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.  MacArthur Justice Center is advocating against extreme sentences that fail to take into account the unique mitigating qualities of youth. 

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 in New Jersey are eligible for parole after at most 20 years. 

Ms. Bellamy was 19 years old when she committed her crime of conviction, and she appealed her life sentence, arguing that she should be sentenced in accordance with the state’s protections against excessive sentences based on youth. She cited the now well-established body of scientific research that shows that adolescent development continues well past 18 years old, such that late adolescents over the age of 18 but still within the age range characterized by the hallmark traits of youth deserve the same constitutional protections as their younger peers.

Ms. Bellamy was granted a new sentencing hearing, and the MacArthur Justice Center filed an amicus brief focusing on the New Jersey Constitution’s counterpart to the federal Eighth Amendment. New Jersey’s high court has long interpreted its constitution broadly when addressing sentencing. We argued that, 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 a day under 18 years old.

The state superior court ruled against Ms. Bellamy, holding that the protections afforded to juvenile offenders “do not apply to late adolescent offenders, such as nineteen-year-old [Latonia Bellamy].” Ms. Bellamy has appealed to the Appellate Division, seeking recognition of the broad protections provided by New Jersey law for late adolescents in sentencing.

MacArthur Justice Center, represented by Jenny-Brooke Condon of the Center for Social Justice at the Seton Hall University School of Law, has filed an amicus brief in support of Ms. Bellamy before the Appellate Division. We argue that the New Jersey Constitution compels meaningful consideration of the mitigating qualities of youth for late adolescents likes Ms. Bellamy.