Commonwealth v. Carter, 481 Mass. 352

Summary

The Supreme Judicial Court of Massachusetts affirmed Michelle Carter's conviction for involuntary manslaughter as a youthful offender in connection with Conrad Roy's suicide. The court held that the trial evidence was sufficient to establish wanton or reckless conduct and causation, rejected due process and vagueness claims, and concluded that the defendant's coercive verbal conduct was not protected by the First Amendment or the Massachusetts Declaration of Rights.

Holdings

1. The evidence, viewed in the light most favorable to the Commonwealth, was sufficient to prove beyond a reasonable doubt that Carter engaged in wanton or reckless conduct that caused Roy's death by suicide.
2. The common-law offense of involuntary manslaughter was not unconstitutionally vague as applied to Carter's conduct.
3. Carter's conviction did not violate the First Amendment or article 16 because the punishable communications were reckless or wanton speech integral to a course of criminal conduct that caused death, rather than words alone.
4. General Laws chapter 119, section 54, does not require the defendant personally and directly to inflict serious bodily harm; involuntary manslaughter in these circumstances inherently involves the infliction of serious bodily harm.
5. The court did not decide whether an objective reasonable-juvenile standard applies because the trial judge found Carter's conduct wanton or reckless under the subjective standard based on her actual knowledge of the danger.
6. The Juvenile Court judge did not abuse his discretion by excluding the proposed forensic psychologist's general testimony concerning adolescent brain development, and Carter suffered no prejudice.

Questions Presented

1. Whether the trial evidence was sufficient to prove beyond a reasonable doubt that Carter's wanton or reckless conduct caused Roy's death.
2. Whether Carter's conviction violated due process because involuntary manslaughter was unconstitutionally vague as applied to her conduct.
3. Whether imposing criminal liability for her pressuring text messages and telephone communications violated the First Amendment or article 16 of the Massachusetts Declaration of Rights.
4. Whether the youthful-offender statute required Carter personally and directly to inflict serious bodily harm.
5. Whether wanton or reckless conduct by a juvenile must be evaluated under a reasonable-juvenile rather than a reasonable-person standard.
6. Whether the Juvenile Court judge abused his discretion by excluding proposed expert testimony concerning adolescent brain development.

Disposition

affirmed