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Former California Jail Guards Plead Guilty to Fatal Beating of Mentally Ill Detainee

Three former Santa Clara County Jail guards pleaded guilty to voluntary manslaughter on August 13, 2024, for fatally beating a mentally ill detainee nearly nine years earlier. In their plea deal, Jereh Lubrin, 37, Matt Farris, 36, and Rafael Rodriguez, 35, agreed to serve a maximum of 11 years in prison for killing detainee Michael Tyree, 31, on August 15, 2015.

As PLN reported, the guards blamed an accidental fall for Tyree’s extensive injuries. A jury didn’t buy that, though, and convicted them of second-degree murder. They were sentenced to serve 15 years to life in prison in 2018, but the state Court of Appeal tossed that conviction four years later; another year on, the state Supreme Court remanded the case for reconsideration. [See: PLN, Sep. 2023, p.55.]

Both decisions retroactively applied a 2018 law, SB 1437, which amended the state’s felony murder statute to bar a murder conviction for anyone who did not directly participate in a killing. The Court of Appeal reconsidered the case but arrived at the same conclusion on February 7, 2024, sending the three for retrial “on a valid theory or theories of homicide.” They turned once again to the state Supreme Court, but it denied review on April 24, 2024. See: People v. Lubrin, 2024 Cal. App. Unpub. LEXIS 793; and2024 Cal. LEXIS 2186.

In their subsequent plea deal, District Attorney Jeff Rosen laid down a condition. “It was important for us to have them admit in court that they beat Michael Tyree to death,” Rosen said. The actual amount of time they serve in prison will be determined on October 22, 2024, but Rosen expected all three would be paroled by year-end. See: People v. Lubrin, Cal. Super. (Cty. of Santa Clara), Case No. C-15-19377.

Tyree’s family collected a $3.6 million settlement in 2016 in their suit filed over his death, as PLN also reported. [See: PLN, Jan. 2018, p.26.] “Mental illness is not a criminal justice problem, it is a public health problem,” said their attorney, Paula Canny, after the plea deal was announced. “And until we reconcile that and recognize it as such, we’re going to continue to have tragedies like this.”  

Additional sources: KGO, Mercury News

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