[2016] TASCCA 17
COURT: SUPREME COURT OF TASMANIA (COURT OF CRIMINAL APPEAL)
CITATION: Donohue v Tasmania [2016] TASCCA 17
PARTIES: DONOHUE, Darryl Scott
v
STATE OF TASMANIA
FILE NO: CCA 142/2015
DELIVERED ON: 5 October 2016
DELIVERED AT: Hobart
HEARING DATE: 29 September 2016
JUDGMENT OF: Blow CJ, Estcourt and Brett JJ
CATCHWORDS:
Criminal Law – Evidence – Propensity, tendency and coincidence – Admissibility and relevancy – Tendency and coincidence evidence under uniform evidence law – Other cases – Inciting to commit murder – Tendency of appellant to offer men he did not know money in return for killing his estranged wife for reasons related to access to his children.
Evidence Act 2001 (Tas), ss 97(1), 101(2).
IMM v The Queen [2016] HCA 14, 98 ALJR 529; R v Matonwal [2016] NSWCCA 174, referred to.
Aust Dig Criminal Law [2782]
REPRESENTATION:
Counsel:
Appellant: E G Hughes
Respondent: L Mason
Solicitors:
Appellant: Rae & Partners
Respondent: Director of Public Prosecutions
Judgment Number: [2016] TASCCA 17
Number of paragraphs: 42
Serial No 17/2016
File No CCA 142/2015
DARRYL SCOTT DONOHUE v STATE OF TASMANIA
REASONS FOR JUDGMENT COURT OF CRIMINAL APPEAL
BLOW CJ
ESTCOURT J
BRETT J
5 October 2016
Order of the Court (29 September 2016)
Appeal dismissed.
Serial No 17/2016
File No CCA 142/2015
DARRYL SCOTT DONOHUE v STATE OF TASMANIA
REASONS FOR JUDGMENT COURT OF CRIMINAL APPEAL
BLOW CJ
5 October 2016
On 2 December 2014 the appellant, Darryl Scott Donohue, was found guilty by a jury of two charges of inciting to commit murder, contrary to s 298 of the Criminal Code. He appealed against his convictions, contending that the learned trial judge, Pearce J, erred in a ruling as to the admissibility of tendency evidence, and in refusing to order separate trials of the two charges. On 29 September 2016 this Court heard the appeal and dismissed it, deferring the publication of the reasons for dismissing it. The Court is now publishing those reasons.
I have read the reasons of Estcourt J in draft form. They accord with my reasons for dismissing the appeal. There is nothing that I wish to add.
File No 142/2015
DARRYL SCOTT DONOHUE v STATE OF TASMANIA
REASONS FOR JUDGMENT COURT OF CRIMINAL APPEAL
ESTCOURT J
5 October 2016
The appeal
On 2 December 2014 the appellant, Darryl Scott Donohue, was found guilty by a jury of two charges of inciting to commit murder contrary to s 298 of the Criminal Code.
He was sentenced by Pearce J to seven years' imprisonment with a non-parole period of four years.
The appellant has appealed to this Court against his conviction on the grounds that the learned trial judge erred in refusing the appellant's application to sever the two counts on the indictment, and in admitting as tendency evidence, cross-admissible on both counts, the evidence of approaches by the appellant to witnesses Adrian Hayes and Mark Lopes, and to witnesses Scott…
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CaseChat Overview and Summary
The legal issues before the court were whether the evidence of the appellant's prior conduct towards Mr Hayes, Mr Etchell, and Mr Saxelby constituted admissible tendency evidence under the Uniform Evidence Law. Specifically, the court had to determine if this evidence possessed significant probative value and if its probative value substantially outweighed any prejudicial effect, as required by sections 97(1)(b) and 101(2) of the Evidence Act. The court also considered the cross-admissibility of evidence relating to the alleged approaches to Mr Etchell and Mr Saxelby.
The court reasoned that tendency evidence is admissible if it can rationally affect the assessment of the probability of a fact in issue and has significant probative value. The court noted that when assessing probative value for the purposes of admissibility, the reliability and credibility of the evidence are generally not considered, and it must be assumed that the evidence will be accepted. The court found that the conduct on each occasion relied upon by the Crown was highly similar: the appellant approached individuals he did not know, offered money to kill his estranged wife, and did so for reasons related to gaining custody of his children. This similarity, the court held, gave the evidence significant probative value, supporting an inference that the appellant acted with a similar intention on each occasion. The court also considered that the evidence was necessary to exclude the possibility that the appellant was merely boasting.
The appeal was dismissed.
Orders
Orders of the court
Appeal dismissed.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
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Ratio Decidendi
Legal Principle Established
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