The Court of Appeal has dismissed Ian Connaghan’s appeal against the severity of his sentence for manslaughter, leaving in place a nine-year prison term with the final 12 months suspended for three years.
Connaghan was found not guilty of murdering Michael Mulvey but guilty of his manslaughter after a trial. The Central Criminal Court imposed the sentence on 4 December 2023. Connaghan’s brother, Danial Connaghan, was separately convicted of causing serious harm to Mulvey.
The appeal focused mainly on whether the sentencing judge was right to place the manslaughter in the high-culpability range under the Supreme Court’s sentencing guidelines. Connaghan argued that the case belonged in the medium range, pointing to the absence of a weapon and arguing that the assaults were unpremeditated. He also said the judge had not given enough weight to mitigation, including his personal circumstances, acceptance of the verdict and remorse. He argued that the difference between his sentence and his brother’s was disproportionate.
The prosecution submitted that the offending involved premeditation, animosity and multiple aggravating factors. It said the sentencing judge had properly considered mitigation and that the brothers had been convicted of different offences and had different levels of culpability.
The Court of Appeal found that the second assault, near the Halfway House pub, involved significant premeditation: Connaghan had enlisted his brother’s help, and the two had lain in wait for Mulvey. The court also pointed to callousness and the vicious, frenzied nature of the attacks. It said those factors supported placing the offending in the high-culpability range, although towards its lower end. The sentencing judge had not made an error of principle by doing so.
The court rejected the disparity argument, saying the cases were not the same. Connaghan had been involved in two incidents close together, while his brother was involved in one. It also found that adequate credit had been given for mitigation. The court dismissed all grounds of appeal and left the sentence unchanged.