaving release decisions to the Parole Board.

## Conclusion

*Commonwealth v. Mattis* holds that Massachusetts may not impose mandatory life without parole on individuals who were 18, 19, or 20 at the time of committing murder in the first degree because such sentences violate art. 26’s ban on cruel or unusual punishment; the court invalidated the parole-ineligibility provisions as applied to that age group and required that these offenders be treated as serving life sentences with the possibility of parole, with the rule applying retroactively.


Commonwealth v. Mattis, 493 Mass. 216 (2024)