Coe, R. v [2009] EWCA Crim 1452 (14 July 2009)

Coe, R. v [2009] EWCA Crim 1452 (14 July 2009)

Section 15 of the Road Traffic Offenders Act 1988 does not apply to offences under section 3A(1)(c) of the Road Traffic Act 1988; the blood analysis evidence was relevant and admissible, and its admission did not render the conviction unsafe. The sentence imposed was not manifestly excessive given aggravating...

Source-derived case information.

Citation
[2009] EWCA Crim 1452
Parties
Appellant: Regina; Respondent: Christopher Steven Coe
Jurisdiction
England and Wales
Judgment Date
14 July 2009
Procedural Posture
Criminal Appeal / Appeal Against Conviction and Sentence
Outcome
appeal dismissed
Legal Topics
Causing Death by Careless Driving, Failure to Provide Specimen, Admissibility of Evidence, Sentencing Guidelines
Criminal Law Road Traffic Law Causing Death by Careless Driving Failure to Provide Specimen Admissibility of Evidence Sentencing Guidelines

Source-derived case record

Summary, issues, holding and outcome

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Parties

Regina

Appellant

Christopher Steven Coe

Respondent

Procedural Posture

Criminal Appeal / Appeal Against Conviction and Sentence

Legal Issues

  1. 1 Whether evidence of blood alcohol analysis was admissible under section 15 of the Road Traffic Offenders Act 1988
  2. 2 Whether evidence should have been excluded under section 78 of the Police and Criminal Evidence Act 1984
  3. 3 Whether the conviction was safe absent the blood analysis evidence

Ratio Decidendi

Section 15 of the Road Traffic Offenders Act 1988 does not apply to offences under section 3A(1)(c) of the Road Traffic Act 1988; the blood analysis evidence was relevant and admissible, and its admission did not render the conviction unsafe. The sentence imposed was not manifestly excessive given aggravating factors and applicable guidelines.

Court Disposition

appeal dismissed

Orders

  • conviction upheld
  • application for leave to appeal against sentence refused