In a case that hinged largely on a teenage couple’s intimate text messages, Michelle Carter was found guilty of involuntary manslaughter Friday in the 2014 death of her boyfriend, who poisoned himself by inhaling carbon monoxide in his pickup truck, a Massachusetts judge ruled.
“She called no one, and finally she did not issue a simple additional instruction: Get out of the truck,” Bristol County Juvenile Court Judge Lawrence Moniz said during a 15-minute explanation of his rationale.
Carter, 20, cried silently as Moniz spoke. She stood to receive the ruling, which could set legal precedent for whether it’s a crime to tell someone to commit suicide.
Prosecutors had argued that Carter sent Conrad Roy III, 18, numerous text messages urging him to commit suicide, listened over the phone as he took his last breaths, and failed to alert authorities or his family that he’d died. The judge agreed.
Roy’s relatives, who sat near Carter in the front row of Moniz’s courtroom, wept as the judge ticked through the steps Roy took to end his life, as well as Carter’s complicity.
“This court has found that Carter’s actions and failure to act where it was her self-created duty to Roy since she put him in that toxic environment constituted reckless conduct,” the judge said. “The court finds that the conduct caused the death of Mr. Roy.”
Moniz let Carter, who was tried as a juvenile because she was 17 at the time of the crime, remain free on bail until her sentencing on August 3. She was ordered to have no contact with members of the Roy family. She cannot apply for or obtain a passport, nor can she leave Massachusetts without permission from a judge.
The ruling, which may spur lawmakers to codify the behavior highlighted in the case as criminal, was closely watched by legal experts.
“Given the expansive definition of manslaughter under Massachusetts law, the guilty verdict is not a surprise,” CNN legal analyst Danny Cevallos said.
“Still, this verdict is concerning because it reflects a judicial willingness to expand legal liability for another person’s suicide, an act which by definition is a completely independent choice,” he said. “Historically, suicide has been considered a superseding act which breaks the chain of legal causation.”
Texts drove suicide, prosecutors argued
Carter secretly nudged Roy toward suicide by sending him numerous text messages encouraging him to take his life, prosecutors said.
In closing arguments Tuesday, prosecutors said Carter berated her vulnerable boyfriend when he had second thoughts about killing himself, listened by phone to his last breaths and used his suicide to get from friends the attention that she desperately craved.
Carter went from offering “words of kindness and love” to aggressively encouraging Roy via text message to carry out longtime threats to commit suicide, Bristol Assistant District Attorney Katie Rayburn told the court.
“It got to the point that he was apologizing to her, … apologizing to her for not being dead yet,” Rayburn said in her closing argument.
Rayburn reminded the judge of text messages in which Carter encouraged Roy to get back in the truck. In text messages to a friend, she described hearing his finals words and breaths on the phone.
Roy’s body was found July 13, 2014, a day after his suicide in his parked truck in a Kmart parking lot in Fairhaven, nearly 40 miles from his home.
‘Tragic … not a homicide,’ defense said
Carter’s attorney argued she was a troubled, delusional young woman who was “dragged” into the suicidal journey of Roy, who has long been intent on killing himself.
“The evidence actually established that Conrad Roy caused his own death by his physical actions and by his own thoughts,” defense attorney Joseph Cataldo said. “You’re dealing with an individual who wanted to take his own life. … He dragged Michelle Carter into this.”
Carter was “overwhelmed” by Roy’s talk of suicide while at the same time dealing “with all of her baggage,” including the side effects of medication for depression, Cataldo said.
“It’s sad, it’s tragic,” he said. “It’s just not a homicide.”
Earlier in the trial, a psychiatrist testified that Carter was delusional after becoming “involuntarily intoxicated” by antidepressants. She was “unable to form intent” after switching to a new prescription drug months before Roy’s suicide, and she even texted his phone for weeks after he died, the psychiatrist testified.
Case watched closely
Legal experts had anticipated Friday’s ruling.
“The wrinkle here is whether she coerced him or pressured him into doing something that he wasn’t in a position to rationally and autonomously decide to do because he was in such a depressive state,” Daniel Medwed, professor of law and criminal justice at Northeastern University, said days before Moniz ruled.
“It’s a square peg in a round hole,” he said. “It’s not a perfect fit for manslaughter.”