52 N.E.3d 1054
Mass.2016Background
- Michelle Carter (17) was indicted as a youthful offender for involuntary manslaughter after Conrad Roy (18) died by suicide from carbon monoxide inhalation in July 2014.
- Carter and Roy exchanged frequent texts and calls; evidence showed Carter repeatedly encouraged Roy to kill himself, advised on method (generator/pump), pressured him about delays, and told him she would "take care" of his family.
- During the victim’s final suicide, police records show long phone calls; a friend reported Carter told Roy to get back into his truck when he had gotten out scared.
- Carter deleted messages, lied to police, and admitted she could have stopped him but did not; prosecutors presented these communications to a grand jury.
- The Juvenile Court denied Carter’s motion to dismiss the youthful offender indictment; the Supreme Judicial Court reviewed whether words alone could support an involuntary manslaughter indictment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether words alone can support probable cause for involuntary manslaughter (wanton/reckless conduct) | Commonwealth: texts/calls showed coercive, continuous pressure that overbore Roy’s will and caused his death | Carter: verbal encouragement, without providing the instrument or being physically present, cannot constitute wanton/reckless conduct or cause death | Held: Yes — under these facts words (including a coercive final command while virtually present) supported probable cause for wanton/reckless conduct causing death |
| Whether grand jury evidence was sufficient to establish intentional, wanton/reckless conduct, and causation | Commonwealth: presented extensive messages, calls, admissions, deleted texts, and witness report of panic and being told to re-enter truck | Carter: evidence insufficient as she neither furnished the means nor acted physically; causation breaks on victim’s independent act | Held: Sufficient — evidence could show subjective knowledge and that Carter’s communications overcame Roy’s will so his return to truck was not an independent intervening act |
| Vagueness/ First Amendment challenge to applying involuntary manslaughter to speech | Commonwealth: manslaughter common-law elements and case law cover speech that causally induces self-harm; State has compelling interest in preserving life | Carter: statute vague as applied; speech protected by First Amendment and Mass. Declaration of Rights | Held: Not vague as applied; speech here is unprotected because it had a direct causal link to a specific victim’s suicide and manslaughter elements were met |
| Youthful offender statute application (G. L. c.119, §54) | Commonwealth: manslaughter is punishable by state prison and involves serious bodily harm, and defendant was 17 at offense | Carter: argued conduct does not inflict or threaten serious bodily harm | Held: Grand jury properly returned youthful offender indictment because involuntary manslaughter satisfies the statute’s elements |
Key Cases Cited
- Commonwealth v. Moran, 453 Mass. 880 (used as standard for viewing grand jury evidence)
- Commonwealth v. Rex, 469 Mass. 36 (limited inquiry into grand jury sufficiency)
- Commonwealth v. McCarthy, 385 Mass. 160 (grand jury must hear evidence of criminal activity)
- Commonwealth v. Levesque, 436 Mass. 443 (probable cause standard)
- Commonwealth v. Pugh, 462 Mass. 482 (definition and standard for wanton/reckless conduct)
- Commonwealth v. Welansky, 316 Mass. 383 (wanton conduct framework)
- Commonwealth v. Atencio, 345 Mass. 627 (liability when concerted action induces self-inflicted death)
- Persampieri v. Commonwealth, 343 Mass. 19 (words plus aiding can support involuntary manslaughter)
- Life Care Ctrs. of Am., Inc. v. Commonwealth, 456 Mass. 826 (theories of involuntary manslaughter)
- Commonwealth v. Rodriquez, 461 Mass. 100 (manslaughter as common-law crime)
- Mendoza v. Licensing Bd. of Fall River, 444 Mass. 188 (state interest in preserving life invoked for speech limitations)
- Brown v. Entertainment Merchants Ass'n, 564 U.S. 786 (First Amendment standards referenced)
- Washington v. Glucksberg, 521 U.S. 702 (state interest in preservation of life)