R v Marcus Taylor
[2024] EWCA Crim 615
R v Jean-Claude Placide
13 December 2023
[2023] EWCA Crim 1636
Court of Appeal
A man was given a long prison sentence for serious crimes against his partner. He tried to appeal the length of the sentence, but the appeal court said the sentence was fair given the horrific nature of the crimes.
Key Facts
- •Jean-Claude Placide (aged 57) was convicted of four counts of rape, one count of false imprisonment, and one count of controlling or coercive behaviour.
- •The offences involved significant violence, threats, and psychological abuse against the victim (C1), spanning several years.
- •The relationship between the applicant and C1 began in 2014, deteriorating a year later.
- •The offences included repeated rapes, false imprisonment involving threats of violence and the use of scissors, and sustained controlling and coercive behaviour.
- •The victim suffered physical injuries and significant psychological harm.
Legal Principles
Reporting restrictions under the Sexual Offences (Amendment) Act 1992 apply to protect the victim's identity.
Sexual Offences (Amendment) Act 1992
Sentencing for rape follows the Sentencing Guideline for rape, considering harm and culpability.
Sentencing Guideline for rape
An extended determinate sentence may be imposed if the offender is considered dangerous under section 279 of the Sentencing Act 2020.
Sentencing Act 2020, section 279
On appeal against sentence, the court considers whether the sentence is manifestly excessive or wrong in principle.
Court of Appeal Criminal Division
Outcomes
The application for an extension of time to appeal the sentence was refused.
The sentence was not manifestly excessive or wrong in principle. The judge appropriately considered the aggravating and mitigating factors and applied the relevant sentencing guidelines.
Leave to appeal against sentence was refused.
The court found the sentencing remarks clear and well-structured, and the sentence, if anything, generous to the applicant. The argument that the sentence was manifestly excessive was deemed not arguable.