How Long Is a Life Sentence in Massachusetts? (2026 Guide)

In Massachusetts, first-degree murder carries mandatory life without parole under M.G.L. c. 265 Section 2. Second-degree murder carries a life sentence with parole eligibility after a court-fixed minimum of 15 to 25 years. Massachusetts abolished the death penalty in 1984, making life without parole the state's most severe punishment.

This article was last reviewed and updated on March 17, 2026. All statutes, case law, sentencing data, and legislative developments have been verified against current Massachusetts government sources.

In Massachusetts, a life sentence is exactly what the name suggests: a sentence that can keep a person in prison for the rest of their natural life. For first-degree murder, the sentence is mandatory life without the possibility of parole. For second-degree murder, the sentence is life with the possibility of parole after serving a court-fixed minimum of 15 to 25 years.

Massachusetts stands apart from many other states in two significant ways. First, it abolished the death penalty in 1984, making LWOP the ceiling for criminal punishment. Second, it became the first state in the nation to ban life without parole for defendants under 21 years old, a groundbreaking extension of juvenile sentencing protections that no other state has matched.

These facts place Massachusetts at the center of a national conversation about how long is long enough when a state sentences someone to life.

Massachusetts Life Sentence Statutes

Massachusetts defines murder and its penalties across several sections of the General Laws. Understanding the statutory framework is essential to understanding how life sentences work in practice.

Murder Defined (M.G.L. c. 265 Section 1): Section 1 defines the two degrees of murder. Murder committed with deliberately premeditated malice aforethought, with extreme atrocity or cruelty, or in the commission or attempted commission of a crime punishable with death or imprisonment for life (felony murder) is murder in the first degree. Murder that does not appear to be in the first degree is murder in the second degree, and the jury decides the degree.

First-Degree Murder (M.G.L. c. 265 Section 2): Section 2 sets the punishment. A person convicted of first-degree murder (other than a person who was 14 to 17 at the time of the offense) is punished by life imprisonment and cannot be paroled. The penalty is life imprisonment without the possibility of parole.

Second-Degree Murder (M.G.L. c. 265 Section 2): For murder in the second degree as defined in Section 1, Section 2 sets the penalty at life imprisonment, with parole eligibility after a minimum term the court fixes under c. 279 Section 24 (not less than 15 nor more than 25 years).

Parole Eligibility Statutes (M.G.L. c. 279 Section 24 and M.G.L. c. 127 Section 133A): Under c. 265 § 2, the court fixes a minimum term under c. 279 § 24, which must be not less than 15 nor more than 25 years. M.G.L. c. 127 § 133A then makes the person eligible for parole at the expiration of that court-fixed minimum.

It is important to note that Massachusetts does not use the "25 years to life" or "15 years to life" phrasing common in other states. A life sentence in Massachusetts is simply "life." The parole eligibility window is a separate statutory provision, not part of the sentence itself.

Parole for Life Sentences

Parole eligibility in Massachusetts depends entirely on whether the conviction is for first-degree or second-degree murder.

First-Degree Murder: No Parole

Persons convicted of first-degree murder in Massachusetts are not eligible for parole. The sentence is mandatory life without parole. There is no minimum term after which they can apply. The only paths to release are executive commutation by the Governor (with the approval of the Governor's Council) or a successful appeal that overturns the conviction.

Commutations for first-degree murder lifers are extraordinarily rare in Massachusetts. The Massachusetts Parole Board does not have jurisdiction over these cases.

Second-Degree Murder: 15-Year Minimum

Persons convicted of second-degree murder become eligible for parole after serving the minimum term fixed by the sentencing judge. Under M.G.L. c. 279 Section 24, that minimum must be not less than 15 years nor more than 25 years.

Once eligible, the person appears before the Massachusetts Parole Board. The board evaluates the nature of the offense, institutional conduct, rehabilitation efforts, release plans, and risk to public safety. Parole hearings for lifers are thorough and often contentious.

Even when granted, parole for a life sentence is not unconditional. The person remains under parole supervision for the rest of their life and can be returned to prison for a parole violation at any time.

Parole Eligibility Summary

Banning LWOP for Defendants Under 21: A National First

The single most significant development in Massachusetts sentencing law in recent years is the ban on life without parole for defendants who were under 21 at the time of their offense. No other state has gone this far.

The Path to Commonwealth v. Mattis

The road to this landmark ruling began with the U.S. Supreme Court's decision in Miller v. Alabama (2012), which held that mandatory life without parole for juveniles under 18 violates the Eighth Amendment's prohibition on cruel and unusual punishment, and Montgomery v. Louisiana (2016), which held that this rule applies retroactively to juveniles whose convictions and sentences were already final.

Massachusetts went further than the federal floor. In Diatchenko v. District Attorney (2013), the Massachusetts Supreme Judicial Court (SJC) banned LWOP for all juveniles, not just mandatory LWOP, but discretionary LWOP as well. The SJC held that the reasoning in Miller applied with equal force to all juvenile offenders, not just those subject to mandatory sentencing schemes.

Then came the question that no other state court had answered: What about 18-, 19-, and 20-year-olds?

