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No Life Without Parole for Juveniles, Mass. High Court Rules

By Aditi Mukherji, JD on December 26, 2013 | Last updated on March 21, 2019

Earlier this week, the highest court in Massachusetts struck down life sentences without parole for juveniles as unconstitutional. The court said that scientific research shows that lifelong imprisonment for youths is cruel and unusual because their brains are not fully developed.

The court's decision dovetails with a previous ruling by the U.S. Supreme Court and fits into the goals of our juvenile justice system.

U.S. Supreme Court Ruling

In 2012, the U.S. Supreme Court ruled that mandatory life sentences without parole for juveniles violate the Eighth Amendment's ban on cruel and unusual punishment. The 5-4 decision came in the robbery and murder cases of two 14-year-olds in Alabama.

The Court said in that case that life without parole is an unconstitutionally disproportionate punishment when viewed in the context of the unique characteristics of juvenile offenders. But it left out murder, leaving a gap that the Massachusetts court rulings fill.

Massachusetts Ruling

In Massachusetts, teens as young as 14 can be tried and convicted as adults for first-degree murder. But with the Supreme Judicial Court's ruling, those young offenders can no longer get life without parole, reports The Associated Press.

Because a juvenile's brain isn't fully developed structurally or functionally, a judge can't accurately determine whether a juvenile is "irretrievably depraved," the state court explained. The court's decision stems from the case of Gregory Diatchenko, who was convicted of first-degree murder for stabbing a man to death in Boston in 1981, when Diatchenko was 17.

The court also ruled in the separate case of Marquise Brown, who was tried and convicted last year of first-degree murder at the age of 17. In its decision for that case, the court wrote that "the context of the offender's age and the wholesale forfeiture of all liberties" make the sentence of life without parole on a juvenile "strikingly similar, in many respects, to the death penalty," which Massachusetts has banned.

Juvenile Justice

A cornerstone of our juvenile justice system is the belief in rehabilitation. Both the Massachusetts Supreme Judicial Court and U.S. Supreme Court rulings -- along with decisions in other courts in the country -- promote the idea that while violent felons should be held accountable, youthful ones deserve the opportunity for rehabilitation as they are developmentally different from adults.

In January, Massachusetts Gov. Deval Patrick filed legislation to bar automatic life sentences without parole for juveniles, reports The AP. With the Massachusetts justices explicitly urging the state legislature to change the sentencing law, a change in favor of rehabilitation looks promising.

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