In 2017, a juvenile court in Massachusetts ruled that repeatedly encouraging someone to complete suicide was not protected by the First Amendment,[7] and found a 20-year-old woman, who was 17 at the time, guilty of manslaughter on this basis.[8] The judge cited a little-known 1816 precedent.[9] The woman is expected to file an appeal.[8] On February 6, 2019, the Massachusetts Supreme Judicial Court ruled that the defendant acted with criminal intent, so her involuntary manslaughter conviction was ordered to stand.[10] The Supreme Court declined to hear the case in January 2020, leaving in place the Massachusetts Supreme Court conviction.[11]