Commonwealth v. Carter

Massachusetts Supreme Judicial Court
52 N.E.3d 1054, 474 Mass. 624 (2016)

ELI5:

Rule of Law:

Verbal conduct, including encouragement and coercion, can constitute the wanton or reckless conduct required for an involuntary manslaughter charge if it overwhelms a vulnerable person's willpower and causes them to commit suicide.

Facts:

Conrad Roy had a history of mental illness and a prior suicide attempt.
Michelle Carter and Conrad Roy were in a long-distance relationship and communicated primarily via text messages and phone calls.
Carter was aware of Roy's mental health history and his suicidal thoughts.
Over an extended period, Carter sent Roy numerous text messages encouraging him to commit suicide, assisting him in planning the method, and chastising him for his delays.
On July 12, 2014, Roy began his suicide attempt by filling his truck with carbon monoxide from a water pump.
During the attempt, Roy became scared, exited the vehicle, and expressed hesitation to Carter over the phone.
While on the phone with Roy, Carter commanded him to get back into the truck.
Roy re-entered the truck and subsequently died from carbon monoxide poisoning.

Procedural Posture:

On February 6, 2015, a grand jury indicted Michelle Carter as a youthful offender for involuntary manslaughter.
Carter filed a motion to dismiss the indictment in the Juvenile Court.
A Juvenile Court judge denied Carter's motion to dismiss.
Carter filed a petition for extraordinary relief with a single justice of the Massachusetts Supreme Judicial Court.
The single justice reserved and reported the case to the full Supreme Judicial Court for a decision on the motion to dismiss.

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Issue:

Is verbal conduct alone, specifically a systematic campaign of encouragement and a final command to a vulnerable person to complete a suicide attempt, sufficient evidence to support a grand jury indictment for involuntary manslaughter on a theory of wanton or reckless conduct?

Opinions:

Majority - Cordy, J.

Yes. Verbal conduct alone is sufficient to support an indictment for involuntary manslaughter when the evidence suggests it constitutes wanton or reckless conduct that causes a death. The court rejected the argument that words can never overcome a person's willpower to live. Citing precedent like Commonwealth v. Atencio, the court reasoned that 'mutual encouragement' and 'concerted action' can lead to a death for which participants are criminally liable. The inquiry is fact-specific, and in this case, the defendant’s relationship with the victim, her 'virtual presence' at the suicide, the constant pressure she applied, and the victim's fragile mental state were critical circumstances. The defendant's final command to 'get back in' at the victim's moment of equivocation could be found by a jury to have been a coercive act that overbore the victim's willpower. Therefore, the victim's act of returning to the truck was not an independent intervening cause, but a direct result of the defendant's wanton or reckless conduct.

Analysis:

This decision significantly clarifies that verbal conduct, particularly in the context of modern electronic communication, can satisfy the actus reus for involuntary manslaughter. It establishes that psychological coercion can be a legally sufficient cause of a suicide, especially when a defendant exploits a victim's known vulnerabilities. This ruling sets a precedent for prosecuting individuals who encourage suicide, potentially expanding criminal liability for cyberbullying and online harassment that results in death. The case signals that the law will look beyond physical actions to hold individuals accountable for the foreseeable and deadly consequences of their words.

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