Roberio v. Massachusetts Parole Board
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Summary

Roberio, sentenced to life as a teen, challenged limited parole reviews. Massachusetts Supreme Court in 2019 allowed more frequent reviews by applying a recent law retroactively as it didn't worsen his punishment.

2019 | State Juristiction

Roberio v. Massachusetts Parole Board

Keywords parole eligibility; felony-murder; LWOP; juvenile sentencing

Abstract

Jeffrey Roberio, convicted of murder at 17 years old, challenged the Massachusetts Parole Board's decision denying him parole eligibility in Roberio v. Massachusetts Parole Board. At the time of his offense, Roberio faced a mandatory life sentence without parole. However, a subsequent Supreme Court decision, Diatchenko v. District Attorney, ruled such sentences unconstitutional for juveniles. This made Roberio parole-eligible. The issue in Roberio's case was whether a statutory amendment allowing the Parole Board to set longer parole review periods applied retroactively to his case. The amendment was enacted after Roberio's initial sentencing. The Supreme Judicial Court of Massachusetts ruled in Roberio's favor. They determined the amendment did not create a new punishment but rather adjusted the parole review process. Since it did not worsen Roberio's situation, the court applied the amendment retroactively, allowing him access to a more frequent parole review.

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Abstract

Jeffrey Roberio, convicted of murder at 17 years old, challenged the Massachusetts Parole Board's decision denying him parole eligibility in Roberio v. Massachusetts Parole Board. At the time of his offense, Roberio faced a mandatory life sentence without parole. However, a subsequent Supreme Court decision, Diatchenko v. District Attorney, ruled such sentences unconstitutional for juveniles. This made Roberio parole-eligible. The issue in Roberio's case was whether a statutory amendment allowing the Parole Board to set longer parole review periods applied retroactively to his case. The amendment was enacted after Roberio's initial sentencing. The Supreme Judicial Court of Massachusetts ruled in Roberio's favor. They determined the amendment did not create a new punishment but rather adjusted the parole review process. Since it did not worsen Roberio's situation, the court applied the amendment retroactively, allowing him access to a more frequent parole review.

Jeffrey Roberio, who was convicted of murder at age 17 and sentenced to mandatory life in prison without the possibility of parole, challenged the Massachusetts Parole Board's denial of his parole eligibility in the case of Roberio v. Massachusetts Parole Board. Roberio's mandatory life sentence was rendered unconstitutional for juveniles by the subsequent Supreme Court decision in Diatchenko v. District Attorney, making him eligible for parole.

The central issue in Roberio concerned the retroactive application of a statutory amendment granting the Parole Board the authority to establish extended parole review intervals. This amendment, enacted after Roberio's initial sentencing, raised the question of its applicability to his case. The Supreme Judicial Court of Massachusetts ultimately ruled in Roberio's favor, holding that the amendment did not constitute a new punishment but rather modified the existing parole review procedure. As the amendment did not result in a more severe outcome for Roberio, the court applied it retroactively, thereby granting him the opportunity for more frequent parole reviews.

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Abstract

Jeffrey Roberio, convicted of murder at 17 years old, challenged the Massachusetts Parole Board's decision denying him parole eligibility in Roberio v. Massachusetts Parole Board. At the time of his offense, Roberio faced a mandatory life sentence without parole. However, a subsequent Supreme Court decision, Diatchenko v. District Attorney, ruled such sentences unconstitutional for juveniles. This made Roberio parole-eligible. The issue in Roberio's case was whether a statutory amendment allowing the Parole Board to set longer parole review periods applied retroactively to his case. The amendment was enacted after Roberio's initial sentencing. The Supreme Judicial Court of Massachusetts ruled in Roberio's favor. They determined the amendment did not create a new punishment but rather adjusted the parole review process. Since it did not worsen Roberio's situation, the court applied the amendment retroactively, allowing him access to a more frequent parole review.

Jeffrey Roberio, who committed murder at age 17, was sentenced to life in prison without the possibility of parole. However, the Supreme Court later ruled in Diatchenko v. District Attorney that such sentences for juveniles were unconstitutional. This ruling meant Roberio became eligible for parole.

