Massachusetts Supreme Judicial Court Upholds Manslaughter Conviction Against Teen Who Encouraged Boyfriend to Commit Suicide

The Massachusetts Supreme Judicial Court today affirmed a juvenile girl’s conviction for involuntary manslaughter after she successfully urged her boyfriend to commit suicide by way of carbon monoxide poisoning.  The name of the case is Commonwealth v. Carter. 

The 17-year-old defendant and her 18-year-old boyfriend had a relationship that was conducted mostly over the phone.  They spoke and texted frequently and the defendant knew the victim suffered from mental illness and was suicidal.  In the years prior to his death, the victim had attempted suicide on multiple occasions.  The defendant initially encouraged the victim to seek help for his mental illness and suggested they be treated together at McLean Hospital (where she was planning to seek treatment for an eating disorder).  However, as time passed, the defendant began supporting the victim’s plans to commit suicide and ultimately suggested he use a portable generator to poison himself.  When the victim expressed concern that his suicide would upset his family, the defendant assured him his parents would accept his suicide and “move on.”  When the victim balked at killing himself, the defendant texted him and made him promise to kill himself by driving to a parking lot and running the generator in his truck.  Cell phone records established the defendant was talking to the victim on the phone as he was poisoning himself.  After the victim died, the defendant texted a friend and said the victim had gotten out of the truck after feeling the effects of the carbon monoxide.  The defendant told the victim to get back into the truck, which he did.  He died a short time later.  A juvenile court judge found the defendant guilty of involuntary manslaughter and sentenced her to serve 15 months in jail.  The defendant appealed and the Supreme Judicial Court affirmed.

A person is guilty of involuntary manslaughter when, through her reckless or wanton conduct, she unintentionally causes the death of another person.  The defendant here argued the evidence introduced at her trial was insufficient to allow the judge to find her guilty.  The SJC ruled there was “no question” the defendant’s conduct was reckless or wanton.  She knew the details of the victim’s mental illness and was aware he had attempted suicide in the past.  The defendant certainly would have appreciated the grave danger to the victim’s life.  Nevertheless, she made the decision to encourage his suicide and badger him into returning to his poisonous truck after he escaped.  The Court also concluded the Commonwealth had proven causation – it was the defendant’s words that caused the victim’s death.  The defendant’s conduct did not become criminal until she told the defendant to get back into the truck after he exited the vehicle.  The trial judge determined, and the SJC affirmed, that the defendant’s words overpowered the victim’s will and therefore caused his death.  When the mentally-ill victim saved himself from the poisoning by getting out of his truck, it was the defendant – his girlfriend and close confidant – who encouraged him to fulfill his promise to her that he would kill himself.  And after he followed her order, she failed to call for help.  Instead, she listened to him choke to death.

The defendant had been free pending appeal, but after the SJC affirmed her conviction she was taken into custody and has started to serve her 15-month sentence.