R. v. Edwards

R. v. Edwards

The trial judge erred by failing to grant enhanced credit for pre-sentence custody where appropriate: credit must be given for the 86-day revocation period and two-for-one credit applied to the first 30-day remand period where the only reason to deny it was a withdrawn breach charge; accordingly the appeal is...

Source-derived case information.

Citation
2011 ONCA 798
Parties
Respondent: Her Majesty The Queen; Appellant: Paul King Edwards
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
16 December 2011
Procedural Posture
Criminal / Appeal From Conviction and Sentence (court of Appeal for Ontario)
Outcome
Leave to appeal granted; appeal allowed; sentence reduced by 202 days.
Legal Topics
Pre Sentence Custody Credit, Two for One Credit, Recognizance Breach, Sentence Reduction
Source Language
en
Criminal Law Sentencing Bail/remand Pre Sentence Custody Credit Two for One Credit Recognizance Breach Sentence Reduction

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Parties

Her Majesty The Queen

Respondent

Paul King Edwards

Appellant

Procedural Posture

Criminal / Appeal From Conviction and Sentence (court of Appeal for Ontario)

  1. 1 Whether the trial judge erred in failing to give credit for pre-sentence custody (86 days)
  2. 2 Whether two-for-one credit should have been applied to a 30-day remand period where the breach of recognizance charge was withdrawn
  3. 3 Whether one-for-one credit should apply to all pre-sentence custody because the post-credit sentence was fit

Ratio Decidendi

The trial judge erred by failing to grant enhanced credit for pre-sentence custody where appropriate: credit must be given for the 86-day revocation period and two-for-one credit applied to the first 30-day remand period where the only reason to deny it was a withdrawn breach charge; accordingly the appeal is allowed and the sentence reduced by 202 days.

Court Disposition

Leave to appeal granted; appeal allowed; sentence reduced by 202 days.

Orders

  • Leave to appeal granted
  • Appeal allowed