Twenty years ago, Frederick Christian was sentenced to life in prison without the possibility of parole for a crime – felony murder – that was committed when he was seventeen years old. At the time of the crime, Christian and a friend, Russell Horton, got into a car with three other men – Manual Araujo, his brother Carlos Araujo, and a third individual, Kepler Desir. The five drove around Brockton before Horton told Manuel Araujo, who was driving, to stop at a house so that he and Christian could rip off drug dealers that they thought lived there. When Christian and Horton got back to the car, Horton told Manual Araujo to drive to a nearby park. Without a word, he shot Manual Araujo, Carlos Araujo, and Desir. Carlos Araujo survived by pretending to be dead and later identified Horton as the shooter. Christian told police he knew of the drug rip off, but did not know that Horton planned to shoot anyone and stated that Horton “just snapped.” Horton and Christian were ultimately convicted of first-degree murder and both were sentenced to life in prison.
At the time of Frederick’s conviction, Massachusetts judges were required to sentence defendants as young as fourteen to life in prison with no possibility of parole if they were convicted of first degree murder. Given the state of the law, Christian went to prison with no reasonable hope that he would ever get out. Despite that fact, Christian signed up and participated in every educational and therapeutic program available to him. He also found a way to avoid any trouble or disciplinary tickets, which are issued for any failure to follow prison rules and regulations, including such minor infractions as taking too long in the shower. Prison life is extremely difficult and often violent – so much so that it is almost impossible for young prisoners to avoid conflict and thereby receive at least some sort of disciplinary citation. Frederick, however, managed to do so.
This past December, Massachusetts became the first state in the country to declare life without the possibility of parole sentences unconstitutional for juveniles. Specifically, in 2012, the United States Supreme Court ruled in Miller v. Alabama that it was unconstitutional to sentence defendants to life sentences without parole for crimes they committed as juveniles. The Court’s decisions was based largely on the growing scientific evidence that young brains are not as equipped as adult brains to control violent impulses and understand the consequences of rash behavior. The Miller decision led the Supreme Judicial Court to issue a similar ruling in December of 2013: Diatchenko v. District Attorney for the Suffolk District. The Diatchenko decision held that Massachusetts law imposing a mandatory life sentence without the possibility of parole for juveniles violated both the 8th Amendment prohibition on cruel and unusual punishment, and the analogous provision of the Massachusetts Declaration of Rights set forth in Article 26. Continue reading →