Massachusetts Manslaughter Conviction Upheld in Teen Texting Suicide Case

By Nate Raymond

BOSTON – Massachusetts’ highest court affirmed on Wednesday the manslaughter conviction of a woman who was accused of encouraging her teenage boyfriend to take his own life in 2014 through text messages and phone calls. This case has garnered significant national attention regarding the issues of cyber-bullying.

The Massachusetts Supreme Judicial Court upheld a 2017 ruling concerning Michelle Carter. Prosecutors argued that Carter urged her boyfriend, Conrad Roy, 18, to end his life in a parking lot approximately 60 miles south of Boston.

This case was notable as it was the first in the state to address manslaughter charges connected to texting, raising alarm among civil liberties advocates who claimed that Carter was being prosecuted for exercising her free speech rights.

Justice Scott Kafker stated that the evidence substantiated the assertion that Carter, then 17, “badgered” Roy over the phone to return to a truck filled with carbon monoxide, after “constantly pressuring” him through text messages to take his life.

“The evidence against the defendant proved that, by her wanton or reckless conduct, she caused the victim’s death by suicide,” Kafker wrote on behalf of the unanimous seven-member court.

Kafker dismissed Carter’s arguments, now 22, that her conviction infringed upon her free speech rights under the U.S. Constitution. He clarified that the court was not penalizing her for her speech alone, but rather for “reckless or wanton words causing death.”

Daniel Marx, Carter’s attorney, expressed disappointment with the ruling and indicated that he was contemplating an appeal to the U.S. Supreme Court.

Roy died by suicide on July 12, 2014, by filling his parked truck in Fairhaven, Massachusetts, with carbon monoxide from a generator he had connected.

During the trial, prosecutors presented evidence that Roy had briefly exited the vehicle after being overwhelmed by fumes but returned after Carter, who was on the phone with him at the time, urged him to “get back in.”

This instruction was noted in a text message Carter sent to a friend. Previously, she had encouraged Roy to “promise” to take his own life and had assisted him in planning the act after he had previously attempted to end his life.

Carter, from Plainville, Massachusetts, was indicted in 2015. She chose not to have a jury trial, allowing her fate to be determined by Bristol County Juvenile Court Judge Lawrence Moniz, who found her guilty of involuntary manslaughter in June 2017.

Moniz subsequently sentenced her to serve 15 months of a 2 1/2-year prison term, which was put on hold while she appealed the decision.