R. v. Tmenov

R. v. Tmenov

Fresh evidence showed trial counsel did not appreciate the immigration consequences of enhanced pre-sentence custody credit; with Crown consent and under Pham and Nassri the court reduced the credit from 198 to 179 days and varied the sentence to a suspended sentence with two years' probation to avoid the...

Source-derived case information.

Citation
2017 ONCA 454
Parties
Respondent: Her Majesty the Queen; Appellant: Tamerlan Tmenov
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
2 June 2017
Procedural Posture
Criminal Appeal / On Appeal From Sentence; Sentence Appeal Allowed
Outcome
Appeal allowed; sentence varied
Legal Topics
Pre Sentence Custody Credit, Deportation Consequences, Fresh Evidence, Joint Submission, Weapons Prohibition (s.109), DNA Order
Source Language
en
Criminal Law Immigration Law Sentencing Pre Sentence Custody Credit Deportation Consequences Fresh Evidence Joint Submission Weapons Prohibition (s.109) +1 more

Source-derived case record

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Legal principles 3 Authorities cited 3 Party arguments 2 Amounts and remedies 3
Sign in to unlock

Parties

Her Majesty the Queen

Respondent

Tamerlan Tmenov

Appellant

Procedural Posture

Criminal Appeal / On Appeal From Sentence; Sentence Appeal Allowed

  1. 1 Whether enhanced credit for pre-sentence custody should be reduced because it produced adverse immigration consequences
  2. 2 Whether fresh evidence that trial counsel failed to appreciate immigration consequences justifies appellate intervention
  3. 3 Whether the sentence should be varied to avoid collateral deportation consequences

Ratio Decidendi

Fresh evidence showed trial counsel did not appreciate the immigration consequences of enhanced pre-sentence custody credit; with Crown consent and under Pham and Nassri the court reduced the credit from 198 to 179 days and varied the sentence to a suspended sentence with two years' probation to avoid the deportation appeal bar.

Court Disposition

Appeal allowed; sentence varied

Orders

  • Pre-sentence custody credit reduced to 179 days (originally 198 days)
  • Sentence varied to a suspended sentence with two years' probation with credit for 179 days' pre-sentence custody