SUPREME COURT OF SOUTH AUSTRALIA
(Magistrates Appeals: Criminal)
KOHLER v POLICE
[2013] SASC 69
Judgment of The Honourable Justice White
20 May 2013
MAGISTRATES - APPEAL AND REVIEW - SOUTH AUSTRALIA - APPEAL TO SUPREME COURT
CRIMINAL LAW - APPEAL AND NEW TRIAL - APPEAL AGAINST SENTENCE - GROUNDS FOR INTERFERENCE - SENTENCE MANIFESTLY EXCESSIVE OR INADEQUATE
TRAFFIC LAW - LICENSING OF DRIVERS - SOUTH AUSTRALIA - DISQUALIFICATION, CANCELLATION OR SUSPENSION OF LICENCES
A Magistrate imposed a single sentence of six months imprisonment for two offences of driving while disqualified and suspended the sentence upon the appellant entering into a bond to be of good behaviour - the appellant appeals against the period of imprisonment on the ground that it is manifestly excessive.
Held (allowing the appeal):
(1) Although the Magistrate stated that he had made reductions on account of the appellant's guilty pleas, he did not specify the amount of those reductions - whilst it is desirable for the amount of the reduction to be stated, the omission to do so does not amount to an error (at [16]).
(2) The Magistrate was correct to view the offending seriously, especially given its contumacious nature - however, when account is taken of the appellant's youth, background and psycho-social profile, and the proximity of the Magistrate's apparent notional sentence for the second offence to the applicable maximum, the sentence imposed is manifestly excessive (at [22], [30]).
(3) Appellant resentenced.
Motor Vehicles Act 1959 (SA) s 9, s 74, s 91, s 102; Australian Road Rules r 20, r 270, referred to.
Eldridge v Bates (1989) 51 SASR 532; O'Toole v Police [2006] SASC 206; Police v Cadd (1997) 69 SASR 150; Police v Nowak (2000) 76 SASR 551; R v Carroll (1989) 154 LSJS 359; R v Harris & Simmonds (1992) 59 SASR 300; R v KWG [2000] SASC 398; R v McGaffin [2010] SASCFC 22; R v Mills [1998] 4 VR 235; R v Place (2002) 81 SASR 395; Ryszawa v Samuels [1969] SASR 158; Wessling v Police (2004) 88 SASR 57, considered.
KOHLER v POLICE
[2013] SASC 69Magistrates Appeal
WHITE J. A Magistrate imposed a single sentence of imprisonment for six months on the appellant for two offences of driving while disqualified, contrary to s 91(5) of the Motor Vehicles Act 1959 (SA) (MVA). The Magistrate then suspended that sentence upon the appellant entering into a bond to be of good behaviour for a period of two years and to comply with other conditions.
The appellant contends that the sentence of six months is manifestly excessive.
Background
The appellant was born in May 1993. He was just 19 years old at the time of his two offences.
On 23 August 2011, the appellant had been sentenced in the Youth Court for the offences of exceeding the speed limit[1] and driving while unauthorised,[2] committed on 4 August 2010. The latter offence was his second offence of driving while unauthorised.…
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- AGLC
- KOHLER v Police [2013] SASC 69
- Case
- [2013] SASC 69
- Decision Date
CaseChat Overview and Summary
The court held that while it is desirable for the amount of the reductions to be stated, the omission to do so does not amount to an error. However, the court found that the sentence imposed was manifestly excessive, considering the appellant's youth, background, and psycho-social profile, as well as the proximity of the Magistrate's apparent notional sentence for the second offence to the applicable maximum. The court allowed the appeal and ordered the appellant to be resentenced.
Orders
Orders of the court
Held (allowing the appeal):
(1) Although the Magistrate stated that he had made reductions on account of the appellant's guilty pleas, he did not specify the amount of those reductions - whilst it is desirable for the amount of the reduction to be stated, the omission to do so does not amount to an error (at [16]).
(2) The Magistrate was correct to view the offending seriously, especially given its contumacious nature - however, when account is taken of the appellant's youth, background and psycho-social profile, and the proximity of the Magistrate's apparent notional sentence for the second offence to the applicable maximum, the sentence imposed is manifestly excessive (at [22], [30]).
(3) Appellant resentenced.
Background
Background to the litigation
Evidence
Evidence Before The Court
Full text does not contain this section.
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Established by: WHITE J
Counsel for the appellant provided the Magistrate with a copy of a report from Mr Balfour, a psychologist. I will refer to this report later. The Magistrate said:Mr Balfour endeavours to give an insight into your behaviour and your circumstances. He adduces compelling reasons why the Court ought to look favourably upon you in determining how to best deal with this offending rather than to simply lock you up.In saying this, it is really up to you to determine how you conduct yourself and whether or not you stay out of trouble. No one is better placed to oversee your behaviour than yourself and, obviously, if you continue down this path, you are eventually going to see what the inside of a prison looks like. You shouldn’t need me to tell you that it is not the place for a young 20 year old to be....I take into account your plea of guilty and the matters your counsel has put on your behalf together with the report of Mr Balfour and the matters set out in ss 10 and 11 of the CLSA. I have considered s 11 and had regard to the prevailing case law on drive disqualified offending and, noting that the offending occurred in circumstances of contumacy, find that a period of imprisonment is appropriate. Allowing for the discounts for the guilty pleas and, taking both offences occurring on separate occasions into account in fixing an appropriate term, I fix six months as the term.Consideration Although the Magistrate said that in fixing the single sentence of imprisonment for six months, he had made reductions for the appellant’s guilty pleas he did not identify the amount of those reductions. It is desirable for the amount of the reductions to be stated.[8] However, the Magistrate’s omission to state the amount of the reductions is not of itself a ground for interference with the sentence.[9][8] R v Harris & Simmonds (1992) 59 SASR 300 at 302; R v Place [2002] SASC 101 at [81]-[83], (2002) 81 SASR 395 at 425.[9] R v Place [2002] SASC 101 at [80], (2002) 81 SASR 395 at 425; Wessling v Police [2004] SASC 51 at [20]; (2004) 88 SASR 57 at 61. It seems reasonable to suppose that the Magistrate allowed a reduction of 20-25 per cent. If he allowed a reduction of 25 per cent, then his starting point for the single sentence would have been imprisonment for eight months. It is a matter of conjecture as to how the Magistrate may have reached a starting point of that order. However, given that he treated the two offences as separate offending, it is likely to reflect the aggregate of two notional sentences. Further, the Magistrate regarded the offence committed on 20 July 2012 as more serious than that committed on 21 May 2012. The notional sentence for the second is therefore likely to have been higher than that for the first. This suggests that more than four months of a notional starting point of about eight months should be attributed to the second offence. As I have said, there must inevitably be some speculation about the manner in which the Magistrate reached the sentence of six months. The analysis just outlined indicates, however, that the notional starting point for the sentence for the second offence was probably a relatively high proportion of the maximum of six months applicable to that offence.