SUPREME COURT OF SOUTH AUSTRALIA
(Court of Appeal: Criminal)
NGUYEN v THE QUEEN
[2022] SASCA 23
Judgment of the Court of Appeal
(The Honourable President Livesey, the Honourable Justice Lovell and the Honourable Justice Bleby)
24 March 2022
CRIMINAL LAW - APPEAL AND NEW TRIAL - APPEAL AGAINST SENTENCE
CRIMINAL LAW - PARTICULAR OFFENCES - DRUG OFFENCES - DEALING AND DISTRIBUTION OF DRUGS - TRAFFICKING OR SALE AND SUPPLY
CRIMINAL LAW - PARTICULAR OFFENCES - DRUG OFFENCES - POSSESSION - OF EQUIPMENT AND IMPLEMENTS
CRIMINAL LAW - SENTENCE - INTERPRETATION OF SENTENCING PROVISIONS
Appeal against sentence.
The appellant pleaded guilty to one count of trafficking in a large commercial quantity of a controlled drug, two counts of possessing a controlled drug, and one count of possessing prescribed equipment, contrary to ss 32(1), 33L and 33LA of the Controlled Substances Act 1984 (SA) respectively.
The sentencing judge fixed a starting point of four years’ imprisonment for the first count. He reduced that by 20 per cent on account of the appellant’s guilty plea, resulting in a sentence of three years, two months and 13 days. He imposed a single sentence of five months for the remaining counts. He reduced that by 30 per cent on account of the appellant’s guilty plea, resulting in a sentence of three months and 16 days.
The judge ordered the two sentences to be served wholly concurrently. After taking into account time spent in prison, this resulted in a head sentence of three years, two months and five days. He set a non-parole period of two years, six months and 17 days. This was four-fifths of the head sentence, the appellant being a serious repeat offender.
The appellant was diagnosed as both illiterate and innumerate. He was placed in the ‘Intellectual Disability’ (i.e. IQ>70) range of ‘intelligence’, and fell within 0.01 percentile of the age equivalent of population. In the opinion of his psychologist, the appellant represented one of the most extreme cases of poor cognitive ability that he had ever assessed. The appellant was also diagnosed with multiple mental health disorders, including PTSD, and a mixed personality disorder.
The issues on appeal are whether:
•the sentencing judge erred in applying the sentencing principles relevant to the appellant’s intellectual disability and mental impairment (Grounds 1 and 2);
•the sentencing judge erred in applying s 54(2) of the Sentencing Act 2017 (SA) (Ground 3); and
• the sentence imposed is manifestly excessive (Ground 4).
Held, per Bleby JA (Livesey P and Lovell JA agreeing), granting permission to appeal and allowing the appeal:
1.The judge did not appear to grapple with how the appellant’s intellectual disability and mental impairments may affect personal and general deterrence, or how the sentence might weigh more heavily on the appellant when compared with a person without his mental impairments. It cannot be inferred safely that the sentencing judge gave effect to the principles applicable on sentencing an offender with an intellectual disability or mental illness.
2.In describing the appellant’s personal circumstances as…
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- [2022] SASCA 23
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CaseChat Overview and Summary
The legal issues before the Court of Appeal were whether the sentencing judge erred in applying the principles relevant to the appellant's intellectual disability and mental impairment, whether the judge erred in applying section 54(2) of the Sentencing Act 2017 (SA), and whether the imposed sentence was manifestly excessive. The appellant's intellectual disability was described as being in the 'Intellectual Disability' range with an IQ above 70, placing him in the 0.01 percentile for age-equivalent cognitive ability, and his psychologist considered him one of the most extreme cases of poor cognitive ability assessed.
The Court of Appeal, per Bleby JA, found that the sentencing judge had not adequately grappled with how the appellant's intellectual disability and mental impairments might affect the principles of personal and general deterrence, nor how the sentence might weigh more heavily on him compared to an offender without such impairments. The Court also determined that the sentencing judge had erroneously foreclosed an inquiry into whether the appellant's exceptional personal circumstances, as identified by his psychologist, met the statutory description in s 54(2) by describing them as 'regularly, routinely or commonly encountered by the courts'. Consequently, the appeal was allowed, and the appellant was resentenced to a head sentence of two years, four months and 16 days, with a non-parole period of one year and six months, backdated to commence on 23 November 2020.
Orders
Orders of the court
Appeal against sentence.
The appellant pleaded guilty to one count of trafficking in a large commercial quantity of a controlled drug, two counts of possessing a controlled drug, and one count of possessing prescribed equipment, contrary to ss 32(1), 33L and 33LA of the Controlled Substances Act 1984 (SA) respectively.
The sentencing judge fixed a starting point of four years’ imprisonment for the first count. He reduced that by 20 per cent on account of the appellant’s guilty plea, resulting in a sentence of three years, two months and 13 days. He imposed a single sentence of five months for the remaining counts. He reduced that by 30 per cent on account of the appellant’s guilty plea, resulting in a sentence of three months and 16 days.
The judge ordered the two sentences to be served wholly concurrently. After taking into account time spent in prison, this resulted in a head sentence of three years, two months and five days. He set a non-parole period of two years, six months and 17 days. This was four-fifths of the head sentence, the appellant being a serious repeat offender.
The appellant was diagnosed as both illiterate and innumerate. He was placed in the ‘Intellectual Disability’ (i.e. IQ>70) range of ‘intelligence’, and fell within 0.01 percentile of the age equivalent of population. In the opinion of his psychologist, the appellant represented one of the most extreme cases of poor cognitive ability that he had ever assessed. The appellant was also diagnosed with multiple mental health disorders, including PTSD, and a mixed personality disorder.
The issues on appeal are whether:
• the sentencing judge erred in applying the sentencing principles relevant to the appellant’s intellectual disability and mental impairment (Grounds 1 and 2);
• the sentencing judge erred in applying s 54(2) of the Sentencing Act 2017 (SA) (Ground 3); and
• the sentence imposed is manifestly excessive (Ground 4).
Held, per Bleby JA (Livesey P and Lovell JA agreeing), granting permission to appeal and allowing the appeal:
1. The judge did not appear to grapple with how the appellant’s intellectual disability and mental impairments may affect personal and general deterrence, or how the sentence might weigh more heavily on the appellant when compared with a person without his mental impairments. It cannot be inferred safely that the sentencing judge gave effect to the principles applicable on sentencing an offender with an intellectual disability or mental illness.
2. In describing the appellant’s personal circumstances as ‘regularly, routinely or commonly encountered by the courts’, the judge erroneously foreclosed an inquiry into whether the appellant’s personal circumstances, which were identified by his psychologist as exceptional, were so exceptional as to meet the statutory description in s 54(2).
3. The appellant is resentenced to a head sentence of two years, four months and 16 days, with a non-parole period of one year and six months.
Background
Background to the litigation
Evidence
Evidence Before The Court
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Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
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