AG v Downey and Skinner (Royal Court : Sentencing (Criminal)) [2025] JRC 079 (24 March 2025)

AG v Downey and Skinner (Royal Court : Sentencing (Criminal)) [2025] JRC 079 (24 March 2025)

Prior convictions and cautions for violent and disorderly conduct committed by Downey and Skinner, except those committed by Skinner when under 15, are admissible as bad character evidence under Article 82F, as they establish a propensity to commit offences of the kind charged and do not unfairly prejudice the...

Source-derived case information.

Citation
[2025] JRC 079
Parties
Applicant: The Crown; Defendant: Downey; Defendant: Skinner
Jurisdiction
Jersey
Judgment Date
24 March 2025
Procedural Posture
Criminal / Pre Trial Evidentiary Ruling
Outcome
Crown's application to adduce bad character evidence partially granted
Legal Topics
Bad Character Evidence, Admissibility of Prior Convictions, Propensity, Self Defence
Criminal Law Bad Character Evidence Admissibility of Prior Convictions Propensity Self Defence

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Parties

The Crown

Applicant

Downey

Defendant

Skinner

Defendant

Procedural Posture

Criminal / Pre Trial Evidentiary Ruling

Legal Issues

  1. 1 Whether evidence of prior convictions and cautions is admissible as bad character evidence under Article 82F of the Police Procedures and Criminal Evidence (Jersey) Law 2003
  2. 2 Whether admission of such evidence would unfairly prejudice the defendants or adversely affect the fairness of proceedings
  3. 3 Whether the interests of justice require admission of convictions committed when the defendant was under 15

Ratio Decidendi

Prior convictions and cautions for violent and disorderly conduct committed by Downey and Skinner, except those committed by Skinner when under 15, are admissible as bad character evidence under Article 82F, as they establish a propensity to commit offences of the kind charged and do not unfairly prejudice the proceedings. Convictions committed by Skinner when under 15 are not admitted as the interests of justice do not require their admission.

Court Disposition

Crown's application to adduce bad character evidence partially granted

Orders

  • Evidence of Downey's 2017 and 2018 convictions admitted as bad character evidence.
  • Evidence of Skinner's 2018 conviction and 2022 caution admitted as bad character evidence.