3 Santa Clara Jail Deputies Convicted in Fatal Beating Take Plea Deal for Lighter Sentence

Updated 3:47 p.m. Tuesday

The three former correctional deputies who were charged in the fatal beating of a man incarcerated at a Santa Clara County jail in 2015 are likely to be paroled soon after taking a plea deal on Tuesday.

All three had initially been found guilty of second-degree murder, but the convictions were overturned in 2022 after a change in state law invalidated one of the legal doctrines considered at the time of the trial.

Michael Tyree, who had a mental illness and was in custody awaiting the availability of a treatment bed, was found bruised and covered with feces and vomit early on Aug. 27, 2015, inside his cell at the county’s Main Jail. The deputies, Jereh Lubrin, Matthew Farris and Rafael Rodriguez, were initially convicted in 2017 and each sentenced to 15 years to life in prison.

On Tuesday, Lubrin, Farris and Rodriguez all pleaded guilty to one count of voluntary manslaughter, agreeing to a deal to serve 11 years in state prison — including time already served — followed by three years of parole.

“Today in court, three former correctional officers … admitted to the judge and our community that they beat to death Michael Tyree,” Santa Clara County District Attorney Jeff Rosen said after the hearing. “These guards who are sworn to protect our community as well as the inmates in their care walked into a mentally ill man’s cell at night and attacked him like predators for close to five minutes.”

For at least the last month, all three have been on home detention. Officials will calculate their total credit for time served and good behavior when they return on Oct. 22 for sentencing, but Judge Benjamin William told the men that, given the years they’ve already spent in prison, “the court expects that you will be at, or just about at, credit for time served at the time of sentencing.”

Matthew Braker, the supervising deputy district attorney for the office’s homicide unit, asked each defendant if they personally assaulted or aided and abetted the assault of Tyree, causing his death — as well as if they did so with “conscious disregard for human life.” All three men answered yes.

The plea comes after almost nine years of legal proceedings related to Tyree’s killing, which led to the creation of civilian oversight in Santa Clara County and raised broader questions about the treatment of those with mental illnesses in jails there.

Attorneys for Lubrin, Farris and Rodriguez had appeals pending in 2018 when California lawmakers enacted a change to state law, SB 1437, invalidating the “natural and probable consequences” doctrine that was considered in their trial. That doctrine allows a defendant to be found guilty of murder if the person participated in a dangerous crime during which an accomplice committed murder. The legal doctrine required that the killing be a predictable outcome of the original crime, such as a violent robbery or, in this case, the alleged deadly beating of a prisoner.

Under this doctrine, a jury could convict someone of murder even if they had not directly killed the victim if that person’s murder was the natural or probable result of their actions or inactions.

The judge instructed the jury that had convicted Lubrin, Farris and Rodriguez to consider whether the death of the victim was a natural or probable result of the defendants’ actions.

In 2022, an appellate court ruled that the invalidation of the doctrine could be applied retroactively on appeal under separate state legislation, SB 775, and reversed the convictions of all three former deputies.

The appellate ruling cited arguments made by the attorney general’s office that the convictions could still be upheld under a different legal principle known as “implied malice,” in which the men could be convicted if they knew that their actions could result in death and still proceeded, but that would have required a new trial.

The California Supreme Court upheld the appellate court’s ruling, which meant the decision to bring the men to a second trial went to Santa Clara County prosecutors.

Rosen said after the hearing on Tuesday that the district attorney’s office had been preparing to retry the case based on malice murder before the defendants came forward and said they would plead guilty to voluntary manslaughter and take the maximum sentence for the charge.

“Based upon that offer from the defense, as well as their admission in court that they committed this act and they did it with conscious disregard for human life, we accepted that disposition, the defendants pled guilty and the case is concluded,” Rosen said. “We brought some finality, some measure of justice to Michael Tyree’s family as well as our entire community.”