Commonwealth v. Mattis (2024)

In Commonwealth v. Mattis (2024), the Massachusetts Supreme Judicial Court ruled that life without parole is unconstitutional for defendants who were under 21 at the time of their offense. The court relied on the same developmental science that underpinned Miller, research showing that brain development, particularly in the prefrontal cortex governing impulse control, risk assessment, and decision-making, continues well into the early twenties.

The SJC held that the rationale for treating juveniles differently from adults applies with equal force to emerging adults aged 18, 19, and 20. Because these individuals retain a greater capacity for change and rehabilitation, imposing an irrevocable sentence of life without parole is disproportionate.

This ruling made Massachusetts the first state in the nation to extend the juvenile LWOP ban to defendants under 21. It affects not only future sentences but also existing cases where individuals under 21 at the time of their offense are currently serving LWOP.

Impact of the Ruling

The practical impact of Mattis is significant. Individuals who were under 21 when they committed first-degree murder and are currently serving LWOP are now entitled to a parole eligibility hearing after serving a sufficient period. The ruling effectively converts their sentences from LWOP to life with the possibility of parole.

Advocates estimate that dozens of currently incarcerated individuals may be affected by this ruling. The decision has been closely watched by other states considering similar reforms and by legal scholars tracking the expansion of juvenile sentencing protections to emerging adults.

Notable Massachusetts Cases

Massachusetts has produced several high-profile cases that illustrate how life sentences and serious criminal charges operate in the state.

Aaron Hernandez

Aaron Hernandez, a former tight end for the New England Patriots, was convicted of first-degree murder in 2015 for the killing of Odin Lloyd. He was sentenced to life without the possibility of parole.

While serving his sentence, Hernandez was tried for a separate double murder and acquitted in 2017. Days after the acquittal, Hernandez was found dead in his prison cell at the Souza-Baranowski Correctional Center. His death was ruled a suicide.

Under a Massachusetts legal doctrine known as abatement ab initio, because Hernandez died while his appeal of the Lloyd murder conviction was still pending, his conviction was initially vacated. However, the SJC subsequently abolished the abatement doctrine in Commonwealth v. Hernandez (2019), reinstating the conviction posthumously.

Michelle Carter: The Texting Suicide Case

Michelle Carter was convicted of involuntary manslaughter in 2017 for encouraging Conrad Roy III to take his own life through a series of text messages. The case drew national attention and raised profound questions about the boundaries of criminal liability for speech.

Carter was sentenced to two and a half years in the Bristol County House of Correction, with 15 months to serve and the balance suspended, not a life sentence, but the case became a defining Massachusetts criminal case of its era. The SJC upheld the conviction in Commonwealth v. Carter (2019), and the U.S. Supreme Court declined to hear the case.

The case inspired the HBO series "I Love You, Now Die" and the Hulu series "The Girl from Plainville," and it prompted legislative proposals in Massachusetts and other states to criminalize suicide coercion.

Karen Read

Karen Read was charged with second-degree murder in the death of her boyfriend, Boston Police Officer John O'Keefe, who was found dead outside a Canton home in January 2022. The case became one of the most polarizing criminal prosecutions in recent Massachusetts history.

Read's first trial in 2024 ended in a mistrial after the jury was unable to reach a unanimous verdict. The case generated intense public interest, with supporters arguing that Read was framed and that the investigation was compromised. At her retrial, the jury returned its verdict on June 18, 2025: Read was acquitted of second-degree murder and manslaughter and convicted only of operating under the influence. She was sentenced to one year of probation, the standard penalty for a first offense.

Recent Criminal Justice Reforms

Massachusetts has undertaken significant criminal justice reform in recent years, reshaping the landscape for life-sentenced prisoners and the broader incarcerated population.

The 2018 Criminal Justice Reform Act (Chapter 69)

Signed into law in April 2018, the Criminal Justice Reform Act was the most comprehensive overhaul of the Massachusetts criminal justice system in decades. Key provisions include:

• Reduced mandatory minimum sentences for certain drug offenses
• Bail reform to reduce pretrial detention for those who cannot afford bail
• Raised the felony larceny threshold from $250 to $1,200
• Expanded diversion programs for young adults aged 18-21 in the juvenile court system
• Decriminalized minor offenses that previously triggered incarceration
• Compassionate release provisions for terminally ill prisoners
• Restrictions on solitary confinement (further expanded in 2021)

While the 2018 reforms did not directly change life sentence lengths, they reflected a broader shift in Massachusetts toward rehabilitation-focused sentencing and away from the mandatory minimum framework that defined the 1990s and 2000s.

2021 Solitary Confinement Restrictions

In 2021, Massachusetts enacted restrictions on the use of solitary confinement, with specific protections for life-sentenced prisoners. The law limits restrictive housing to 15 consecutive days and requires mental health screenings before and during isolation.

The reforms were driven by growing evidence that prolonged solitary confinement causes severe psychological harm, particularly for individuals serving decades-long sentences. Advocacy groups like the American Civil Liberties Union of Massachusetts had pushed for these changes for years.

Pregnant inmates, individuals with serious mental illness, and those under 21 are now prohibited from being placed in solitary confinement under any circumstances.

