Brief of Amici Curiae for the Eastern District Attorney
Jonathan W. Blodgett
David F. O'Sullivan
SimpleOriginal

Summary

This Court should follow the majority of states and decline to extend Miller to defendants who were 18 at the time of the crime.

2022 | State Juristiction

Brief of Amici Curiae for the Eastern District Attorney

Keywords murder; emerging adults; mandatory LWOP; mandatory life without parole; disproportionate; Eighth Amendment (U.S.); 18-year-olds; young adults; brain development; neuronal immaturity; Diatchenko; Miller
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Summary of Argument

In Miller v. Alabama, 567 U.S. 460 (2012), relying on developmental science first noted in Roper v. Simmons, 543 U.S. 551 (2005), the United States Supreme Court held that the 8th Amendment1 bars mandatory LWOP for juvenile offenders, and mandates an individualized sentencing hearing that considers the hallmark features of youth -- the so-called “Miller factors”2 -- before sentencing such a juvenile to LWOP. Citing this same science, this Court held in Diatchenko v. District Attorney for the Suffolk Dist. (Diatchenko I), 466 Mass. 655, 668 (2013) that Art. 263 provides greater protections, and bars even discretionary imposition of LWOP for juveniles. For the purpose of both rules, “juveniles” were defined as those under age 18. Diatchenko I, 466 Mass. at 659 & n. 8 (“When we use the term ‘juvenile’ offenders here, we are referring to defendants who were under the age of eighteen at the time they committed murder in the first degree. See G.L. c. 119, § 72B, as amended through St. 2013, c. 84, § 24.”).

Defendants Sheldon Mattis and Jason Robinson were, respectively, 18 and 19 at the time of their commission of first-degree murder.4 Under G.L. c. 265, § 2, both were sentenced to mandatory LWOP. They now have proffered developmental science, most post-dating Diatchenko, which finds among 18 to 20 year olds markers of neuronal immaturity similar to juveniles. The proffered science pertains to average neuronal immaturity in this age set; it was not particularized to these defendants. The defendants’ essential claim was straightforward: since the science shows developmental similarities among juveniles and 18-20 year olds, art. 26 at a minimum forbids mandatory imposition of LWOP for this age group, and requires Miller hearings before the imposition of any such sentence. 5 On remand order of this Court, the Superior Court (Ullman, J.) conducted an evidentiary hearing at which the affidavits and testimony of four experts were admitted -- Dr. Laurence Steinberg, a developmental psychologist; Dr. Adriana Galvan, a developmental cognitive neuroscientist; and Drs. Robert Kinscherff and Stephen Morse, both attorneys and forensic psychologists. Ullman decision, 10-11. Also admitted were seven scientific articles ranging from 2008 to 2022, six of which were co-authored by Drs. Steinberg and/or Galvan. Id. On the basis of this evidence, Judge Ullman made certain “core findings” concerning age and brain development, id. at 15-18, and held on the basis of those findings that art. 26 forbids mandatory LWOP for 18-20 year olds. Id. at 2. Following remand, though the vast majority of Courts have declined to extend Miller to legal adults,6 the defendants ask this Court to join one state, Washington, that has extended Miller to 18 through 20 year olds,7 and one other, Michigan, that has extended it to 18 year olds,8 each over vigorous dissents.

The Court should not accept this invitation. In deciding the question, this Court should strictly apply its own tripartite standard for evaluating punishments as “cruel or unusual” under art. 26.9 Applying this standard is essential because it demarcates the boundary between legislative and judicial functions mandated by art. 30.10 Adherence to it ensures that legislative prerogatives are not trespassed, that an ongoing democratic process is not short-circuited, and that constitutional analysis does not become a proxy for imposition of the policy preferences of the judiciary. Application of that standard would hold the current sentencing scheme constitutional, in light of the gravity of the crime and nature of offender in this older age group, the punishments for other offenses, and those in other jurisdictions for the highest degree of murder. While Judge Ullman’s core findings are not clearly erroneous, for the reasons that follow, they do not compel differing constitutional treatment for 18-20 year olds than for those 21 and older.

