R v Joe Robert Slack
[2023] EWCA Crim 522
R v Raymond Alexander McLaren
5 December 2023
[2023] EWCA Crim 1555
Court of Appeal
A man stabbed his wife, causing serious injuries. He was sentenced to 7 years in prison. The court decided this sentence was fair considering the seriousness of the crime and the fact that it was committed against his wife, even though he had a good character and showed some remorse.
Key Facts
- •Appellant (63) pleaded guilty to wounding with intent (s 18 Offences Against the Person Act 1861) after stabbing his wife, Helen.
- •The stabbing occurred during an argument about separation after 30 years of marriage.
- •Helen suffered serious injuries, including a 1cm laceration to her left ventricle and a blood clot around her heart, requiring emergency surgery.
- •Appellant was described as 'quite calm' after the incident and said, 'I've done the crime, I'll do the time'.
- •Appellant had previous convictions, but they were old and unrelated.
- •The offence was categorized as medium culpability (Category B) and harm category 1 under the s 18 guideline.
- •The Recorder gave a 12.5% discount for the guilty plea, resulting in a 7-year sentence.
Legal Principles
Sentencing guidelines for s 18 Offences Against the Person Act 1861.
Sentencing Guidelines
Aggravating factors in sentencing for s 18 offences, including domestic context and history of abuse.
Case Law and Sentencing Guidelines
Credit for guilty pleas in sentencing.
Case Law and Sentencing Practice
Outcomes
Appeal dismissed.
The Court found the 7-year sentence was not manifestly excessive. The aggravating factors (serious injuries, domestic context, history of abuse) outweighed the mitigating factors (good character, efforts to address alcohol issues). The credit given for the guilty plea was deemed appropriate.