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Practice and procedure Tom Spohr Practice and procedure Tom Spohr

VP v R [2021] NSWCCA 11

In this decision the Court of Criminal Appeal (‘CCA’) has held that if a defendant remains silent until the end of a trial about the prosecutor’s failure to call witnesses, they risk the appearance that it was a forensic decision – and that may impact on whether the failure will amount to a miscarri

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Sentencing Tom Spohr Sentencing Tom Spohr

Mandranis v R [2021] NSWCCA 97

In this decision, the Court of Criminal Appeal (‘CCA’) has endorsed a practice of reducing, rather than backdating, sentences of imprisonment when there is pre-sentence custody and an Intensive Correction Order (‘ICO’) is ultimately imposed.

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Criminal law Tom Spohr Criminal law Tom Spohr

Attorney-General’s Application pursuant to s 108 Crimes (Appeal and Review) Act 2001 (NSW): Re Robert Burton (a pseudonym) [2021] NSWCCA 87

AUTHOR’S NOTE: There is a really serious question here about what the statutory publication restriction means. The publication restriction in s 108(6) is called out twice by Simpson AJA in the decision (at [5]-[6] and again at [86]), but the judgment offers no advice as to what it really means.

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Sentencing Tom Spohr Sentencing Tom Spohr

R v SS [2021] NSWCCA 56

In this (pair of) decision(s), the Court of Criminal Appeal has held that the so-called Ellis-discount has to an extent been overtaken by legislation – although case law does establish generally-accepted categories of assistance. Merely pleading guilty and confessing to the offence is unlikely to be

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Sentencing Tom Spohr Sentencing Tom Spohr

Wany v DPP [2020] NSWCA 318

This decision adds another chapter to each of two ongoing areas of controversy: the exact nature of District Court appeals, and the content of the test when considering an Intensive Correction Order (‘ICO’). Here the Court of Appeal has determined that it is an error, when considering a sentence app

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Sentencing Tom Spohr Sentencing Tom Spohr

Hamilton v DPP [2020] NSWSC 1745

This decision of a single judge of the Supreme Court deals with the scenario where a defendant agrees that they have committed the offence charged, but disagrees about the particulars of the allegation. It determines that the question of whether the defendant should be committed for sentence (with a

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Sentencing Tom Spohr Sentencing Tom Spohr

Ilic v R [2020] NSWCCA 300

The Court of Criminal Appeal (‘CCA’) (McCallum JA, Wright J agreeing; Garling J also agreeing, though for slightly different reasons) has held that Commonwealth matters are not capable of being placed on a Form 1 (as distinct from a schedule pursuant to Crimes Act 1914 (Cth) s16BA).

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Sentencing Tom Spohr Sentencing Tom Spohr

Eakin v R [2020] NSWCCA 294

In this decision the CCA has held that where a sentencing judge sets up a parity relationship between offenders, and a co-offender subsequently gets their sentence reduced, then that might give rise to a justifiable sense of grievance – even if you already had a lower sentence – allowing an appeal t

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Evidence Tom Spohr Evidence Tom Spohr

R v Riley [2020] NSWCCA 283

In this decision the Court of Criminal Appeal (‘CCA’) has considered a case where illegally-obtained evidence was rejected by a trial judge. In making the determination, they held that the probative value of the evidence must be taken at its highest, excluding (in all but the most extreme circumstan

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Sentencing Tom Spohr Sentencing Tom Spohr

Jackson v R [2020] NSWCCA 230

In this decision the Court of Criminal Appeal (‘CCA’) has pointed out that although advanced age can be relevant in many ways, it does not follow that elderly offenders are necessarily entitled to a lower sentence.

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Sexual offences Tom Spohr Sexual offences Tom Spohr

Saffin v R [2020] NSWCCA 246

Despite being a sentence appeal, this decision sheds some light on how the law of consent works in the context of sex offences. After reiterating that a sentencing judge is not obliged to accept the defence version on sentence just because they do not accept the prosecution version, the Court went o

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Mental health Tom Spohr Mental health Tom Spohr

R v Stonestreet [2020] NSWCCA 212

The last several years have seen an increase in the focus on reduced ‘moral culpability’ as a result of mental illness as a mitigating factor on sentence. However, in this appeal, the CCA has reminded us that in some cases there is a flip side: sometimes, mental illness will indicate an increased ne

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Evidence Tom Spohr Evidence Tom Spohr

SB v R [2020] NSWCCA 207

In this decision the Court of Criminal Appeal (‘CCA’) has held that evidence of complaint is not ‘independent’ of the complainant. To the extent that the Criminal Trials Bench Book had a recommended direction to that effect, it was wrong.

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