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Michelle Carter Is Guilty of Manslaughter in Texting Suicide Case Guilty Verdict for Young Woman Who Urged Friend to Kill Himself
(about 9 hours later)
TAUNTON, Mass. — A young woman who sent a barrage of text messages to another teenager urging him to kill himself was found guilty Friday of involuntary manslaughter in a case that many legal experts had expected to result in an acquittal. TAUNTON, Mass. — For a case that had played out in thousands of text messages, what made Michelle Carter’s behavior a crime, a judge concluded, came in a single phone call. Just as her friend Conrad Roy III stepped out of the truck he had filled with lethal fumes, Ms. Carter told him over the phone to get back in the cab and then listened to him die without trying to help him.
The verdict, handed down by a judge in a nonjury trial, was a rare legal finding that, essentially, a person’s words alone can directly cause someone else’s suicide. That command, and Ms. Carter’s failure to help, said Judge Lawrence Moniz of Bristol County Juvenile Court, made her guilty of involuntary manslaughter in a case that had consumed New England, left two families destroyed and raised questions about the scope of legal responsibility. Ms. Carter, now 20, is to be sentenced Aug. 3 and faces up to 20 years in prison.
The judge, Lawrence Moniz, of Bristol County Juvenile Court in southeastern Massachusetts, said the conduct of the woman, Michelle Carter, toward Conrad Roy III was not only immoral but illegal. Ms. Carter, who faces up to 20 years in prison, will be sentenced on Aug. 3. The judge’s decision, handed down on Friday, stunned many legal experts with its conclusion that words alone could cause a suicide.
Ms. Carter was 17 in July 2014 when she encouraged Mr. Roy, 18, whom she called her boyfriend, to kill himself. On July 12, while she was miles away, he drove alone to a Kmart parking lot and hooked up a water pump that emitted carbon monoxide into the cab of his truck. When he became sick from the fumes and stepped out, prosecutors said, Ms. Carter ordered him by phone to “get back in.” He was found dead the next day. “This is saying that what she did is killing him, that her words literally killed him, that the murder weapon here was her words,” said Matthew Segal, a lawyer with the American Civil Liberties Union of Massachusetts, which raised concerns about the case to the state’s highest court. “That is a drastic expansion of criminal law in Massachusetts.”
Knowing that Mr. Roy was in his truck and in a toxic environment, the judge said, Ms. Carter took no action. Ms. Carter’s defense team is expected to appeal the verdict. Legal experts said that it seemed to extend manslaughter law into new territory, and that if it stood, it could have far-reaching implications, at least in Massachusetts.
“She admits in subsequent texts that she did nothing, she did not call the police or Mr. Roy’s family,” Judge Moniz said. “And finally, she did not issue a simple additional instruction: ‘Get out of the truck.’” “Will the next case be a Facebook posting in which someone is encouraged to commit a crime?” Nancy Gertner, a former federal judge and Harvard Law professor, asked. “This puts all the things that you say in the mix of criminal responsibility.”
The verdict came as a surprise to many legal experts, because suicide is generally considered, legally, to result from a person’s free will. Judge Moniz unspooled his verdict in a packed courtroom, which was silent except for his voice and Ms. Carter’s gasping sobs. By the time he told Ms. Carter to stand up, and pronounced her guilty, the two families seated on either side of the courtroom’s aisle Ms. Carter’s and Mr. Roy’s wept, too.
The verdict concluded an emotionally draining weeklong trial in southeastern Massachusetts involving two troubled teenagers who had built a virtual relationship largely on texting from 2012 to 2014. Ms. Carter, then 17, started out encouraging Mr. Roy, 18, to seek treatment for his depression but then abruptly changed, and in the two weeks before he killed himself on July 12, 2014, she encouraged him, repeatedly, to do it.
For all the scrutiny during the trial of their texts, the judge based his guilty verdict on a phone conversation.
Once Mr. Roy drove his truck to a remote spot at a Kmart parking lot, the two ceased texting and instead talked on their cellphones. When Mr. Roy, with fumes gathering in the cab of his truck, apparently had a change of heart and stepped out, the judge said, Ms. Carter told him to get back in, fully knowing “his ambiguities, his fears, his concerns.”
“This court finds,” the judge added, “that instructing Mr. Roy to get back in the truck constituted wanton and reckless conduct.”
But the phone conversation was not recorded, and the only evidence of its content came three months after the suicide in a text from Ms. Carter to a friend.
“Sam his death is my fault, like honestly I could have stopped him,” Ms. Carter wrote. “I was on the phone with him and he got out of the car because it was working and he got scared.”
She said she then instructed him “to get back in.”
The prosecution made this phone call, as described in Ms. Carter’s text, the heart of its case. And the judge accepted it as factual and incriminating.
The defense strongly argued that there was nothing to substantiate what Ms. Carter had said on the phone and insisted that Mr. Conrad, who had tried to kill himself before, was determined to take his own life, regardless of anything Ms. Carter did or said.
