Caselaw Digest
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R v Dalton Jefferies

16 January 2023
[2023] EWCA Crim 21
Court of Appeal
A man was found guilty of abusing his girlfriend and her daughter. He got a sentence of 2.5 years in prison. The government tried to get him a longer sentence, but the court said the judge made a fair decision considering all the details of the case.

Key Facts

  • Dalton Jefferies (22) pleaded guilty to cruelty to a person under 16 (Children and Young Persons Act 1933, s1(1)) and controlling/coercive behaviour (Serious Crime Act 2015, s76(1) and (11)).
  • Offences involved abuse of his partner (A) and her 8-year-old daughter (C) over several months.
  • Abuse included physical violence, threats, intimidation, and controlling behaviour.
  • A recorded Jefferies' abusive behaviour, providing crucial evidence.
  • Jefferies had a difficult childhood marked by his father's violence and his own mental health issues, including a personality disorder.
  • He received concurrent sentences of 2 years and 6 months imprisonment for both counts.

Legal Principles

Sentencing guidelines for controlling or coercive behaviour and child cruelty.

Sentencing Council guidelines

Principle of totality in sentencing.

Case law and sentencing principles

Consideration of mitigating factors, including youth, mental health issues, and lack of previous convictions.

Sentencing Council guidelines and case law

Overarching Principles: Domestic Abuse guideline.

Sentencing Council guidelines

Reporting restrictions under s45 of the Youth Justice and Criminal Evidence Act 1999.

Youth Justice and Criminal Evidence Act 1999, s45

Outcomes

The Attorney General's application for leave to refer the sentence as unduly lenient was refused.

The Court of Appeal found that while the sentence was lenient, it was within the reasonable range available to the judge considering all mitigating and aggravating factors. The judge's sentencing exercise was deemed careful and considered.

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