Michelle Carter and the Death of Conrad Roy

In June 2017, news broke regarding the conviction of Michelle Carter. At 23 years old, Carter was charged with involuntary manslaughter for facilitating the suicide of her boyfriend, Conrad Roy III. The verdict caused controversy surrounding the matter of facilitated suicide — in other words, suicide assisted by someone other than a physician.

Physician-assisted suicide is a controversial issue on its own, but facilitated suicide is an entirely different story. While physically assisted suicide is prohibited across the country, laws regarding the facilitation of suicide through verbal encouragement vary by state.

Ultimately, the Commonwealth v. Carter case begged the question of whether or not Carter could truly be held accountable for Roy’s death.

The Conrad Roy Suicide

On the evening of July 12, 2014, Conrad Roy III, age 18, drove his truck to a secluded parking lot in Fairhaven, Massachusetts. There, Roy intentionally allowed a gasoline-powered water pump to leak deadly carbon monoxide into his truck. The next day, police discovered Roy’s body and, upon further investigation, determined that he had died by suicide.

As police sought to learn more about Roy’s death, they found suspicious phone conversations and other digital messages between Roy and his then 17-year-old girlfriend, Michelle Carter.

Roy and Carter had begun seeing each other in 2011. Although their relationship was on-and-off, they continued to communicate with one another through emails, phone calls, and texts until Roy’s suicide. Within these conversations, police found many messages discussing Roy’s intent to harm himself. In fact, Roy remained in constant contact with Carter until the very moment of his death, with Carter encouraging Roy to end his life.

Carter sent Roy text messages full of inflammatory statements, including:

“You’re just making it harder on yourself by pushing it off, you just have to do it.”

“You’re gonna have to prove me wrong because I just don’t think you really want this.”

“You better not be bullshitting me and saying you’re gonna do this and then purposely get caught.”

Following Roy’s suicide, Carter also texted a friend and stated: “I was on the phone with him and he got out of [the truck] because it was working and he got scared and I fucking told him to get back in.”

Almost a year later, on February 6, 2015, the Commonwealth of Massachusetts indicted Michelle Carter as a youthful offender on the charge of involuntary manslaughter as a result of her alleged role in encouraging Roy’s suicide.

On June 5, 2017, court proceedings for the case of Conrad Roy began. While the prosecution stated that Carter facilitated Roy’s suicide and manipulated him into going through with it, the defense argued that not only was Carter not culpable, but she also suffered from mental illness that impaired her judgment.

The Commonwealth v. Carter

In the state of Massachusetts, there are no statutes that prohibit facilitated suicide. As a result, when there is a case involving facilitated suicide, the state must use another approach for a conviction. In this instance, Carter was charged with involuntary manslaughter, and the Supreme Judicial Court of Massachusetts supported the indictment.

Over the course of the trial, the prosecution argued that Carter influenced Roy with two primary tactics. The first was by messaging Roy and instructing him to kill himself until the day of his death. The second way Carter allegedly manipulated Roy was by telling him, on the phone, to “get back in” the truck as it filled with carbon monoxide. While building their case, the prosecution contacted various witnesses — including Carter’s friends, Roy’s mother, and investigators — for additional support and credibility.

However, the defense argued that Carter’s statements were allowed as per the First Amendment and that Roy had complete autonomy over his suicide. The defense called upon two witnesses, including an electronics forensic expert named Steven Verraneau and the psychiatrist Dr. Peter Breggin. Dr. Breggin stated on the day of Roy’s death in July 2014, Carter was suffering from a “substance-induced mood disorder with manic features and irritability” from taking an antidepressant by the name of citalopram. Breggin went on to say that Carter was “involuntarily intoxicated” at the time of Roy’s death while also exhibiting symptoms of mania and psychosis.

Ultimately, the judge disagreed with the defense’s assertions and ruled Carter guilty of facilitating Roy’s suicide. This verdict is primarily due to the fact that on July 12, 2014, “she instructed him to get back in the truck which she has reason to know is becoming a toxic environment to human life.”

In August 2017, Carter was sentenced to over two years in the Bristol County House of Correction and Jail.

Who Is Responsible for the Death of Conrad Roy?

While this highly divisive case is technically resolved, there remains much debate over responsibility for the death of Conrad Roy.

Michelle Carter’s case drew nationwide attention, bringing the issue of facilitated suicide to the fore. While there have been several other cases in Massachusetts involving facilitated suicide, in most of these incidents, the defendants were physically present at the time of death. In the case of the Commonwealth v. Carter, Carter wasn’t physically with Roy at the time of his death, but the court still ruled that “there was evidence that the defendant’s actions overbore the victim’s willpower.”

Throughout the trial, the defense argued that Carter’s words were protected under the First Amendment, and there was much debate surrounding the validity of this argument. Despite the right to the freedom of speech, there are specific limitations to this amendment. In the case of the Commonwealth v. Carter, the most relevant limitation is that the First Amendment does not protect against “fighting words,” which are defined as words “by which their very utterance inflict injury or tend to incite an immediate breach of the peace.”

Despite the judge’s ruling, those who disagree with the verdict state that Roy had full control over his actions, even if he was in a weakened state of mind as a result of his depression. Roy took the initiative to obtain the gas-powered water pump because he knew it would fill his truck with a fatal level of carbon monoxide. Under this line of thinking, proponents of Carter’s legal innocence argue that though Roy was in a feeble state of mind, he had autonomy over his suicide. In their view, Carter cannot be held culpable for Roy’s decisions because she had no legal obligation to tend to Roy’s mental state.

With the case and Carter’s sentence now concluded, the question of responsibility may seem largely academic. But for Roy’s loved ones and the legal implications of cases to come, the controversy over facilitated suicide will remain a lingering concern.