The Supreme Court has agreed to hear a further appeal by a young man over his conviction for the murder of his mother in a frenzied knife attack.
The court, in a recently published determination, said Celyn Eadon’s case raises legal issues of general public importance concerning whether intoxication can ever be a defence to murder.
Eadon was aged 19 in 2011 when he stabbed his 46-year-old mother Noreen Kelly, a lone parent from Islandeady, Castlebar, Co Mayo, 19 times.
Since he was aged 13, he was a significant and persistent abuser of alcohol and drugs, including amphetamines, cocaine and crystal meth, the Supreme Court noted.
In the eighteen months before the killing, he was spending upwards of €400 per week on drugs and also drank large quantities of alcohol on a daily basis, it said.
The trial heard Ms Kelly had taken drugs from her son’s bedroom and burnt them on the evening before she died.
The Supreme Court said Eadon killed his mother in a “frenzied knife attack” on 9th March 2011 at about 1.30am. He had never previously exhibited violence towards her, it said.
He was charged with murder and his plea to manslaughter was not accepted by the DPP.
He ran two defences, one based on diminished responsibility which the jury rejected, and the second, related to the question of intoxication. He was convicted of murder and his appeal was rejected by the Court of Appeal in May 2018.
His application for a further appeal to the Supreme Court centred on two grounds: (1) what role does intoxication play in the formation of the necessary intent to kill and how that should be explained by the trial judge to the jury, and (2) whether counsels’ address to the jury is a factor an appeal court may take into account in reviewing the adequacy of the judge’s charge.
‘Some uncertainty’
In its determination, the Supreme Court said, in the week before his mother’s killing, Eadon was suffering from hallucinations and paranoid delusions and “behaving most strangely”.
His father, from whom his mother was estranged, was called to the house on the evening before the killing and found his son barricaded inside and in total darkness, in the belief aliens were coming, third parties were spying on him and attempting to poison or gas him, and a nuclear explosion had taken place.
He appeared to have calmed down some three hours later when his father left, it said.
Having killed his mother, he turned up at a neighbour’s house at about 7am, barefoot and in a wet tracksuit bottom with scratches, bruises and cuts on his body indicating he had gone there through fields.
There was a “significant” body of psychiatric evidence before the jury which, if accepted, could have had a material effect on the formation of the specific intent required for a murder conviction, the Supreme Court said.
The trial judge, in his charge and a re-charge, had addressed the intoxication issue and the Court of Appeal held the re-charge meant his overall instruction to the jury was adequate.
The Supreme Court said there is “some uncertainty” about the trial judge’s statement that intoxication is no defence, to for example, a murder charge.
The formation of the necessary intent is a critical ingredient of the murder charge, it said. That intent must be related to facts and circumstances of the individual case with the ultimate question being whether the DPP has satisfied the jury beyond a reasonable doubt such an inhibiting factor did not prevent formation of the intent.
The law on this point is “not decisively clear cut” in this jurisdiction, the court said. Given the crucial element which intent plays in this particular charge, it is in the public interest and a matter of general public importance the issue should be clarified, it said.
As the second issue is so interlinked in the case with the first question, the court said it was granting leave to appeal on both issues,
