R. v. Lawrence

R. v. Lawrence

The Court held the trial judge did not err: the Crown disproved self-defence under s.34(2); necessity did not excuse the impaired driving once the appellant had driven to the parking lot; the impaired driving sentence of one year was excessive and is reduced to four months concurrent; the trial judge properly...

Source-derived case information.

Citation
C39605
Parties
Respondent: Her Majesty the Queen; Appellant: Ronald James Lawrence
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
28 January 2004
Procedural Posture
Criminal / Appeal From Conviction and Sentence (court of Appeal)
Outcome
Appeal dismissed except to reduce the impaired driving sentence to four months concurrent; convictions and other sentences upheld.
Legal Topics
Self Defence, Necessity, Impaired Driving, Sentencing, Conditional Sentence
Source Language
en
Criminal Law Self Defence Necessity Impaired Driving Sentencing Conditional Sentence

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Parties

Her Majesty the Queen

Respondent

Ronald James Lawrence

Appellant

Procedural Posture

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

  1. 1 Whether the Crown disproved self-defence under s.34(2) of the Criminal Code
  2. 2 Whether necessity excuse applied to impaired driving after appellant entered and drove to parking lot
  3. 3 Whether the impaired driving sentence was excessive and whether a conditional sentence was appropriate for the assault

Ratio Decidendi

The Court held the trial judge did not err: the Crown disproved self-defence under s.34(2); necessity did not excuse the impaired driving once the appellant had driven to the parking lot; the impaired driving sentence of one year was excessive and is reduced to four months concurrent; the trial judge properly declined a conditional sentence for the serious assault and that decision is entitled to deference.

Court Disposition

Appeal dismissed except to reduce the impaired driving sentence to four months concurrent; convictions and other sentences upheld.

Orders

  • Appeal allowed in part to reduce impaired driving sentence to four months concurrent.
  • All other aspects of the appeal dismissed; convictions and the trial judge's refusal to impose a conditional sentence are upheld.