Sam Mark Oliver [2019] EWCA Crim 1197

The appellant pleaded guilty on the first day of trial to handling stolen goods and was sentenced to 2 years and 6 months imprisonment. He was stopped driving a stolen car valued at £32,000 and said he had been paid to drive it to Leeds.

The sentencing judge placed this in category 2 as high value goods and high culpability as the appellant was in possession of very recently stolen goods from a domestic burglary. The defence argued that he was in possession of the car a week after the burglary and this could not be described as ‘very’ recent so his culpability should have been medium.

Held: the judge was entitled to conclude that the appellant’s possession of the car only a week after the burglary constituted very recent possession for the purpose of the guidelines. The appeal was dismissed.