In 2017, the Massachusetts Supreme Judicial Court found Michelle Carter guilty of involuntary manslaughter for the death of Conrad Roy, determining that her repeated text messages, which pressured Roy into suicide, constituted wanton and reckless conduct despite her physical absence. See Commonwealth v. Carter, 481 Mass. 352 (2019). Carter's holding was significant: words alone can have fatal consequences, and the individuals who employ them can be held criminally liable.