Three former Santa Clara County correctional deputies pleaded guilty Aug. 13 to reduced charges in the 2015 beating death of Michael Tyree, a mentally ill jail inmate.
All three defendants – Matthew Farris, 36, Jereh Lubrin, 37 and Rafael Rodriguez, 40 – admitted to voluntary manslaughter, seven years after being convicted of second-degree murder and two years after those convictions were overturned by an appellate court.
After the appellate reversal, the defendants had been returned to Santa Clara County to face retrial. All three were released from custody and placed on home detention pending retrial.
The guilty pleas—coupled with an agreement to be sentenced to a maximum of 11 years in prison—came as District Attorney Jeff Rosen was preparing to retry the case.
“Today, there was some justice for the voiceless and the vulnerable,” Rosen said in a statement accepting the pleas. “Michael Tyree’s death was a shocking abuse of power but also an impetus that led to long-needed reforms in how we handle the mentally ill in custody. I pray that his name will continue to inspire us to advocate for a criminal justice system that never treats human dignity as a luxury.”
Michael Tyree was a 31-year-old mentally ill inmate housed in the Santa Clara County main jail for outstanding warrants and misdemeanor offenses. He was being held in custody until bedspace became available at an appropriate mental health facility.
On Aug. 26, 2015, the on-duty guards entered Tyree’s small cell armed with batons. In a press release, Rosen described the violent and gruesome nature of the crime:
“One or more of the trio beat Tyree to death. Fellow inmates heard screams of pain, crying, and pleas for mercy. Within an hour, Tyree lay dead in his cell in a pool of vomit and feces. He had lost up to half of his blood through massive internal bleeding. Tyree’s liver was severely lacerated, and his spleen was nearly torn in half.”
The forensic pathologist who performed the autopsy determined that death was caused by “‘‘multiple blunt force injuries’ that included ‘a catastrophic abdominal injury from either being crushed or a blow to the abdomen.’”
Prosecutors said their investigation revealed that the defendants had a pattern of abuse and violence toward inmates as part of a scheme to instill fear and maintain control in the jail. Inmates described prior acts of violence at the hands of the defendants, which were corroborated by text messages from defendants Farris and Rodriguez boasting of violent treatment of jail inmates.
A former acquaintance of Lubrin testified at the original trial that the guard had told him, “Beating people up is part of my job at the jail.”
In 2017, a jury convicted all three defendants of second-degree murder. The defendants challenged their murder convictions on appeal based on new legislation in 2018 that was retroactive and significantly changed the requirements to convict a person of murder when the identity of the actual killer could not be proven.
Based on this new law, an appellate court reversed the conviction.
Rosen said in a press release that Michael Tyree’s sister, Shannon Tyree, and the family’s attorney, Paula Canny, support the result announced today “to avoid the emotional toll and significant risk of a retrial.”
“Today’s guilty pleas validate the jury verdict within the confines of the changes in the law and confirms our unwavering commitment to holding law enforcement accountable in the rare instances when its members violate their oath and the law,” Rosen said in the press release.
Following the death of Michael Tyree, federal monitors were brought in to investigate Santa Clara County’s jail operations.
In addition, the Board of Supervisors convened a Blue-Ribbon Commission on Improving Custody Operations. The Office of Corrections and Law Enforcement Monitoring (OCLEM) was established to provide independent monitoring of the County’s corrections and law enforcement functions.
Reforms adopted include increased training in crisis intervention, training on interacting with mentally ill inmates, body worn cameras, and a revised inmate complaint reporting system.
Coupled with the sheriff’s office handling of subsequent jail inmate mistreatment cases, Tyree’s death also led to a civil grand jury corruption trial that prompted the retirement, resignation and formal expulsion of previous longtime sheriff Laurie Smith.
