Commonwealth v. WattAnnotate this Case
The Supreme Judicial Court affirmed Defendants' convictions and the orders denying their motions for a new trial and for postconviction relief but remanded the matter of Sheldon Mattis's sentence for an evidentiary hearing, holding that the record was insufficient to address the issue of whether a term of life without the possibility of parole for an individual between the age of eighteen and twenty-two years old violates the prohibition against cruel or unusual punishment.
Defendants, Nyasani Watt and Sheldon Mattis, were convicted of murder in the first degree and related crimes. In addition to other claims, Mattis appealed from his mandatory sentence of life without the possibility of parole, arguing that, due to his age of eighteen, the sentence was unconstitutional. The Supreme Judicial Court held (1) there was no prejudicial error in the trial judge's challenged evidentiary rulings; (2) the judge did not err in failing to provide an involuntary manslaughter instruction; (3) remand was required for development of the record with regard to research on brain development after the age of seventeen; (4) the trial court did not err in denying Defendants' motions for a new trial; and (5) there was no reason to grant either defendant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E.