The Supreme Court ruled on Thursday, Mar. 1, that Carr could not have foreseen that the attack could cause the victim’s death, which was found to have been caused by a rare combination of heart and lung defects.
“No reasonable factfinder could conclude that (Carr’s) attack—which inflicted only minor physical injuries—posed a risk of death so great that Tracy was grossly deviant for not recognizing it,” the Supreme Court opinion reads, according to the news service.
The court said that the standard for the more serious charge was that Carr would have to have both acted with “criminal negligence” and have “caused” the death. According to the court, this was not the case, leading to the conviction’s reversal.
The criminal conspiracy conviction still stands.
“(The attack)—reprehensible as it was—was not so violent that it presented a readily apparent risk of death,” the opinion states.
“Department of Justice prosecutors are disappointed but respect the court’s decision,” said Carl Kanefsky, an agency spokesman.
Prosecutors accused Carr and two other women–Zion Snow and Chakiera Wright–of planning the confrontation in the 20 hours before the attack.
Snow was found guilty of third-degree conspiracy, but Wright was not, owing to insufficient evidence.
Crucial to the prosecution’s case was cellphone video of the assault. It shows Carr dragging Joyner-Francis by her hair through a bathroom stall. Carr could be seen landing punches to the head and torso of Joyner-Francis, and kicking her while she lay on the floor.
The ruling also means Carr will be resentenced based on the conspiracy charge.
In June, 2017, Carr was sentenced to six months at Grace Cottage—a secure residential program for female youth near Wilmington.
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