SUPREME COURT OF SOUTH AUSTRALIA
(Court of Criminal Appeal)
R v KOHLHAGEN
[2016] SASCFC 19
Judgment of The Court of Criminal Appeal
(The Honourable Justice Peek, The Honourable Justice Blue and The Honourable Justice Nicholson)
2 March 2016
CRIMINAL LAW - PARTICULAR OFFENCES - OFFENCES AGAINST THE PERSON - SEXUAL OFFENCES - INDECENT ASSAULT AND RELATED OFFENCES - GENERALLY
CRIMINAL LAW - PARTICULAR OFFENCES - OFFENCES AGAINST THE PERSON - SEXUAL OFFENCES - UNLAWFUL SEXUAL INTERCOURSE OR CARNAL KNOWLEDGE - GENERALLY
CRIMINAL LAW - APPEAL AND NEW TRIAL - APPEAL AGAINST SENTENCE - GROUNDS FOR INTERFERENCE - SENTENCE MANIFESTLY EXCESSIVE OR INADEQUATE
Appeal against sentence. The appellant was charged with the offences of aggravated making a child amenable to a sexual activity, aggravated indecent assault and unlawful sexual intercourse with a person under 14 years. He pleaded guilty to the offences in the District Court and, as such, was subject to a 20 per cent discount pursuant to section 10C of the Criminal Law (Sentencing) Act 1988 (SA). The Judge sentenced the appellant to a term of imprisonment of four years, eight months and 24 days, reduced from a head sentence of six years, with a non-parole period of two years, five months and 24 days, allowing credit of six days for time the appellant had spent in custody.
The appellant appealed against the sentence imposed by the Judge on a number of grounds. The first three grounds of appeal assert errors involving the appellant’s prospects of rehabilitation, the appellant’s remorse and insight into the offending, and the effect an immediate custodial sentence would have on the appellant’s treatment and rehabilitation. The final two grounds of appeal assert that the head sentence and non-parole period are manifestly excessive and the Judge erred in not suspending the sentence of imprisonment.
Held by Nicholson J (Peek J agreeing), allowing the appeal:
1. In all of the circumstances, the head sentence imposed by the Judge was manifestly excessive. It is unnecessary to consider the remainder of the appellant’s grounds of appeal (at [49], [73]-[74]).
2. The sentence of the District Court is set aside. The appellant is resentenced to a head sentence of four years and nine months imprisonment, reduced to three years and ten months imprisonment, with a non-parole period of 23 months. The head sentence and non-parole period are backdated to commence on 21 July 2015 (at [75]).
3. The seriousness of the offending and the need for general deterrence are such as to exclude good reason to suspend the sentence (at [76]).
Held per Blue J (dissenting):
1. The Judge did not err in his assessment concerning prospects of rehabilitation (at [18]).
2. The Judge did not err in his assessment concerning remorse (at [24]).
3. The Judge did not err concerning the effect of an immediate custodial sentence on the appellant’s treatment and rehabilitation (at [28]).
4. The head sentence imposed was not manifestly excessive (at [40]).
5. The Judge did not err in the exercise of his discretion…
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- AGLC
- R v Kohlhagen [2016] SASCFC 19
- Case
- [2016] SASCFC 19
- Decision Date
CaseChat Overview and Summary
The appeal raised several grounds, including that the sentencing judge erred in finding no satisfactory explanation for the offending, in failing to adequately consider the adverse impact of immediate custody on the appellant's rehabilitation, in misjudging the appellant's appreciation of the impact on the victim and his remorse, and that the head sentence and non-parole period were manifestly excessive. A further ground argued that the sentencing judge erred in declining to suspend the sentence. The central legal issue was whether the sentencing judge had erred in the exercise of their discretion in imposing the sentence, particularly in relation to the weight given to psychological evidence and the appellant's prospects of rehabilitation, and whether the sentence was demonstrably excessive or inappropriate.
The Full Court considered the psychological reports, which indicated the appellant had a history of childhood sexual abuse and struggled with trust, and that his intoxication was a significant disinhibitor. However, the court noted that the sentencing judge was troubled by the lack of a clear explanation for the offending, even with the psychological input. The judge found that the appellant should not have needed explicit signals of discomfort from the victim to cease his actions. The court ultimately found that the sentencing judge had not erred in concluding that there was no good reason to suspend the sentence and that the sentence imposed was not manifestly excessive.
The appeal was dismissed, with permission to appeal refused on the ground concerning the suspension of the sentence.
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