R v Max Perry Manus Prior
[2023] EWCA Crim 1651
Daniel Wills v R
10 July 2024
[2024] EWCA Crim 789
Court of Appeal
Daniel Wills was found guilty of assaulting a police officer. He tried to appeal, arguing he acted in self-defence and citing other problems in his life. The court rejected his appeal because the evidence showed he did not act in self-defence, and his other problems weren't a valid excuse for the assault.
Key Facts
- •Daniel Wills was convicted of assaulting an emergency worker (CSI Smith) on 17 March 2022.
- •The assault occurred on 20 January 2021 outside Street Police Station, Somerset.
- •Wills was unrepresented at trial and sentencing.
- •Wills claimed self-defence.
- •The prosecution's case relied on body-worn footage and CSI Smith's testimony.
- •Wills sought to introduce evidence from other witnesses and proceedings related to his housing, employment, and other disputes.
- •Wills applied to renew his appeal against conviction, extend the time for appeal, and admit further evidence.
Legal Principles
Self-defence: A person is entitled to use reasonable force to defend themselves from an attack or threat of attack. A grievance or feeling provoked is insufficient.
Judge's direction to the jury
Extension of time for appeal: Inadequate reasons for delay, such as prioritizing civil disputes, will not justify an extension of time.
Court of Appeal's decision
Fresh evidence: Further evidence must be relevant to the defence and have a reasonable prospect of changing the outcome.
Court of Appeal's implicit reasoning
Outcomes
Application to renew appeal against conviction dismissed.
The conviction was deemed safe. The grounds of appeal were weak, and no new evidence was found to be relevant or likely to change the outcome.
Application to extend time for appeal dismissed.
The delay was significant, and the reasons provided were insufficient. Even if the appeal were heard in time, it would have been dismissed.
Application to admit further evidence dismissed.
The proposed evidence was not relevant to the defence of self-defence and would not likely change the outcome.