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Criminal law Tom Spohr Criminal law Tom Spohr

Xue v R [2021] NSWCCA 270

In this decision the Court of Criminal Appeal (‘CCA’) has held that when prosecuting an offence of dealing with property that there are reasonable grounds to suspect are proceeds of crime, the Crown can rely upon a non-specific ‘serious offence’ as the source of the proceeds. This is to be contraste

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Criminal law Tom Spohr Criminal law Tom Spohr

Ah Keni v R [2021] NSWCCA 263

In this decision the CCA has found that in order to be guilty of being an accessory after the fact, an offender has to take active steps to assist the principal offenders. It will not be enough to simply fail to report the offence to the police – although silence might sometimes be relevant to objec

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Sentencing Tom Spohr Sentencing Tom Spohr

Nasrallah v R [2021] NSWCCA 207

This decision of the CCA exposes a potential problem in trying to apply the principles from Bugmy v The Queen (2013) 249 CLR 571 (‘Bugmy’) to cases where there may not have been a lengthy history of trauma, but rather only one or two traumatic episodes, and perhaps against a background of less depri

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Appeals Tom Spohr Appeals Tom Spohr

Lunney v Director of Public Prosecutions [2021] NSWCA 186

In this decision, the Court of Appeal has held that in a District Court appeal against conviction, the issues to be considered by the judge are those raised by the parties. If the appellant does not raise for consideration a point that requires a review of the whole of the evidence, then a judge wil

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Sentencing Tom Spohr Sentencing Tom Spohr

Meoli v R [2021] NSWCCA 213

In this decision the Court of Criminal Appeal (‘CCA’) has held that whilst prospects of rehabilitation, and unlikelihood of reoffending are separate and distinct factors, the burden of establishing the latter falls on the offender – and in any event the two issues will often be co-extensive.

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Sentencing Tom Spohr Sentencing Tom Spohr

Ke v R [2021] NSWCCA 177

In this case the Court of Criminal Appeal (‘CCA’) has held that when considering the Early Appropriate Guilty Plea sentencing discounts, if it happens to be the case that the parties failed to record in the Case Conferencing Certificate an offer which was formally made in writing by a defendant, the

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Sentencing Tom Spohr Sentencing Tom Spohr

Naberezhnov v R [2021] NSWCCA 142

You might think drugs and music festivals seem to go hand-in-glove; a fact which was as true at Woodstock as it is today. In this decision, however, the CCA has used the occasion to observe that just because it might be notorious that drugs are consumed and distributed at music festivals, that gener

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Local Court Tom Spohr Local Court Tom Spohr

Huynh v R [2021] NSWCCA 148

The Court of Criminal Appeal (‘CCA’) has held that, in appeals to the District Court, if the original sentence included a conviction and the appellant a mental health diversion, they need to lodge a conviction appeal, not just a sentence appeal – under both Commonwealth and State regimes. A convicti

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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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