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.