Court of Appeal: Man who stabbed his mother in a state of drug-induced psychosis fails in appeal against conviction

About this case:

• Judgment:
  External link

Dismissing all four grounds raised by the man, Mr Justice Edwards said that the trial judge’s directions to the jury were adequate and stated that the verdict was safe.

Background

Celyn Eadon was 19 years old when he fatally stabbed his mother, Nóirín Eadon, in their home in Castlebar, Co Mayo in 2011.

Hearing Mr Eadon’s appeal against his conviction, Mr Justice Edwards explained that “n the five days immediately prior to the incident the appellant was consuming a large quantity of drugs, in particular amphetamines as well as methadone and diazepam, and because of the effect of the amphetamines was unable to sleep. During this period he suffered paranoid delusions and engaged in erratic behaviour: spraying deodorant to ward off demons; believing he was being pursued by aliens and making crop circles to communicate with them; asserting that fire ants and demons were emerging from the walls; imagining that the house was full of smoke; blocking the air vent in his bedroom with coins and stones because he believed the room was being filled with poison gas; and setting on fire an electrical socket and the family cat’s bed”.

Hours after the stabbing, Mr Eadon arrived at a man’s house in a neighbouring townland covered in scratches and cuts, wearing only a set of wet tracksuit bottoms, claiming that he had “been abducted by aliens who experimented on his mind”. In Garda interviews after the incident, Mr Eadon stated that he didn’t know that he had stabbed his mother, and that he thought she was someone else at the time.

Mr Justice Edwards also explained that Mr Eadon’s mother had attempted to get professional help for him from state services on numerous occasions, including the day before her death, but that she had been unsuccessful.

In February 2014, after a 10-day trial, Mr Eadon was convicted of the murder of his mother.

Having pleaded guilty to manslaughter, this was rejected by the DPP; and his defence of diminished responsibility under Section 6 of the Criminal Law (Insanity) Act 2006 was rejected by the jury at his trial for murder.

The jury also rejected an alternative defence which contended that Mr Eadon lacked the specific intent necessary for the homicide to be characterised as murder rather than manslaughter. In the Court of Appeal, Mr Eadon contended that the trial judge misdirected the jury on this issue, particular with regard to his intoxication and its relevance in the assessment of his intent.

Intoxication

Psychiatric professionals indicated at trial that his intoxication could have interfered with his capacity to reason, his judgment, his ability to control himself and his intention; including a consultant psychiatrist who opined that his intoxication had the effect that “…in such a state of mind, he would have been so grossly impaired it would have affected his ability to form that kind of intent”

In the trial judge’s charge to the jury, it was stated in relation to diminished responsibility that “‘Mental disorder includes mental illness, mental disability, dementia or any disease of the mind, but does not include intoxication.’ It is the situation of our law that voluntary intoxication or the taking of drugs in the words of the former Chief Justice, ‘does not afford a defence to criminal responsibility or any mitigation in one’s responsibility to society’.”

In reference to the evidence presented by expert witnesses, the trial judge explained to the jury that Mr Eadon was mentally “not just simply intoxicated but grossly intoxicated and in addition to being grossly intoxicated experiencing psychotic symptoms as a result of the intoxication”, and further, that “as a consequence of his intoxication, experienced a substance-induced psychosis”.

The trial judge went on to say that Mr Eadon had a “drug-induced brain injury” that was not the same as someone who was merely drunk or intoxicated, and that a degree of intoxication was central to his behaviour at the time.

Upon the request of defence counsel, the trial judge re-charged the jury to emphasise that his statements on intoxication were given in a free-standing manner not included in his statements on diminished responsibility. Further, he again referred to the words from a former Chief Justice that “voluntary taking of drink and drugs does not under our law form a defence or any mitigation in one’s responsibility to society” - but added that intoxication was “part of the mix” in relation to whether a person is capable of forming necessary intent.

Court of Appeal

In the Court of Appeal, Mr Eadon challenged his conviction on four grounds:

In considering the trial judge’s charge, partially outlined above, Mr Justice Edwards said that the judge was correct to tell the jury that voluntary intoxication did not provide a defence to criminal responsibility. Mr Justice Edwards was also satisfied that the trial judge’s instructions to the jury when recharging them was adequate having regard to the overall run of the trial.

Satisfied that the trial was satisfactory and the verdict safe, Mr Justice Edwards dismissed all four grounds of appeal submitted by Mr Eadon.

Copyright © Irish Legal News Ltd 2018