Judgment: 2021-07-23 · Court archive

Court of Appeal upholds 16-year sentence for Noel McKeon over violent attacks on two sex workers

Court of Appeal · [2021] IECA 212

Who, what, where, when and why

Who
  • Noel McKeon (Appellant)
What

Court of Appeal upholds 16-year sentence for Noel McKeon over violent attacks on two sex workers

Where

Places mentioned in the report

  • Central Criminal Court
  • Court of Appeal
When

Judgment:

Why

Reasons reported in the judgment

In the second case, another woman initially agreed to paid sexual activity. The court found that events then became non-consensual and violent. McKeon punched her, pulled out hair and raped her vaginally and anally. Gardaí later documented bruising and facial swelling.

The Court of Appeal has upheld Noel McKeon’s combined 16-year sentence for two separate episodes of serious violence and sexual offending against sex workers, committed about 20 months apart.

McKeon pleaded guilty in July 2019 to six offences. Four arose from an attack on the first woman on June 18, 2016: sexual assault, false imprisonment, assault causing harm and robbery. The second incident, on February 4, 2018, resulted in guilty pleas to rape and rape under section 4.

In the first case, consensual sexual activity was followed by a prolonged violent assault. The court record describes the woman being beaten, restrained, robbed and sexually assaulted before escaping through a window. She later required hospital treatment, including five sutures.

In the second case, another woman initially agreed to paid sexual activity. The court found that events then became non-consensual and violent. McKeon punched her, pulled out hair and raped her vaginally and anally. Gardaí later documented bruising and facial swelling.

The Central Criminal Court treated the two episodes separately. Concurrent sentences for the 2016 offences produced a seven-year term. Concurrent nine-year terms were imposed for the 2018 offences, but consecutively to the first set. The total was 16 years, with the final two years suspended on extensive rehabilitation and good-behaviour conditions.

On appeal, McKeon argued principally that the combined sentence breached the totality principle, which requires courts to ensure multiple sentences do not become disproportionate when added together.

The Court of Appeal disagreed. It noted that McKeon had been questioned by Gardaí about the first attack before committing the second. The sentencing judge had already reduced a combined pre-mitigation assessment of 25 years to 20 years to reflect totality, before allowing further mitigation.

The appeal court found that the guilty pleas, addiction and mental-health issues, remorse and willingness to engage with treatment had been properly recognised. The 16-year sentence, including the two-year suspended portion, therefore remained in place.

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