Commonwealth v. Concepcion

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Raymond Concepcion was automatically tried as an adult in Massachusetts for crime that occurred when he was 15 years old. Upon conviction, Raymond received a mandatory sentence of life imprisonment with the possibility of parole.

Juvenile Law Center filed an amicus brief in the Massachusetts Supreme Judicial Court in support of Raymond. We argued that both the mandatory transfer into adult court and the imposition of a mandatory life sentence on a youth violate due process and the Eighth Amendment by precluding any analysis of the mitigating characteristics of youth, as required by Miller. Our brief further argued that mandatory statutory schemes create the risk of a disparate effect on youth of color.

The Massachusetts Supreme Judicial Court held that neither the mandatory transfer of youth into adult court nor the imposition of a mandatory life with parole sentence is unconstitutional. However, the Court found that Raymond’s “exceptional and rare” case provided grounds to vacate his first degree murder conviction. The case was remanded to the Superior Court to impose on Raymond a second degree murder conviction and to sentence him accordingly.