R v Jamie Reece Williamson & Anor

Interference with an unduly lenient sentence requires a conclusion outside the range properly open to the sentencing judge on the evidence. Witness intimidation ordinarily requires immediate imprisonment and, when accompanying substantive offences, a consecutive sentence, absent exceptional circumstances. Abuse of trust under the sexual offence sentencing guideline requires a degree of responsibility for the victim. Exploitation of privileged domestic access and a perceived paternal relationship may nevertheless aggravate offending. Sentences must adequately reflect repeated sexual offending and associated interference with justice. Mitigation already reflected in the lead sentence cannot be applied again in a way that neutralises the additional offending. A mother's active participation in sexual offending against her child limits the mitigating weight attributable to her acting under her partner's direction.

The Attorney General sought leave under section 36 of the Criminal Justice Act 1988 to refer sentences imposed by the Crown Court at Leicester as unduly lenient. Jamie Williamson was the partner of QJO, the mother of the two victims, identified as V1 and V2. Both daughters had spent substantial periods in care.

Williamson was convicted of assault by penetration, three sexual assaults against V1, who had recently turned 18, and witness intimidation. V1 regarded him as a father figure and encountered him during visits to her mother's home. He received concurrent sentences producing five years' imprisonment, with a consecutive month for breach of a suspended sentence order.

QJO was convicted of inciting V2, then aged 16, to engage in sexual activity, intimidating V1 and attempting to pervert the course of justice. She also faced sentencing for possessing a bladed article and failing to surrender to bail. Her concurrent sentences produced two years' imprisonment suspended for 18 months. The principal issues were the treatment of privileged access and trust, consecutive sentencing for interference with justice, and the weight and repeated application of QJO's mitigation.

Leave was granted in both cases and the sentences were increased. Williamson's total sentence became seven years and one month's imprisonment. QJO's suspended sentence was replaced by three years' immediate imprisonment.

1. Interference on an Attorney General's reference was not routine. The court could intervene only where the sentencing judge's conclusion fell outside the range of options properly open on the evidence. The errors identified in both sentencing exercises justified intervention (paragraphs 74–75, 79 and 84).

2. Absent exceptional circumstances, witness intimidation required immediate custody. When added to substantive offences, it should attract a consecutive sentence. There were no exceptional circumstances here. Each offender required a consecutive term of 12 months for intimidation (paragraphs 75, 78 and 83).

3. The court accepted the judge's finding that V1 was not particularly vulnerable. Abuse of trust within the sexual offence sentencing guideline concerned cases where the offender had a degree of responsibility for the victim. Williamson's conduct did not fall within that category. His exploitation of privileged domestic access through his relationship with QJO, coupled with V1's perception of him as a father figure, nevertheless aggravated the offending. The increase from the four-year starting point to five years inadequately reflected that feature and the three incidents of sexual abuse. The least appropriate sentence for the sexual offences, taking assault by penetration as the lead offence, was six years (paragraphs 76–78).

4. QJO's sentencing exercise contained two errors of principle. Even if the intimidation and attempted perversion sentences ran concurrently with each other, they should have run consecutively to the sentences for the other offences. Their treatment left them without any effect on the outcome. The judge also applied the already generous mitigation reduction for the lead offence a second time to the additional interference with justice offences (paragraphs 80–81).

5. The finding that QJO acted under Williamson's direction warranted less mitigating weight than the judge had given it. She was the victim's mother and actively participated in the offence and the wider episode. Her participation could not be excused to the extent reflected in the original sentence (paragraph 82).

6. Williamson's consecutive month for breach of the suspended sentence order remained unchanged. QJO's two-year term for the lead offence was retained, with 12 months consecutive for intimidation. Her remaining concurrent terms were retained but ceased to be suspended (paragraphs 78–79 and 83–84).

• Court of Appeal (Criminal Division): In [2026] EWCA Crim 1269 , granted the Attorney General leave to refer both sentences under section 36 of the Criminal Justice Act 1988. Substituted seven years and one month's imprisonment for Williamson and three years' immediate imprisonment for QJO.
• Crown Court at Leicester: Following jury convictions before His Honour Judge Raynor, sentenced Williamson to five years and one month's imprisonment and QJO to two years' imprisonment suspended for 18 months. No citation for the sentencing decision was stated.