State of New Jersey v. Bellamy

Latonia Bellamy was 19 years old when a relative – who, unbeknownst to her, had already committed a string of violent crimes – involved her in a robbery-turned-murder in New Jersey. Ms. Bellamy was convicted of felony murder and related charges, and – absent any consideration of Mr. Bellamy’s youth or history of childhood trauma – she received a sentence of life plus 30 years in prison.  

New Jersey’s Supreme Court has banned life without parole for all individuals convicted of crimes committed when they were under 18, both on U.S. constitutional grounds following the U.S. Supreme Court’s decisions in Miller v. Alabama and Graham v. Florida and on state constitutional grounds. Now, youth under 18 are eligible for parole after at most 20 years. 

Ms. Bellamy appealed her sentence, arguing that she should be sentenced in accordance with these laws as well. She is advocating for courts’ clear recognition of science that shows that adolescent development continues well past 18 years old, such that youth over 18 deserve the same constitutional protections as their younger peers. 

Ms. Bellamy was granted a new sentencing hearing, where the court will consider both evidence of the effects of her traumatic youth, as well as a recently enacted statute that makes youth a mitigating factor in sentencing for individuals under 26 years old at the time of their offenses. The court will also hear about Ms. Bellamy’s extraordinary record while imprisoned, including earning a bachelor’s degree with honors and her service to and advocacy for incarcerated people. 

The MacArthur Justice Center filed an amicus brief focusing on the New Jersey Constitution’s equivalent to the federal Eighth Amendment. New Jersey’s high court has long interpreted its constitution broadly when addressing sentencing, and objective measures suggest that society does not adhere to age 18 as a firm age of maturation, given adolescent development continues well past that age. Therefore, as a constitutional matter Ms. Bellamy is entitled to the same constitutional sentencing protections at 19 years old that she would have had if she were 17 years old.