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The Massachusetts Supreme Court has affirmed the conviction of a 22-year-old woman, Michelle Carter, who repeatedly encouraged her boyfriend to commit suicide in 2014. She has been sentenced to 15 months in prison. 18-year-old Conrad Roy III was found dead in his car in a K-Mart parking lot after using a pump to fill the car with Carbon Monoxide. Official text message transcripts reveal details that in the prior days to the suicide, Roy expressed doubt and fear if he was making the right decision. Carter’s replies consisted of encouraging him to purchase the pump, pushing to get the suicide over with, and even telling him “people that commit suicide don’t think this much”. After the car filled with Carbon Monoxide, Roy exited in fear, however Carter told him to get back inside the car. Roy died later that night. The next day, Carter sent a text to a friend saying she was at fault for Roy’s death because she had instructed him to go back inside his vehicle. Carter was 17 at the time of the incident, and was originally tried in the Bristol Juvenile Court of Taunton, Massachusetts. The lower court found her guilty of involuntary manslaughter in a bench trial.
Upon appeal to the Massachusetts Supreme Court, Carter’s legal team raised a variety of issues to the court. In Justice Scott L. Kafker’s opinion, the Court rejected the notion that her not being physically present absolve her of responsibility, finding that her verbal comments were a direct link to Roy’s death. The opinion went on to note that the victim was aware of the influence her comments had on the victim, and understood very well that Roy suffered from depression and suicidal tendencies. Carter’s attorneys based her defense around these key issues: insufficient evidence, lack of due process, free speech infringement, no infliction of bodily harm, not being a reasonable juvenile, and not being able to bring an expert witness forward. Claiming that the only evidence of her admitting responsibility was the text message to her friend, Carter’s team said that an extrajudicial message is not valid evidence. The Court found that this evidence is is valid if corroborated, which it was by her various other messages encouraging him to commit suicide. Her claim that she lacked due process due to the involuntary manslaughter charge being constitutionally vague did not hold up, as the Court explained that any statute previously expanded upon by judicial explanation cannot be considered vague. Her free speech was also not infringed upon, according to the opinion, as involuntary manslaughter requires “wanton or reckless conduct”. If this conduct happens to be speech, it is implied that the speech is not protected by the First Amendment. Kafker also denies that Carter had to physically cause or inflict the bodily harm, as the law only states the incident must involve the infliction of harm, not that the defendant must physically cause it. Carter’s team also argued that she should not be considered under the reasonable person standard, but the reasonable juvenile standard. The Court found that Carter was a reasonable juvenile, as her statements to the victim showed she fully understood the gravity of her actions. Lastly, Carter’s team was denied bringing forth an expert psychology witness in the original trial, and argued against this saying similar witness have been brought forth in similar cases. Kafker stated that one judge’s discretion over a different witness in a different case does not hold weight for this case.
The upholding of the case was the cause for some controversy. Matt Segal, the Massachusetts American Civil Liberties Union director, condemned the decision for its broad implications. His concern is that the decision has allowed prosecutors to place charges over subjective interpretations of speech that has been deemed “criminal”. Carter’s attorneys will explore appealing the case to the U.S. Supreme Court.
If you ever experience or have experienced suicidal thoughts, contact the National Suicide Prevention Hotline at 1-800-273-8255.