R v Marcus Taylor
[2024] EWCA Crim 615
R v DCB
11 April 2024
[2024] EWCA Crim 554
Court of Appeal
A man was convicted of sexually abusing his daughter and stepdaughter many years ago. He got a long prison sentence (19 years). He appealed, saying the sentence was too long, but the Court of Appeal disagreed, saying the sentence was fair given the serious crimes committed.
Key Facts
- •The appellant, DCB (name anonymized for victim protection), was convicted of multiple counts of rape and indecent assault against his biological daughter (C1) and stepdaughter (C2).
- •Offenses occurred between 1973 and 1980.
- •Appellant was 82 years old at sentencing.
- •Appellant received a 19-year custodial sentence with a one-year extended licence period.
- •The appeal concerned the sentence's length, not the conviction itself.
- •Appellant had no prior convictions.
- •The appellant's health was a significant factor in sentencing considerations, including COPD, diabetes, and a history of cancer.
- •Victim Personal Statements detailed the significant long-term effects on C1 and C2.
Legal Principles
Sexual Offences (Amendment) Act 1992: Restrictions on publishing information that could identify victims of sexual offenses.
Sexual Offences (Amendment) Act 1992
Sentencing Act 2020, section 278: Special Custodial Sentences.
Sentencing Act 2020
Sentencing Act 2020, section 33: Pre-sentence reports.
Sentencing Act 2020
Totality principle in sentencing: Ensuring the overall sentence is just and proportionate.
Case Law (implied)
Categorization of harm and culpability in sexual offense sentencing, referencing R v KC [2020] 1 Cr App R(S) 41 and R v DP [2022] EWCA Crim 57.
Case Law: R v KC [2020] 1 Cr App R(S) 41; R v DP [2022] EWCA Crim 57
Consideration of offender's age and health in sentencing.
Case Law (implied)
Outcomes
Appeal dismissed.
The court found the sentence, while severe, was not manifestly excessive or wrong in principle. The judge appropriately considered the totality principle, the seriousness of the offenses, the appellant's age and health, and the harm caused to the victims.