An additional threshold point bears noting. While the defendants’ claims pertain only to sentencing, the developmental science on which the defendants rely does not. The proffered science is also plainly relevant to and, per decisions of this Court, may be used to litigate a defendant’s mental state at the time of the crime in the guilt phase. See Commonwealth v. Fernandes, 487 Mass. 770, 782 (2021), cert. denied sub nom. Fernandes v. Massachusetts, 142 S. Ct. 831 (2022)(permitting expert testimony with respect to “‘general principles and characteristics of the undeveloped adolescent brain’ when it is accompanied by other evidence, such as testimony by a different expert, or medical or school records, specific to the defendant”). Post-trial, it may be used to argue for a reduction of the degree of murder under G.L. c. 278, § 33E or Mass. R. Crim. P. 25(b)(2), or in support of a new trial motion, again where particularized to an individual defendant. See Commonwealth v. Johnson, 486 Mass. 51, 69 & n. 16 (2020)(“We agree that the mental maturity of an individual defendant is relevant to our analysis under § 33E.”). The question before this Court concerns the legislature’s ability to fix punishment for those in this age group after they were convicted, in a fair trial and beyond a reasonable doubt, of the required elements of first degree murder.

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Summary

This case examines whether the Eighth Amendment and Article 26 of the Massachusetts Constitution prohibit the mandatory sentence of life without parole (LWOP) for individuals between the ages of 18 and 20 convicted of first-degree murder. The defendants argue that recent scientific findings concerning brain development in young adults support extending the protections of Miller v. Alabama to this age group. The defendants rely on scientific evidence demonstrating that individuals between 18 and 20 exhibit characteristics similar to juveniles in terms of brain development. This evidence suggests that these individuals may not be fully responsible for their actions due to their continued brain maturation.

The Court is tasked with deciding whether the legislature's imposition of mandatory LWOP for this age group violates constitutional protections against cruel and unusual punishment. The Court must carefully consider the legislative function and balance it against the judiciary's role in ensuring constitutional compliance. The Court must also consider the severity of the crime, the nature of the offender, and the punishments for similar crimes in other jurisdictions.

The defendants also highlight that this scientific evidence can be used in other legal contexts, including challenging the defendant's mental state at the time of the crime, arguing for a reduction in the degree of murder, or seeking a new trial. However, the Court's focus remains on the constitutionality of the legislature's sentencing scheme for those convicted of first-degree murder within this specific age range.

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Summary

The court is tasked with deciding whether the 8th Amendment and Article 26 of the Massachusetts Constitution require a Miller hearing for individuals who were 18-20 years old at the time of committing a crime, specifically first-degree murder. The defendants argue that developmental science shows that individuals in this age group share similar brain development patterns to juveniles. This leads them to claim that mandatory LWOP (Life Without Parole) should be unconstitutional for them and that a Miller hearing should be required before sentencing. The court must weigh this argument against its own established tripartite standard for evaluating punishments as “cruel or unusual.” This standard requires considering the gravity of the crime, the punishment for other offenses, and punishments in other jurisdictions. The court must also consider the legislative prerogative and the ongoing democratic process. Ultimately, the court must decide whether the presented scientific evidence compels a different constitutional treatment for those aged 18-20 compared to those aged 21 and older.

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Summary

The Supreme Court in Miller v. Alabama said that the Constitution doesn't allow for life in prison without parole (LWOP) for kids who commit crimes. They said judges need to think about how young people's brains are different before giving them this punishment. The Court in Massachusetts also said that kids can't even be given LWOP, even if a judge wants to. In both cases, "kids" meant people under 18.

Two men, Sheldon Mattis and Jason Robinson, were 18 and 19 when they committed murder. They were sentenced to LWOP. Now, they are saying that new science shows that people between 18 and 20 are still developing, just like kids. They want the Court to change the law so that 18-20 year olds can't be given LWOP without a special hearing. They also want the Court to use this science to show that they weren't thinking clearly when they committed the crime.

This Court should not change the law. The law is still okay because it takes into account how serious murder is and how old the people are. The Court should stick to the rules about how to decide if a punishment is too harsh. If it does change the law, it will be stepping on the Legislature's job. It also won't be fair to people who were over 20 when they committed murder.

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Summary

This is a story about two people, Sheldon and Jason, who were 18 and 19 years old when they committed a serious crime. They were both sentenced to life in prison without the chance of parole. They are trying to get their sentences changed because they believe that the law shouldn't treat people that age the same way it treats older adults. They say that young adults' brains are still developing, just like teenagers', and they shouldn't be held to the same standards.

This case is important because it looks at how the law decides what punishment is fair for people of different ages. The judges have to figure out if it's okay to have different laws for young adults than for older adults. It's a tough question because it involves both science and law.

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Footnotes and Citation

Cite

Brief of Amici Curiae for the Eastern District Attorney, Commonwealth v. Mattis, No. SJC-11693 (Mass. S. J. Ct. Dec. 2022).

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