Morally Wrong, Constitutionally Vague: The Improper Conviction of Michelle Carter

In this Note, Madison Heckel analyzes Michelle Carter’s conviction of involuntary manslaughter for encouraging and commanding her boyfriend to kill himself. Heckel argues that the Massachusetts Appellate Court ignored the full extent of the fair warning requirements and incorrectly determined that there was appropriate notice that Carter’s conduct could result in criminal prosecution. Heckel further contends that the U.S. Supreme Court erred in denying Carter’s writ of certiorari and that her conviction was unconstitutional.

Madison N. Heckel is a Juris Doctor candidate at Loyola University Chicago School of Law, class of 2021.

Recommended citation: Madison N. Heckel, Morally Wrong, Constitutionally Vague: The Improper Conviction of Michelle Carter, 52 Loy. U. Chi. L.J. Online 17 (2021).