Suffolk District Attorney Kevin Hayden praised the decision of a Superior Court judge that sets the groundwork for individualized sentencing hearings for emerging adults convicted of first-degree murder. Hayden also supported a separate decision to stay the sentence of a man convicted of murder in 1969.
In a decision issued in post-conviction motions filed by Sheldon Mattis and Jason Robinson, Suffolk Superior Court Judge Robert Ullman stated that the defendants are entitled to new sentencing hearings. The defendants were ages 18 and 19, respectively, when they committed murders for which they were subsequently sentenced to life without the possibility of parole – the mandatory term for the offense of first-degree murder.
The decision impacts emerging adult between the ages of 18 and 20. Over the past decade, courts locally and nationally have made a series of rulings that have reshaped sentencing practices for juvenile offenders age 17 and younger. The US Supreme Court’s 2012 decision in Miller v. Alabama struck down the mandatory imposition of lifetime incarceration without the possibility of parole for juvenile offenders across the country, and the Massachusetts Supreme Judicial Court subsequently ruled in Diatchenko v. District Attorney for the Suffolk District barring the imposition of the sentence for offenses committed as a juvenile in Massachusetts courts.
“Reasonable incarceration, even for young adult offenders, is justified in certain cases. Excessive incarceration is never justified. The practice of putting a person behind bars forever, without paying attention to decision-making ability based on age and the science of brain development, should end. We supported these motions and we support the judge’s decision,” Hayden said. Hayden also thanked his predecessor, U.S. Attorney Rachael Rollins, for her “early leadership on this issue.”
The SJC in 2021 remanded Mattis’ case to the Superior Court for an evidentiary hearing to help determine whether life without parole is constitutional for Mattis and other emerging adults whose brains continue to develop. Today’s decision adopts the position argued by Suffolk prosecutors. The decision quotes from the SJC’s decision in Diatchenko as it concludes that, “On the record of brain science and social science in this case, the imposition of non-discretionary (i.e. mandatory) life-without-parole sentences for defendants who were age 18 through 20 at the time of their crimes constitutes a ‘sentencing practice based on mismatches between the culpability of a class of offenders and the severity of a penalty.’”
Mattis and a second man, Nyasani Watt, stand convicted of first-degree murder in the 2011 shooting death of 16-year-old Jaivon Blake. Watt, who fired the fatal shot, was 10 days shy of his 18th birthday at the time of the murder. As a result, he was sentenced to life with the possibility of parole. Mattis had already achieved the age of 18 at the time and was sentenced to life without the possibility of parole.
Robinson and Tanzerius Anderson were convicted in the 2000 murder of Yazbek Inaamnaim in Boston. Robison was 19 at the time.
In a separate case, a single justice of the SJC allowed a motion to stay the sentence of PAUL ROBINSON. Following a review by the office’s Integrity Review Bureau, Suffolk prosecutors agreed that the interests of justice require a reduction of Robinson’s 1969 first-degree murder conviction to manslaughter, with his sentence deemed served. As the matter remained before the court, Robinson filed a motion to stay his sentence, which would allow him to remain free while the case is pending. A Superior Court judge previously denied the stay, but SJC Justice David Lowy today reversed that decision, allowing Robinson’s motion and permitting his release while his post-conviction motion is pending.
“It is never easy to retread the past, but it is vital that we do so to correct past wrongs and ensure that they are never repeated. We must always seek to do what is right,” Hayden said.
Assistant District Attorneys Cailin Campbell, Monica DeLateur and Paul Linn of the DA’s Appeals Unit represented the Commonwealth in the proceedings involving Mattis and Jason Robinson. Assistant District Attorney David Lewis of the DA’s Integrity Review Bureau represented the Commonwealth in the case of Paul Robinson.