R v Joe Robert Slack
[2023] EWCA Crim 522
David Dixon v R
17 March 2023
[2023] EWCA Crim 280
Court of Appeal
A man stabbed his friend badly. He had a long history of violence, so the judge gave him a life sentence. The appeal court agreed because of how serious the stabbing was and his past crimes.
Key Facts
- •The appellant, David Dixon, was convicted of wounding with intent after stabbing his friend, Marie Hughes, multiple times following an argument.
- •The attack involved the use of two knives and resulted in serious injuries to Ms. Hughes, including a throat perforation and fractured eye socket.
- •Ms. Hughes' injuries were potentially life-threatening, though she received timely medical treatment.
- •The appellant had a significant criminal history, including previous convictions for attempted murder and other violent offences.
- •A pre-sentence report assessed the appellant as posing a high risk of causing serious harm.
Legal Principles
Sentencing for wounding with intent under section 18 of the Offences Against the Person Act 1861.
Offences Against the Person Act 1861
Imposition of life sentences under sections 283 and 285 of the Sentencing Act 2020.
Sentencing Act 2020
Categorization of harm in sentencing guidelines for section 18 offences.
Seriousness Guideline (Overarching Principles)
Consideration of dangerousness and the seriousness of the offence in determining the appropriate sentence.
R v Burkinskas [2014] EWCA Crim 334
Section 63 of the 2020 Act considers harm caused, intended, or foreseeably caused when assessing the seriousness of the offence.
Sentencing Act 2020
Outcomes
Appeal against sentence dismissed.
The court found the notional determinate sentence of 15 years and the life sentence to be appropriate given the severity of the offence, the appellant's criminal history, and the risk he posed to the public.