The Court of Appeal has dismissed Tyler Jackson’s appeal against his conviction for murdering Conor Quinn in Mallow in July 2018, rejecting all three grounds pursued at the hearing.
A jury found Jackson guilty by majority verdict in October 2023, and the Central Criminal Court imposed the mandatory life sentence. The appeal concerned his conviction, not the sentence.
Jackson challenged the trial judge’s refusal to discharge the jury after a witness said he had told Quinn about Jackson and others “hitting me before”. The Court of Appeal said discharging a jury is an exceptional, last-resort measure. It found the comment was a single, unprompted answer in the context of evidence that there was bad blood between the parties. The witness had said he was hit, rather than that Quinn was assaulted. The appeal court was not satisfied the trial judge had wrongly exercised her discretion.
The other two grounds concerned a statement by Christine Kearney, who was 16 when she gave it to gardaí three days after the killing. At trial, Kearney said she could not remember making the statement. It said she saw Jackson running with a kitchen knife and described the blade. She acknowledged her signature but disputed that she would have described its length in inches. The trial judge admitted the statement under section 16 of the Criminal Justice Act 2006.
The appeal court held that professed amnesia can amount to material inconsistency under section 16. It found there was evidence on which the trial judge could conclude that Kearney’s evidence was materially inconsistent with her statement. The trial judge had also found the statement voluntary, that Kearney understood the truth declaration, and that the circumstances of its taking were reliable. The Court of Appeal found no basis to interfere with those conclusions.
The appeal judges noted that the statement was not video-recorded and that amendments were not initialled. They said video recording is not a statutory requirement and its absence alone did not make an otherwise admissible statement inadmissible. The court rejected the remaining challenges to the reliability assessment and to the burden of proof. The appeal was dismissed.