Caselaw Digest
Caselaw Digest

Christopher Donaldson v R

[2024] EWCA Crim 55
A man was sentenced to life in prison with a minimum of 24 years for killing someone in a fight. He appealed, saying the sentence was too long, but the Court of Appeal disagreed. They said the sentence was fair given the seriousness of the crime and his long criminal record.

Key Facts

  • Christopher Donaldson convicted of murder, section 18 wounding with intent, and assault occasioning actual bodily harm.
  • Offences arose from a series of fights stemming from a dispute over stolen goods.
  • Donaldson stabbed Anthony Steel three times, causing his death.
  • Donaldson had 44 previous convictions for 109 offences, including five offences against the person.
  • The judge rejected self-defence, finding Steel unarmed and no threat.
  • Judge imposed a life sentence with a minimum term of 24 years less time served.

Legal Principles

Sentencing principles under Schedule 21 to the Sentencing Act 2020

Sentencing Act 2020

Totality in sentencing

Case law (implied)

Self-defence

Case law (implied)

Outcomes

Application for permission to appeal against sentence refused.

Court of Appeal agreed with the single judge that the grounds of appeal were not arguable. The sentence, including the starting point and the consideration of totality, was deemed appropriate given the severity of the offences, Donaldson's extensive criminal history, and the lack of compelling mitigating factors.

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