SAN JOSE — Three former Santa Clara County jail guards who were convicted of murder for the notorious 2015 beating of mentally ill inmate Michael Tyree will soon be freed after pleading guilty to lesser charges, two years after higher courts overturned their original convictions.
Jereh Lubrin, 37, Matthew Farris, 36, and Rafael Rodriguez, 35, appeared in a San Jose courtroom Tuesday to enter the new voluntary manslaughter pleas, which have a maximum prison term of 11 years. After accounting for time served, they will likely be paroled in the next few months.
They entered their pleas next door to the Main Jail, which was the crime scene in the case. The three have been on home detention for the past month and will be formally sentenced in October.
In 2022, their second-degree murder convictions were thrown out by an appellate court, citing a legislative change that invalidated legal instructions jurors received while deciding the original 2017 verdict. The court’s ruling was upheld by the California Supreme Court the following year, leaving the district attorney’s office to decide whether to re-file the original murder charges, seek different charges, reach a plea agreement, or dismiss the case.
As part of a plea agreement, the three men were required to admit in Judge Benjamin Williams’ court Tuesday that they assaulted Tyree or aided and abetted the deadly attack on the inmate. They all answered affirmatively when Deputy District Attorney Matt Braker asked them to confirm that they participated in the assault and that they acted with “conscious disregard for human life.”
The defendants’ admissions also close the door for future appeals. District Attorney Jeff Rosen said that the resolution originated from a proposal from the defendants; Rosen said after Tuesday’s hearing that the agreement would not noticeably affect the prison time the defendants ultimately served. Their clean prison record made them likely to receive parole toward the end of this year.
“We accepted that disposition, the defendants pleaded guilty, and the cases concluded. We brought some finality, some measure of justice to Michael Tyree’s family, as well as our entire community,” Rosen said.
He noted that the defendants’ allocutions were important to his office in closing the case.
“It was important for us to have them say what they did, and what they did is beat this mentally ill man to death, and that it was an awful, awful crime,” he said.
Tyree’s death was a landmark event in the county that prompted a massive top-down civilian auditof the county jails andongoing scrutiny of South Bay custody operations. It also inspired the establishment of county-run civilian oversight over the jails, and clashes over the watchdog’s access to sheriff records, coupled with the sheriff’s office handling of subsequent jail inmate mistreatment cases, helped fuel a civil grand jury corruption trial that prompted the retirement, resignation, and formal expulsion of previous longtime sheriff Laurie Smith.
On Aug. 26, 2015, the 31-year-old Tyree was being held in the county Main Jail in San Jose while waiting for a bed to open up at a residential treatment center. Authorities say Lubrin, Farris and Rodriguez beat Tyree in his cell with batons, fists and kicks, inflicting severe injuries including trauma to his spleen, small bowel, liver, face, skull and the front and back side of his body.
In 2017, the three were convicted of second-degree murder and sentenced to 15 years to life in prison after jurors rejected a defense argument that the injuries were the result of an accidental fall or suicide.
During the two-month trial, prosecutors argued the defendants enjoyed inflicting pain on the job, presenting text messages from the deputies, primarily Farris, that mentioned inmates being “twisted up,” “sprayed,” “kicked,” “locked down,” “slapped” and “beaten the (expletive) down.” Other testimony alleged Lubrin had casually said, “beating people up is part of my job at the jail.”
Prosecutors also cited a web search byRodriguez titled, “Can you die if someone punches you in the armpit?” the day after Tyree died.
A year after the convictions, the state Legislature passed Senate Bill 1437, which amended state law to eliminate the legal argument known as “natural and probable consequences.” Juries had been allowed to cite the theory in finding a defendant guilty of murder, even if the person may not have directly killed anyone, on the premise that a victim’s death was a natural consequence of the defendant’s actions.
One of SB 1437’s objectives was to alleviate murder convictions for people who had peripheral roles in a crime but who were being punished the same as someone who committed deadly violence.
In August 2022, a three-judge panel from the Fourth District Court of Appeal, Division Three overturned the correctional deputies’ murder convictions after finding that trial jurors were told, in accordance with law at the time, that they could consider natural and probable consequences in reaching their decision.
Their ruling stated that SB 1437 applied retroactively — since the convictions were actively under appeal — and because there was no record to prove whether jurors factored the invalidated theory in their verdicts, the convictions could not stand.
The appellate ruling was brought to the California Supreme Court, which upheld the decision to overturn the convictions and send the case back to Santa Clara County for retrial. The Fourth District panel’s ruling did acknowledge that murder convictions might still be secured against Lubrin, Farris and Rodriguez under an “implied malice” theory, which argues that the deputies knew that their actions had potentially deadly consequences and proceeded anyway.
But implied malice must be assessed for each defendant, unlike natural and probable consequences, which allowed jurors to collectively assign blame without having to sort out individual culpability.
In a separate written statement, the district attorney’s office outlined some of the challenges that prosecutors identified in a prospective second trial, including the fact that Tyree was killed inside a small jail cell with no cameras and no witnesses. Those conditions, the office said, made it “a challenge for the prosecution to prove beyond a reasonable doubt which defendant committed or failed to commit any particular act.”
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