Juvenile Sentencing in Massachusetts

Massachusetts has been at the forefront of juvenile sentencing reform, consistently interpreting constitutional protections more broadly than the federal minimum.

JLWOP: Banned

Juvenile life without parole is banned in Massachusetts. The SJC's decision in Diatchenko v. District Attorney (2013) went further than the U.S. Supreme Court's ruling in Miller, holding that all LWOP sentences for juveniles are unconstitutional, not just mandatory ones.

Juveniles convicted of first-degree murder in Massachusetts are now sentenced to life with the possibility of parole, with parole eligibility set by the court. Under M.G.L. c. 279 Section 24, the court fixes that minimum at not less than 20 nor more than 30 years for a person who was 14 to 17 at the time of the offense, at 25 to 30 years for murder with deliberately premeditated malice aforethought, and at 30 years for murder with extreme atrocity or cruelty.

Extension to Under-21

As discussed above, Commonwealth v. Mattis (2024) extended the JLWOP ban to all defendants under 21. This creates a three-tier sentencing framework in Massachusetts:

This framework recognizes developmental science showing that brain maturation continues into the mid-twenties and that emerging adults retain a greater capacity for rehabilitation than fully mature adults.

History of the Death Penalty in Massachusetts

Understanding Massachusetts life sentences requires understanding why the death penalty was abolished and what replaced it.

Timeline

Massachusetts has a long and conflicted history with capital punishment. The colony of Massachusetts Bay carried out its first execution in 1630.

Over the centuries, the state gradually narrowed the scope of capital punishment. By the twentieth century, the death penalty was reserved for first-degree murder.

Last Execution (1947): The last executions in Massachusetts took place on May 9, 1947, by electric chair at the Massachusetts State Prison in Charlestown. No one has been executed in the Commonwealth since.

Abolition (1984): The death penalty was struck down by the Massachusetts Supreme Judicial Court in Commonwealth v. Colon-Cruz, 393 Mass. 150 (1984). The court held capital punishment unconstitutional because it was not applied fairly: only defendants who went to trial were exposed to it, while those who pleaded guilty were not. An earlier decision, Suffolk County District Attorney v. Watson, 381 Mass. 648 (1980), had already struck down a previous version of Mass. Gen. Laws ch. 265, § 2. Both were judicial rulings rather than a legislative repeal, and the legislature has not enacted a new capital sentencing statute since.

Since abolition, there have been periodic attempts to reinstate the death penalty, most notably after the Boston Marathon bombing in 2013. Dzhokhar Tsarnaev was tried in federal court and sentenced to death under federal law, bypassing the state's abolition. However, state legislators have consistently rejected proposals to restore capital punishment.

The result: Life without parole is the maximum penalty available under Massachusetts state law. This makes the LWOP sentence carry particular weight in the state's criminal justice system. It is the ultimate sanction.

Massachusetts Life Sentence at a Glance

Related Pages

• How Long Is a Life Sentence? State-by-State Guide
• Murder Sentencing Guidelines for Every State

Frequently Asked Questions

How long is a life sentence in Massachusetts?

A life sentence in Massachusetts means imprisonment for the rest of a person's natural life. For first-degree murder, the sentence is mandatory life without the possibility of parole. For second-degree murder, the sentence is life with parole eligibility after serving a minimum term the sentencing judge fixes between 15 and 25 years under M.G.L. c. 279 Section 24.

Does Massachusetts have the death penalty?

No. Massachusetts abolished the death penalty in 1984. The last execution in the state took place on May 9, 1947. Life without parole is the most severe sentence available under Massachusetts state law. Federal death sentences can still be imposed in Massachusetts for federal crimes, as in the case of Boston Marathon bomber Dzhokhar Tsarnaev.

Can someone under 21 get life without parole in Massachusetts?

No. Massachusetts is the first state in the nation to ban life without parole for defendants under 21. The Massachusetts Supreme Judicial Court ruled in Commonwealth v. Mattis (2024) that LWOP is unconstitutional for individuals who were under 21 at the time of their offense, based on developmental science showing that brain maturation continues into the early twenties.

What percentage of Massachusetts prisoners are serving life sentences?

Approximately 29% of Massachusetts prisoners are serving life sentences, one of the highest rates in the country. This figure includes both those serving life without parole for first-degree murder and those serving life with parole eligibility for second-degree murder.

What was the 2018 Criminal Justice Reform Act in Massachusetts?

The 2018 Criminal Justice Reform Act (Chapter 69) was the most comprehensive overhaul of Massachusetts criminal justice law in decades. It reduced mandatory minimums for drug offenses, reformed bail practices, raised the felony larceny threshold, expanded diversion programs for young adults, introduced compassionate release provisions, and placed restrictions on solitary confinement.

Can a life sentence be commuted in Massachusetts?

Yes, but it is extremely rare. The Governor of Massachusetts has the power to commute sentences, but only with the approval of the Governor's Council (an elected body of eight members). Commutations for first-degree murder lifers have been granted only a handful of times in the state's modern history. For second-degree murder lifers, parole through the Massachusetts Parole Board is the more common path to release.