After a seven-day bench trial, Michelle Carter has been found guilty of involuntary manslaughter for urging her boyfriend, Conrad Roy III, to commit suicide via text message. Massachusetts Judge Lawrence Moniz sat with the case for two days before handing down his landmark decision on Friday in a packed Bristol County Juvenile Court.
Roy's family cried as Moniz reasoned that Carter's conduct "caused the death" of her boyfriend. Moniz did not revoke bail, but told Carter not to contact Roy's family. "No texting, no Facebook, no Snapchat." Sentencing was scheduled for August 3rd. Carter, who was charged as a youthful offender, faces 20 years in prison.
On Tuesday, in her closing argument, Bristol County District Attorney Katie Rayburn said that "the risk Carter created was reckless and amounts to involuntary manslaughter." In the age of people falling "in love via the Internet and via text," the prosecutor said that "you can encourage someone to die via text, and you can commit a crime via text." Carter's defense lawyer, Joseph P. Cataldo, contended that Roy was "somebody who wanted to eventually take his own life" and his death was "sad, tragic, but it's just not a homicide."
Roy's suicidal thoughts went public on the final day of court proceedings, which was live-streamed. In two undated notes, he told both his father, Conrad, and Carter that he would see them "someday in Heaven." He told his father that he could not "take the pain" and that he "did this to be happy." He thanked Carter for her kindness. "I love you and really appreciate ur effort."
Carter's case gained national media attention and stimulated legal and moral debates across the United States. How could Carter be held responsible for Roy's suicide via text? Should she be convicted of a crime based on her words alone? Such questions also challenged prosecutors, especially since Massachusetts, unlike at least 40 other states, has no law against assisting someone in taking their own life.
Cataldo has long argued that prosecutors tried to circumvent the lack of state law by charging his client with involuntary manslaughter. In April 2016, he tried getting the indictment thrown out, but the state's highest court allowed prosecutors to pursue matters citing two cases from the 1960s in which people were convicted of involuntary manslaughter for the suicide of others. Three months later, the high court ruled that Carter could be tried as a youthful offender for involuntary manslaughter since she had "verbal communications" with her boyfriend that could have carried "more weight than mere words, overcoming any independent will to live he might have had," Robert Cordy, a Supreme Judicial Court justice who has since retired, wrote in the decision.
For some legal experts, Carter's actions don't live up to the standards for the crime. "Her behavior was horrible, but it doesn't fit perfectly with involuntary manslaughter," Daniel Medwed, a professor at Northeastern University School of Law, tells Rolling Stone. As he explains, a classic manslaughter charge involves "a direct reckless action" – for examples, a drunk driver plowing into a pedestrian or someone firing a gun into a crowd – but here is "an indirect action because Carter's words may have pushed Roy to do something, but ultimately Roy was the one who did it," Medwed says. "The prosecution is saying that Carter's words are the weapon and that she directly caused his death."
It was July 13th, 2014, when 18-year-old Roy's body was found inside his black Ford F250 parked in a Fairhaven, Massachusetts Kmart parking lot. He had rigged a gasoline-powered water pump to release carbon monoxide into his truck and ultimately into his lungs. He stepped out of the truck at one point and talked with Carter who instructed him to get back into the vehicle. In February 2015, a grand jury in Bristol County indicted Carter, then a 17-year-old high school student, as a "youthful offender" which meant that instead of a typical juvenile charge, prosecutors could seek a more severe prison sentence. Carter pleaded not guilty, while prosecutors proceeded to paint her as the arbiter of Roy's suicide.
In his decision, Moniz found that Carter's instructing Roy to get back in his truck was reckless and she failed her duty under state law to take action and help him.
On Monday, June 5th, in her first court appearance, Carter, now 20, "made a rather bold move" in waiving her right to a jury trial, according to Bob McGovern, a reporter covering the case for the Boston Herald. It was the only time she appeared on the witness stand. Bench trials are somewhat rare in Massachusetts, but the defense figured that Judge Moniz could remain "clinical" rather than a jury "potentially swayed by emotions," Medwed says.
Prosecutor MaryClare Flynn said Carter played a "sick game of life and death for attention" when pushing Roy to commit suicide despite his excuses to put it off. Cataldo contended that Roy was afflicted with abuse at home and already attempted suicide. He said that Carter was not a manipulator, but a vulnerable teenager treated for mental health issues at a psychiatric hospital and struggling with the side effects of prescribed antidepressants when she became "overwhelmed" with Roy's suicidal plans.
Roy's mother testified that she and her son spent July 12th, 2014 at Horseneck Beach in Westport, before he drove himself to the Kmart parking lot. She confirmed that Roy had attempted an overdose after being treated for depression, but recalled that his life was turning around for the better. He had graduated high school and was accepted to Fitchburg State University. "I thought he was a little depressed," Lynn said, according to MassLive.com, before adding, "I thought he was doing great." One of Roy's younger sisters testified that Carter texted her that day. "Find him yet?" according to ABC News. The sister, who was 13 years old at the time of her brother's suicide, added that Carter asked her for Roy's ashes two days before his funeral.
Rayburn presented evidence showing that Roy had second thoughts at the Kmart parking lot and stepped out of his vehicle at one point, but Carter convinced him to get back inside and finish the job. Carter's friends supported the claim. Lexi Eblan testified that Carter texted her that she had "all these flashback thoughts of when I was talking to him on the phone when he killed himself" and that she had panic attacks when thinking of "hearing his cries." Samantha Boardman testified that Carter texted her that she "could have stopped him," but she "fucken told him to get back in."
Last Wednesday, Carter, her defense team, prosecutors and Judge Moniz "toured" the Kmart parking lot. Rayburn pursued an emotional tactic by asking Judge Moniz – the judge and jury in the bench trial – to consider the parking spot where Roy's dead body was found inside his truck.
Rayburn questioned state police Sgt. Michael Bates, who helped collect thousands of texts between the teenagers. One week before Roy's death, Carter texted that Roy could "take 10 benedryls and then wait 10 mins then take all the Tylenol," Bates testified. She also suggested that he should "hang yourself, jump off a building, stab yourself."
After the prosecution rested, Judge Moniz rejected a defense motion to find Carter not guilty. Steven Verronneau, a forensic investigator who analyzed both of the teens' phones and computers for the defense, testified that Roy visited search engines where he sought answers for "easy, quick and painless ways to commit suicide?" A month before his death, Roy searched, "suicide by cop" and "I want to kill myself, what meds shall I take to die while sleeping?" Verronneau testified that two days before he died, Roy sent Carter a picture of a portable generator – the same he used to help release carbon monoxide into his truck, according to the Washington Post.
The defense rested after Dr. Peter Breggin, a Harvard-trained psychiatrist, testified that Carter was "involuntarily intoxicated" when taking an SSRI drug that altered her ability to make decisions. Breggin said that she was diagnosed with depression and took Prozac before being given Celexa at too high a dose, according to the Boston Globe. Defense lawyers added that Carter started taking Celexa in April 2014 for "impulse control issues" and went into an inpatient program two months later at McLean Hospital.
As for the verdict, it could have some lasting implications. "I was surprised that her despicable behavior constituted manslaughter, but I'm not shocked because what she did was so reprehensible that a judge wanted to hold her accountable," Medwed says. "I'm worried about whether this could embolden prosecutors to pursue manslaughter charges." In Massachusetts, he says, what will probably happen is legislators will pass a law criminalizing suicide. "That's a good thing. We should have a law that governs this behavior. Manslaughter was always an ill-fitting suit."