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Massachusetts Court Reverses Manslaughter Conviction Based on Overdose Death

Earlier this month, a state appellate court issued a written opinion in a Massachusetts manslaughter case discussing whether the evidence was sufficient to support the defendant’s conviction. Ultimately, the court concluded that the prosecution’s evidence was insufficient and reversed the defendant’s conviction for involuntary manslaughter. The court upheld the defendant’s conviction for distribution of heroin.

According to the court’s opinion, the defendant was a student at the University of Massachusetts in Amherst, and was also a heroin user. One day, another student who lived in the defendant’s neighborhood learned that the defendant frequently made trips to New York to buy heroin, and asked the defendant to pick him up some heroin on the next trip. The defendant agreed, and brought the other student back nine packets of heroin. The next day, the student’s father found his son dead from a heroin overdose in his apartment. The student had consumed three of the packets given to him by the defendant.

The defendant was charged with the distribution of heroin as well as involuntary manslaughter. At trial, the defendant was convicted of both counts. The defendant appealed each of his convictions on the basis that the evidence presented by the prosecution was insufficient to sustain a conviction.

On appeal, the court reversed the defendant’s conviction for involuntary manslaughter. The court began by noting that involuntary manslaughter requires the prosecution to show that the defendant acted with “wanton or reckless” conduct. The court explained that, heroin distribution “may constitute wanton or reckless conduct where, under the circumstances, there is a high degree of likelihood that the person will suffer substantial harm.”

The court also noted that “not every case will present circumstances that make such conduct wanton or reckless.” The court explained it must consider “the totality of the particular circumstances,” when determining whether the defendant “knew or should have known that his or her conduct created a high degree of likelihood of substantial harm, such as an overdose or death.” Essentially, the court’s position was that someone could be guilty of involuntary manslaughter based on an overdose death, but not in every case.

Here, the court held that the defendant’s actions did not rise to the level of wanton or reckless. The court pointed to the fact that the defendant did not know the heroin was unusually strong or laced with another drug, such as fentanyl. The defendant also did not have any indication that the other student was particularly vulnerable to an overdose. The court also noted that the defendant had no idea of the student’s prior drug history. Finally, the court also indicated that the fact that the defendant did not profit from the sale was relevant to its decision. Taking all this into account, the court determined that the evidence was insufficient to find the defendant guilty of involuntary manslaughter.

Have You Been Arrested for a Massachusetts Drug Crime?

If you have recently been arrested and charged with a Massachusetts drug offense, contact Attorney Patrick J. Murphy for immediate assistance. Attorney Murphy is a well-respected and experienced Boston criminal defense attorney with extensive experience handling all types of Boston drug cases. He has a thorough understanding of state and federal constitutional law, and uses this advanced knowledge to his clients’ advantage. To learn more about how Attorney Patrick Murphy can help you defend your freedom from the charges you face, call 617-367-0450 to schedule a free consultation.