Santa Clara County prison guards convicted of killing in custody will soon be released after renewed plea to manslaughter

SAN JOSE, CA — Three former Santa Clara County jail guards will soon be released after beating incarcerated Michael Tyree in 2015, two years after their murder convictions were overturned — the three jail guards pleaded guilty to lesser charges to avoid a second trial, according to The Mercury News.

Wrote The Mercury NewsOn August 26, 2015, Tyree, 31, was being held in the San Jose County Jail. While he was waiting for a bed at a treatment center, authorities say Jereh Lubrin, 37, Matthew Farris, 36, and Rafael Rodriguez, 35, beat him with batons, fists, and kicks in his cell.

Tyree suffered severe injuries, including trauma to his spleen, small intestine, liver, face, skull, and the front and back of his body.

In 2017, the three prison guards were convicted of first-degree murder. Jurors rejected the defense's argument that the injuries were the result of a fall or suicide. The three guards were sentenced to 15 years to life in prison.

During the two-month trial, prosecutors presented officers' text messages, most of which were from Farris, that described detainees being “twisted,” “sprayed,” “kicked,” “locked,” “slapped” and “beaten up.”

According to other witnesses The Mercury News, Lubrin had said casually, “Beating people up is part of my job in prison.” Prosecutors cited an Internet search Rodriguez conducted titled “Can you die if someone hits you in the armpit?” the day after Tyree's death.

In a San Jose courtroom on Aug. 13, the three officers voluntarily pleaded to manslaughter, which carries a maximum sentence of 11 years in prison. They will likely be eligible for parole in the next few months since they have already served time.

The source added that the confessions were submitted in the room next to the main prison, where the crime scene was also located. The three guards have been under house arrest for a month and will be officially sentenced in October.

In 2022, the Court of Appeals overturned the original second-degree murder convictions because a change in the law invalidated the legal instructions given to jurors in reaching a verdict in the original 2017 verdict. The Mercury News.

The following year, the California Supreme Court upheld the verdict, leaving prosecutors to decide whether to refile the original murder convictions, seek different convictions, reach a plea deal, or drop the case entirely.

The three men were forced to admit before Judge Benjamin Williams that they either assaulted Tyree or aided and abetted the fatal attack on the detainee. When Assistant District Attorney Matt Braker asked them to confirm that they participated in the attack and that they acted with “a conscious disregard for human life,” they responded affirmatively that they participated in the attack and acted with “a conscious disregard for human life.” The Mercury News.

The defendants' guilty plea closes the door to future appeals. District Attorney Jeff Rosen said the resolution was the result of a proposal from the defendants. Rosen said the agreement took into account that the three prison guards' time in prison would not be significantly affected. The three guards are expected to be released on parole at the end of this year.

Roses included, wrote The Mercury News, “We accepted that decision, the defendants pleaded guilty and the cases were closed. We brought some degree of finality and justice to Michael Tyree's family and our entire community. It was important to us that they say what they did, and what they did was beat this mentally ill man to death, and that it was a horrible, horrible crime.”

He added that the defendants' confessions were important to his office in ultimately closing the case.

The Mercury News said Tyree's death was an important step toward increased civilian oversight of county jails. The case inspired the creation of a civilian county oversight board for the jails. It also led to conflict over the board's access to sheriff's records and the sheriff's handling of inmate abuse cases.

The conflict culminated in a civil corruption trial before a grand jury, which ended with the retirement, resignation and official dismissal of longtime Sheriff Laurie Smith.

A year after the convictions, the state legislature passed Senate Bill 1437, which amended the law to eliminate the legal argument of “natural and probable consequences.” Previously, juries were allowed to use this theory when finding a defendant guilty of murder, regardless of whether the person directly killed anyone, but provided that the death of a victim was an uncontrollable and unavoidable consequence of the defendant's actions. The Mercury News reported.

One of the goals of SB 1437 was to reduce the number of murder convictions for people who were outwardly involved in a crime but were punished to the same extent as someone who had indisputably committed deadly violence.

Ultimately, a three-judge panel said The Mercury News, of the Fourth Circuit Court of Appeals, Third Department, overturned the officers' murder convictions after finding that, consistent with prior law, jurors had been told they could consider “natural and probable consequences” before making their decision.The Mercury News added that while the Fourth Circuit panel's ruling acknowledged that Lubrin, Farris and Rodriguez could still be convicted of murder, if that were the case, it would be based on the “implied malice” theory, which holds that the officers knew their actions could have deadly consequences but went ahead anyway.

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2015 Beating of Inmate Michael Tyree Former Santa Clara County Jailers Set to Be Released Soon Jailers Plead Guilty San Jose CA Santa Clara County Jail The Mercury News