A man has won his Supreme Court appeal over his conviction for the murder of his mother in a "frenzied knife attack".
The DPP will now decide whether to accept Celyn Eadon’s manslaughter plea or pursue a retrial on the murder charge.
Mr Eadon was aged 19 in 2011 when he stabbed his 46-year-old mother Noreen Kelly, a lone parent from Islandeady, Castelbar, Co Mayo, 19 times.
A five-judge Supreme Court unanimously ruled on Friday his murder conviction was unsafe because the trial judge’s instruction to the jury on intoxication and specific intention was inadequate and also wrongly instructed them that intoxication is never a defence in law.
The question for the jury was not whether Mr Eadon was so intoxicated as to lack capacity to form the specific intent for murder but whether he did “in fact” form the intent, Mr Justice William McKechnie said.
This must be reflected in the trial judge’s charge to the jury and it is not sufficient, as occurred in this case, to tell the jury the issue is determined on the question of whether the accused had the “capacity” to form the necessary intent.
The trial judge’s charge to the effect that voluntary intoxication “is not under our law a defence or any mitigation in one’s responsibility to society” also had the capacity “to mislead”.
The judge did not inform the jury of the “vitally important point” that intoxication can be a partial defence to murder although not to manslaughter.
Rejecting arguments that speeches from counsel to the jury, which stated intoxication could be a defence to murder, could save the defects in the trial judge’s charge, he said speeches from counsel cannot supplant the trial judge’s obligation to correctly state the law.
In a concurring judgment, Mr Justice Peter Charleton said the trial judge's statement that intoxication "is part of the mix" in relation to whether a person is capable of forming the necessary intent to kill or cause serious injury to the victim was wrong.
A person may, for example, “be capable” of intending to kill and yet not so intend, he said. After the judgments, Patrick Gageby SC, for Mr Eadon, confirmed to the court his client had pleaded guilty to manslaughter at the outset of his trial.
The DPP must now consider whether to accept that plea, with the effect Mr Eadon will be sentenced for manslaughter, or retry the murder charge.
Earlier, the judges noted, since Mr Eadon was aged 13, he was a significant and persistent abuser of alcohol and drugs, including amphetamines, cocaine and crystal meth. In the 18 months before the killing, he was spending upwards of €400 per week on drugs and drank large quantities of alcohol on a daily basis.
The trial heard Ms Kelly had taken drugs from her son’s bedroom and burnt them on the evening before she died.
Mr Eadon killed his mother in a “frenzied knife attack” on March 9th, 2011 at about 1.30am.
He had never previously exhibited violence towards her, it noted. After his plea to manslaughter was not accepted, he ran two defences at trial. One was based on diminished responsibility, which the jury rejected, and the second, related to intoxication.
He was convicted of murder and lost an appeal over the conviction. The Supreme Court agreed to hear a further appeal centred on (1) what role intoxication plays 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.
It noted, in the week before his mother’s killing, Mr Eadon was suffering from hallucinations and paranoid delusions and “behaving most strangely”.
His father, from whom his mother was estranged, called to the house 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.
Having killed his mother, he turned up at a neighbour’s house about 7.20am, barefoot and in a wet tracksuit bottom with scratches, bruises and cuts on his body indicating he had gone there through fields.
The neighbour said Mr Eadon told him he had been abducted by aliens, the army were looking for him and he thought he had killed his mother.
In those circumstances, the defence relied upon the defence of intoxication. A psychiatrist gave evidence he considered Mr Eadon was grossly intoxicated at the time, experiencing psychotic symptoms as a result and this would have affected his capacity to form specific intent.
