Judgment: 2019-12-20 · Court archive

Supreme Court overturns murder conviction over intoxication direction

The court found the jury had been incorrectly directed on the relationship between intoxication and intent, and returned the prosecution to the Central Criminal Court to decide whether to retry the accused or accept his manslaughter plea.

Supreme Court · [2020] IESC 000

Who, what, where, when and why

Who
  • Celyn Eadon
  • Nóirín Eadon
  • Peter Charleton (Judge)
What

The court found the jury had been incorrectly directed on the relationship between intoxication and intent, and returned the prosecution to the Central Criminal Court to decide whether to retry the accused or accept his manslaughter plea.

Where

Places mentioned in the report

  • Derrycrieve, County Mayo
  • Derrycrieve
  • County Mayo
When

Judgment:

Other dates in the report
  • 5 February 2014

    Eadon was 19 when he killed his mother, Nóirín Eadon, at their family home in Derrycrieve, County Mayo. He pleaded guilty to manslaughter in January 2014. The prosecution disputed whether that plea properly reflected his culpability, and a jury found him guilty of murder on 5 February 2014 after rejecting his diminished responsibility defence. The Court of Appeal upheld the conviction in 2018.

Why

Reasons reported in the judgment

Eadon was 19 when he killed his mother, Nóirín Eadon, at their family home in Derrycrieve, County Mayo. He pleaded guilty to manslaughter in January 2014. The prosecution disputed whether that plea properly reflected his culpability, and a jury found him guilty of murder on 5 February 2014 after rejecting his diminished responsibility defence. The Court of Appeal upheld the conviction in 2018.

The Supreme Court has overturned Celyn Eadon’s murder conviction, ruling that the jury was incorrectly directed on how to assess intoxication and intent. The case is to return to the Central Criminal Court so the Director of Public Prosecutions can decide whether to seek a retrial for murder or accept Eadon’s existing guilty plea to manslaughter.

Eadon was 19 when he killed his mother, Nóirín Eadon, at their family home in Derrycrieve, County Mayo. He pleaded guilty to manslaughter in January 2014. The prosecution disputed whether that plea properly reflected his culpability, and a jury found him guilty of murder on 5 February 2014 after rejecting his diminished responsibility defence. The Court of Appeal upheld the conviction in 2018.

The Supreme Court granted leave to appeal on whether intoxication could be a defence to murder and whether the trial judge’s directions on that issue were adequate. The homicide and Eadon’s responsibility for it were not contested at trial; the jury’s task included deciding his state of mind and whether the manslaughter plea was sufficient.

In a judgment delivered on 20 December 2019, Mr Justice Peter Charleton said the trial judge had confused a person’s capacity to form an intent with whether that person actually formed the intent to kill or cause serious injury. A person may be capable of forming that intent while drunk and still not have done so, the judgment said. The jury needed to decide whether Eadon in fact intended to kill or cause serious injury.

The court rejected the prosecution’s argument that the judge’s direction could be cured by the prosecution lawyer’s closing speech. Charleton said legal directions were the trial judge’s responsibility and could not be supplied by counsel.

The Supreme Court held that voluntary intoxication is not, by itself, a defence to homicide. But if intoxication meant the accused did not in fact form the intent required for murder, the offence could be reduced to manslaughter. The court said the correct direction should distinguish that question from whether the accused was capable of forming intent.

The order overturns the Court of Appeal’s decision and returns the prosecution to the Central Criminal Court. It does not itself decide whether Eadon will face a retrial or whether his manslaughter plea will be accepted; that decision is for the Director of Public Prosecutions.

Read the original court judgment

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