Michelle Carter, now 22, was found guilty of involuntary manslaughter in 2017 for persuading her boyfriend via text messages to die by suicide. He was 18 when he died. Carter was 17 at the time.
She appealed the decision, but her conviction was upheld Wednesday by the Massachusetts Supreme Judicial Court. In a ruling written by Justice Scott L. Kafker, the court stated 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."
“By her wanton or reckless conduct, she caused the victim’s death by suicide,” the ruling concluded. “Her conviction of involuntary manslaughter as a youthful offender is not legally or constitutionally infirm.”
Carter, and the victim, Conrad Roy III, met in 2012, according to court documents. They maintained their relationship via text messages and frequently discussed mental health issues. Roy had previously attempted suicide, and Carter had planned to seek treatment for an eating disorder.
Initially, Carter urged Roy to seek help, but “as the victim continued researching suicide methods and sharing his findings with the defendant, the defendant helped plan how, where and when he would do so, and downplayed his fears about how his suicide would affect his family,” the court wrote, citing several text exchanges.
“I thought you wanted to do this. The time is right and you’re ready, you just need to do it!” Carter texted Roy in July 2014 as he was having doubts about going through with suicide. They discussed methods, including carbon monoxide poisoning.
On July 13, 2014, Roy’s body was found in a vehicle in a Massachusetts parking lot. He died of carbon monoxide inhalation that was produced “by a gasoline-powered water pump located in the truck,” the ruling said.
In September 2014, Carter texted a friend, writing, “His death is my fault like honestly I could have stopped him I was on the phone with him and he got out of the car because it was working and he got scared and I [expletive] told him to get back in.”
Three years later, Carter was convicted of involuntary manslaughter in Roy’s death, and her case hinged on the text messages she sent him as he contemplated suicide, and the fact that she did not try to prevent him from carrying out the suicide. She was sentenced by Bristol County Juvenile Court Judge Lawrence Moniz to 2½ years in prison but would be eligible for probation after 15 months and was allowed to remain free as she appealed the decision, CBS News reported.
It was a closely watched case not just for its startling details, but also for the legal implications of Carter’s conviction.
After the conviction, Laurie Levenson, a criminal law professor at Loyola Law School in Los Angeles, told The Post that the case sends a strong message that “there are new means of committing old crimes,” and prosecutors will be more likely to look at those cases. She argued that the case did not set legal precedent but raised the question, “When does bullying cross over into committing a homicide?”
The Massachusetts branch of the American Civil Liberties Union raised concerns about the greater implications of the ruling Wednesday.
“Conrad Roy’s suicide is indisputably tragic. But, by upholding Michelle Carter’s conviction, the Supreme Judicial Court has handed prosecutors broad, undefined powers that diminish the speech rights of everyone in Massachusetts,” legal director Matt Segal said in a statement.
“The Court’s decision tells prosecutors that they can bring charges against individuals based on arbitrary and subjective determinations of what speech is noble and what speech is criminal,” Segal continued. “This prosecutorial power will chill important and loving end-of-life discussions between family members, and could lead to erroneous convictions of children who engage in reckless, juvenile conversations with friends. The Court’s assurance that its opinion will not broadly criminalize other speech does little to change this inevitable outcome.”
Carter’s lawyer, Daniel N. Marx, issued similar sentiments Wednesday, telling The Post that the decision “stretches the law” and has “troubling implications, for free speech, due process, and the exercise of prosecutorial discretion.”
In upholding the conviction Wednesday, the court decided that Carter’s claim that her conduct was protected by the First Amendment, among other defenses, “lack[ed] merit.”
Marx said in a statement to The Washington Post that they were considering further legal options, including a possible appeal to the U.S. Supreme Court.