Caselaw Digest
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R v Miles Cracknell

[2024] EWCA Crim 1437
Cracknell was found guilty of serious drug crimes. The appeal court agreed there was enough evidence to convict him and that his sentence was fair, even though it was a long prison term.

Key Facts

  • Miles Cracknell convicted of conspiracy to supply cocaine, conspiracy to supply cannabis, and possession of criminal property.
  • Sentenced to 15 years for cocaine conspiracy, 3.5 years consecutively for cannabis conspiracy (total 18.5 years), and 4 years concurrently for possession of criminal property.
  • Appealed conviction on grounds of 'no case to answer' and improper admission of prior conviction evidence.
  • Appealed sentence on grounds of incorrect role assessment and disproportionate consecutive sentencing.

Legal Principles

Test for 'no case to answer': Whether enough evidence, at its highest, for a reasonable jury to infer guilt (R v Wassab Khan [2013] EWCA Crim 1345).

R v Wassab Khan [2013] EWCA Crim 1345

Admissibility of bad character evidence (R v Hanson [2005] EWCA Crim 824): Relevance to an important matter in issue.

R v Hanson [2005] EWCA Crim 824

Sentencing guidelines for drug trafficking conspiracies: Consideration of role (leading vs. significant), quantity of drugs, and aggravating/mitigating factors.

Sentencing Guidelines (implied)

Outcomes

Appeal against conviction refused.

Judge correctly applied the 'no case to answer' test; evidence, including telephone data, was sufficient for a jury to consider. Admission of prior conviction was also held to be appropriate under R v Hanson.

Appeal against sentence refused.

Judge's assessment of Cracknell's leading role was justified; sentence was within guidelines and proportionate, considering totality of offences.

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