Roberio challenged the Massachusetts Parole Board's decision regarding his parole eligibility. The central issue was whether a legal change allowing the Parole Board to set longer periods between parole reviews applied to Roberio's case. This amendment was passed after Roberio's original sentencing. The Massachusetts Supreme Judicial Court sided with Roberio. They argued the amendment didn't create a harsher punishment, but simply modified the parole review process. Because it didn't worsen Roberio's situation, the court applied the amendment retroactively. This decision grants Roberio access to more frequent parole reviews.

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Abstract

Jeffrey Roberio, convicted of murder at 17 years old, challenged the Massachusetts Parole Board's decision denying him parole eligibility in Roberio v. Massachusetts Parole Board. At the time of his offense, Roberio faced a mandatory life sentence without parole. However, a subsequent Supreme Court decision, Diatchenko v. District Attorney, ruled such sentences unconstitutional for juveniles. This made Roberio parole-eligible. The issue in Roberio's case was whether a statutory amendment allowing the Parole Board to set longer parole review periods applied retroactively to his case. The amendment was enacted after Roberio's initial sentencing. The Supreme Judicial Court of Massachusetts ruled in Roberio's favor. They determined the amendment did not create a new punishment but rather adjusted the parole review process. Since it did not worsen Roberio's situation, the court applied the amendment retroactively, allowing him access to a more frequent parole review.

Jeffrey Roberio, who was found guilty of murder at age 17, took the Massachusetts Parole Board to court over their decision to deny him a chance at parole. Roberio was initially given a life sentence without the possibility of parole, which was the mandatory sentence at the time of his crime. However, a later ruling by the Supreme Court in the case of Diatchenko v. District Attorney found these types of sentences unconstitutional for individuals who were under 18 when they committed their crimes. This ruling meant that Roberio could now be eligible for parole.

The central question in Roberio's case was whether a change to the law, which allowed the Parole Board to set longer periods between parole reviews, could be applied to Roberio's case since the change happened after he was sentenced. Ultimately, the highest court in Massachusetts sided with Roberio. The court decided that this change to the law didn't create a new punishment but simply changed how the parole review process worked. Because it didn't make Roberio's situation worse, the court determined the law could be applied retroactively, granting him the opportunity for more frequent parole reviews.

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Abstract

Jeffrey Roberio, convicted of murder at 17 years old, challenged the Massachusetts Parole Board's decision denying him parole eligibility in Roberio v. Massachusetts Parole Board. At the time of his offense, Roberio faced a mandatory life sentence without parole. However, a subsequent Supreme Court decision, Diatchenko v. District Attorney, ruled such sentences unconstitutional for juveniles. This made Roberio parole-eligible. The issue in Roberio's case was whether a statutory amendment allowing the Parole Board to set longer parole review periods applied retroactively to his case. The amendment was enacted after Roberio's initial sentencing. The Supreme Judicial Court of Massachusetts ruled in Roberio's favor. They determined the amendment did not create a new punishment but rather adjusted the parole review process. Since it did not worsen Roberio's situation, the court applied the amendment retroactively, allowing him access to a more frequent parole review.

Jeffrey Roberio went to prison for murder when he was just 17 years old. He was given a life sentence with no chance of ever getting out. But then, the highest court in the land (the Supreme Court) decided that life sentences for young people like Roberio were wrong. The Court said that everyone, even teenagers who make big mistakes, deserve a chance to show they've changed.

Because of that decision, Roberio was allowed to ask the Parole Board for a chance to get out of prison early. The Parole Board said no. Roberio thought this wasn't fair, so he took his case to court in a case called Roberio v. Massachusetts Parole Board. Roberio argued that a new law, passed after he went to prison, should apply to his case. The court agreed with Roberio. This means Roberio will to have more frequent Parole Board hearings.

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Footnotes and Citation

Cite

Roberio v. Massachusetts Parole Board, 480 Mass. 780 (Mass. 2019)

Highlights