Series: Massachusetts Bars Life Without Parole for People Under 21

Juvenile Sentencing

Massachusetts’s supreme court ruled on January 11, 2024, that “emerging adults” — individuals who are 18, 19, or 20 years old — can’t be sentenced to life in prison without the possibility of parole. Relying on the Massachusetts constitution’s prohibition against “cruel or unusual punishments” and building on a 2013 Massachusetts decision that barred such sentences for minors, Commonwealth v. Mattis is the first time a state high court has prohibited life without parole for people under 21. This a major development in the constitutional limits on punishment. To understand the ruling’s broader implications, State Court Report turned to several experts to produce a small essay series on the case.

Massachusetts Reminds Youth Defense Attorneys to Consider State Constitutions

By holding that life without parole sentences are unconstitutional for anyone under 21, the Massachusetts high court goes far above the federal floor.

By Kristina Kersey, assistant professor at the University of Tennessee College of Law whose scholarship focuses on the juvenile carceral system and youth rights.  

Massachusetts Rejects Harmful Federal Standard for Evaluating Whether Punishment Is Unconstitutional

The state supreme court’s decision outlawing life without parole for people aged 18 to 20 is notable for both its outcome and the test it used to get there.

By Kyle C. Barry, director of the State Law Research Initiative.

Massachusetts Looks to International Sources to Inform ‘Evolving Standards of Decency’

In declaring life without parole unconstitutional for people under 21, the state’s high court cited sentencing practices in Canada and the United Kingdom.

By Martha F. Davis, university distinguished professor at Northeastern University School of Law.


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