Judge Moniz acknowledged that Mr. Roy had taken steps to cause his own death, like researching suicide methods, obtaining a generator and then the water pump with which he ultimately poisoned himself. Indeed, Judge Moniz said that Ms. Carter’s text messages pressuring him to kill himself had not, on their own, caused his death.Judge Moniz acknowledged that Mr. Roy had taken steps to cause his own death, like researching suicide methods, obtaining a generator and then the water pump with which he ultimately poisoned himself. Indeed, Judge Moniz said that Ms. Carter’s text messages pressuring him to kill himself had not, on their own, caused his death.
But then, Judge Moniz homed in on the cellphone calls between Ms. Carter and Mr. Roy while he was poisoning himself in his car. At the time, he said, Mr. Roy had fearfully climbed out of the car. Instead, the judge zeroed in on the moment that Mr. Roy climbed out of his truck.
“He breaks that chain of self-causation by exiting the vehicle,” Judge Moniz said. “He takes himself out of that toxic environment that it has become.” “He breaks that chain of self-causation by exiting the vehicle,” Judge Moniz said. “He takes himself out of that toxic environment that it has become.” That, the judge said, was a clear indication that Mr. Roy as on his previous suicide attempts wanted to save himself.
Judge Moniz pointed out that, during previous suicide attempts in 2012, Mr. Roy had second thoughts and reached out to friends and family for help. But, the judge said, Mr. Roy did not get help when he talked with Ms. Carter. But, the judge said, Ms. Carter had a duty to help Mr. Roy after she had put him in danger by ordering him back into the truck.
“She instructed Mr. Roy to get back into the truck, well knowing his ambiguities, his fears, his concerns,” Judge Moniz said. “This court finds that instructing Mr. Roy to get back in the truck constituted wanton and reckless conduct, by Ms. Carter creating a situation where there is a high degree of likelihood that substantial harm will result to Mr. Roy.” “She admits in a subsequent text that she did nothing, she did not call the police or Mr. Roy’s family,” the judge said. “She called no one. And finally, she did not issue a simple additional instruction: ‘Get out of the truck.’”
As he finished, Judge Moniz asked Ms. Carter, who was sobbing, to stand. He then concluded: “This court, having reviewed the evidence, finds you guilty on the indictment with involuntary manslaughter.” The verdict stunned many legal specialists because suicide is generally considered, legally, to result from a person’s free will.
A spectator let out an audible “wow” as the judge pronounced her guilty. Daniel Medwed, a law professor at Northeastern University, said the decision surprised him because the manslaughter charge seemed “a stretch” to begin with. Because Ms. Carter was not at the scene, and Mr. Roy ultimately acted alone, he said, it was difficult to prove she “caused” the death.
In the courtroom’s front benches, the two families on either side of the aisle Ms. Carter’s and Mr. Roy’s were also sobbing. Mr. Roy’s mother, Lynn, left the courtroom with a tissue in hand and a tight smile, while Ms. Carter rocked ever so slightly back and forth at the defense table, her chin in her hands. Ms. Gertner of Harvard said that likely grounds for appeal would be that the verdict had “extended the law of involuntary manslaughter to an arena into which it hasn’t been extended before — the notion of liability with respect to a suicide for someone who failed to act, who wasn’t present, who didn’t provide the instrumentalities for the suicide and the concept of a failure to intervene are all unique and that’s what would be litigated.”
In a brief statement, Conrad Roy Jr., Mr. Roy’s father, thanked the prosecutors and said: “This has been a very tough time for our family and we’d like to process this verdict, that we’re happy with.” At its core, the case was about two troubled teenagers and the fatal path their online relationship took.
As he left the courthouse, Ms. Carter’s defense lawyer, Joseph P. Cataldo, said that he was “disappointed” in the verdict and that the case was “pending,” indicating a possible appeal. Mr. Roy was a gentle but deeply depressed teenager who worked as a tugboat captain. He had graduated from high school with a college scholarship, but worried about the social anxiety he might experience there.
Relying heavily on voluminous online correspondence, the trial exposed the interior lives of two troubled teenagers, putting their thoughts, their secrets and their rock-bottom self-images on display. Judge Moniz said both of their families had been “immutably changed” by the case, and as arguments closed on Tuesday, Mr. Roy’s family and Ms. Carter herself were left in tears. Ms. Carter was a high school student with homework to finish and a love of the television show “Glee,” but she said her life was controlled by an eating disorder. She too was wrought by social anxiety, desperately seeking the approval of friends whom she admired but worried did not truly like her.
The judge’s decision surprised many legal experts, who had said that, despite the callousness of Ms. Carter’s conduct, the case presented a stiff challenge to prosecutors because Massachusetts, unlike dozens of other states, has no law against encouraging suicide. When Mr. Roy told Ms. Carter in June 2014 that he was considering suicide, she told him he had a lot to live for and urged him to seek help.
Moreover, Ms. Carter was not at the scene. To secure a conviction of involuntary manslaughter, prosecutors needed to show that Ms. Carter’s words alone, typed in thousands of text messages to Mr. Roy, were reckless and essentially killed him.
Legal experts said the judge might have wanted to convey to Massachusetts lawmakers that they needed to pass laws to hold people accountable for their online conduct.
