Michelle Carter conviction upheld by Supreme Judicial Court in ‘texting suicide’ trial
Updated ; Posted
The Massachusetts Supreme Judicial Court upheld the conviction of Michelle Carter, the woman convicted of involuntary manslaughter for pressuring her boyfriend into killing himself when they were both teenagers.
Conrad Roy III was found dead in a Fairhaven Kmart parking lot on July 13, 2014, after he turned on a gas-powered water pump and allowed the cabin of his truck to fill with carbon monoxide.
Carter was 17 years old when she sent Roy, her on-and-off again boyfriend, a barrage of texts and Facebook messages encouraging him to kill himself before his eventual suicide. After those messages were discovered by police, she was charged with a count of involuntary manslaughter in Taunton Juvenile Court.
“We conclude that the evidence was sufficient to support the judge’s finding of proof beyond a reasonable doubt that the defendant committed involuntary manslaughter as a youthful offender, and that the other legal issues presented by the defendant, including her First Amendment claim, lack merit,” Justice Scott Kafker wrote in the ruling. “We therefore affirm.”
Carter’s defense attorneys wrote on Twitter that they are considering all legal options, including a possible appeal to the U.S. Supreme Court.
“We are disappointed in the Court’s decision,” they wrote. “We continue to believe that Michelle Carter did not cause Conrad Roy’s tragic death and is not criminally responsible for his suicide.”
Thousands of text and Facebook messages were entered as evidence at the trial, revealing the mental health struggles of both teenagers and the intimate details of their largely digital relationship. While Carter and Roy met while on vacation in 2012, they communicated almost entirely by text.
At first, those messages showed Carter urging Roy to seek help for his depression, which had led him to multiple previous suicide attempts. But in the weeks before Roy’s death, their communications took a darker turn. Carter began urging Roy to follow through with plans to kill himself, expressing disappointment when he failed to do so.
“Last night was it. You keep pushing it off and you say you’ll do it but u never do. Its always gonna be that way if u don’t take action," Carter wrote to Roy. “You’re just making it harder on yourself by pushing it off, you just have to do it.”
The case captured national and international attention, both for its look into the underbelly of teenage secrecy and mental health and its chief legal question: when can words kill? On June 16, 2017, Carter was found guilty by a judge. She was sentenced to 15 months in jail, though her sentence has been stayed pending appeals in state courts.
Carter's attorneys had argued that Carter was neither responsible for Roy's death nor her own actions, saying that the suicide plan was of Roy's own devising and that Carter's judgment was compromised by the antidepressants she was taking at the time.
But Judge Lawrence Moniz, who issued the verdict after Carter waived her right to a jury trial, ruled that Carter caused Roy's death by telling him over the phone to get back in his truck as it filled with the deadly gas.
"She instructed him to get back in the truck which she has reason to know is becoming a toxic environment to human life," Moniz said in a statement from the bench.
Moniz also ruled that Carter had a legal duty to call for help after placing Roy in a life-threatening situation, citing a case where two homeless people started a warehouse fire that killed six Worcester firefighters after it was not reported.
Prosecutors argued that Carter’s instructions to Roy met Massachusetts' definition of manslaughter, and that the state has long recognized that -- in certain circumstances -- words can kill.
In their appeal to the SJC, Carter’s attorneys argued that the conviction violated Carter’s First Amendment right to free speech by criminalizing non-threatening or coercive text messages. They also disputed the prosecutions account of a crucial phone call, in which Carter allegedly told Roy to get back in his truck as it filled with carbon monoxide. The only account of that call came from texts that Carter later sent a friend.
“Carter may have confabulated about what Roy was doing in the truck, dramatized her role in a later text to another teen, or simply been mistaken, but her claim - that Roy got out of the truck, that she told him to get back in, and that he did so - cannot be credited,” her attorneys wrote.
But the Supreme Judicial Court ruled that Moniz had properly weighed the evidence, and was justified in finding that Carter had in fact made that decisive phone call.
“The judge could have properly found, based on this evidence, that the vulnerable, confused, mentally ill, eighteen year old victim had managed to save himself once again in the midst of his latest suicide attempt, removing himself from the truck as it filled with carbon monoxide,” Kafker wrote in the ruling. “But then in this weakened state he was badgered back into the gas-infused truck by the defendant, his girlfriend and closest, if not only, confidant in this suicidal planning, the person who had been constantly pressuring him to complete their often discussed plan, fulfill his promise to her, and finally commit suicide. And then after she convinced him to get back into the carbon monoxide filled truck, she did absolutely nothing to help him: she did not call for help or tell him to get out of the truck as she listened to him choke and die."
While Moniz tailored his ruling to Carter’s specific case, it raised questions about whether the definition of manslaughter in Massachusetts has now been expanded.
At an October hearing on Carter's appeal, SJC justices asked prosecutors about whether Carter's conviction could lead to criminal charges for people who advise terminally ill relatives to end their lives, questioning whether the ruling could have unintended consequences.
Assistant District Attorney Shoshana Stern said that any application would still require prosecutors to prove coercion and that there was wanton and reckless conduct -- the legal standard for manslaughter in Massachusetts.
But she also said that sympathetic circumstances were not a legal shield from prosecution.
“There’s not really a compassionate exemption for most criminal law,” she said.
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According to Article VII of the Bill of Rights we are guaranteed a common law court which I believe means trial by jury. For some reason she decided to wave this option, this may not have been a good decision.
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