“This sends a strong message to people that using technology to bully people into committing suicide will not be tolerated,” said Daniel S. Medwed, a law professor at Northeastern University.
But Mr. Medwed said he was surprised at the guilty verdict, because the manslaughter charge seemed “a stretch” to begin with. Because Ms. Carter was not at the scene, and Mr. Roy ultimately acted alone, he said, it was difficult to prove she “caused” the death.
“We don’t see this every day,” said Laurie Levenson, a law professor at Loyola Law School in Los Angeles. She said that the decision by a single court in Massachusetts was unlikely to set a legal precedent, but that it could have a social effect.
“On the broader societal spectrum, I think it sends a message that behavior that we sometimes attribute to odd teenage behavior can actually be so extreme that it’s homicide,” she said.
“What used to be seen as just a tragedy,” she added, “is now going to be classified, perhaps, as a crime.”
The virtual nature of Ms. Carter’s role was not a barrier for the judge. And his verdict signaled that the law might need to catch up with cultural and behavioral changes wrought by technology.
A prosecutor made that very point in arguing that Ms. Carter’s physical absence from the suicide scene was immaterial.
In a trial that lasted a week, prosecutors used Ms. Carter’s text messages to paint a portrait of a needy, insecure teenager who pushed Mr. Roy to kill himself in an effort to gain attention. Defense lawyers used the same messages to depict Ms. Carter as a misguided teenager, addled by medication, who thought she was helping a deeply troubled friend.
Ms. Carter and Mr. Roy texted incessantly about their troubles: depression for him, an eating disorder for her, and profound social anxiety for both. When Mr. Roy told Ms. Carter in June 2014 that he was seriously considering suicide, she told him he had a lot to live for and urged him to seek help.
“I’m trying my best to dig you out,” Ms. Carter wrote.“I’m trying my best to dig you out,” Ms. Carter wrote.
“I don’t wanna be dug out,” Mr. Roy answered, adding later, “I WANT TO DIE.”“I don’t wanna be dug out,” Mr. Roy answered, adding later, “I WANT TO DIE.”
By early July, she began to embrace the idea. “If this is the only way you think you’re gonna be happy, heaven will welcome you with open arms,” she wrote.By early July, she began to embrace the idea. “If this is the only way you think you’re gonna be happy, heaven will welcome you with open arms,” she wrote.
Ms. Carter said she would look like a “fool” if Mr. Roy did not kill himself. They talked at length about how he could kill himself with carbon monoxide. “If you emit 3200 ppm of it for five to ten mins you will die within a half hour,” she wrote. In the last days of his life, she told him repeatedly, “You just need to do it.” They talked at length about how he could kill himself with carbon monoxide. “If you emit 3200 ppm of it for five to ten mins you will die within a half hour,” she wrote. In the last days of his life, she told him repeatedly, “You just need to do it.”
With such texts projected onto large screens in the courtroom, there was no question that Ms. Carter had encouraged Mr. Roy to kill himself. The lawyers argued instead about motive. Prosecutors said Ms. Carter wanted Mr. Roy to kill himself because she wanted the sympathy that would come as the “grieving girlfriend.” Ms. Carter’s lawyers cast her as a naïve teenager who wanted to help people and was not even on the scene when Mr. Roy took his life
Prosecutors said Ms. Carter had caused Mr. Roy’s death because she wanted the sympathy that would come to her as the “grieving girlfriend.” In a ploy to get attention from girls she admired, the prosecutors said, Ms. Carter erroneously told them that Mr. Roy was missing two days before he actually was. That Mr. Roy was still alive, they said, increased the pressure on Ms. Carter to make sure he would soon be dead. But the prosecution argued in its closing and evidently Judge Moniz agreed that Ms. Carter’s physical absence was immaterial.
“Every time he came up with an excuse not to do it, she kicked his feet out right from under him and told him why it didn’t matter, why he still needed to die,” an assistant district attorney, Katie Rayburn, said during Tuesday’s closing statements. “The phones that we have now allow you to be virtually present with somebody,” Katie Rayburn, an assistant district attorney, said, adding, “She was in his ear, she was in his mind, she was on the phone, and she was telling him to get back in the car even though she knew he was going to die.”
Ms. Carter’s lawyers cast her as a naïve teenager who wanted to help people. She began encouraging Mr. Roy to kill himself, they said, only after she became “involuntarily intoxicated” with antidepressants and was convinced he was determined to end his life.
Mr. Cataldo argued that Mr. Roy had a history of depression, had tried to kill himself before and had conducted hundreds of online searches for ways to die.
“She takes no physical steps. She doesn’t threaten him with serious bodily harm,” Mr. Cataldo told the judge in his closing argument. “Conrad Roy knows what he is doing, your honor. He made a choice to commit suicide.”
“Michelle Carter,” Mr. Cataldo added, “did not kill Conrad Roy.”
And yet, in the weeks after Mr. Roy’s death, Ms. Carter texted friends that she felt responsible: that she could have stopped him but did not. And she feared her texts would implicate her.
“Sam they read my messages with him I’m done,” she wrote to one friend. “His family will hate me and I can go to jail.”