Rex vs Frederick Ambrose

[2024] EWCA Crim 632

Review of sentence for historical sexual offences.


This case involved the review of a sentence imposed on Frederick Ambrose for historical sexual offences against two boys, with the Court of Appeal determining whether the sentence was unduly lenient.


TLDR:

  • Frederick Ambrose was sentenced for historical sexual offences against two boys.
  • The initial sentence included suspended imprisonment and community requirements.
  • The Solicitor General referred the sentence as unduly lenient.
  • The Court of Appeal quashed the original sentence and imposed immediate custodial terms.


On 18th May 2023, Frederick Ambrose appeared in the Crown Court at Snaresbrook, charged with ten counts of historical sexual offences against two boys aged between 8 and 11. Initially pleading not guilty, Ambrose later pleaded guilty to nine counts, with one count left on file.


By 7th March 2024, Ambrose was sentenced to two years' imprisonment, suspended for two years, for multiple counts of indecent assault and indecency with a child. Additional requirements included 250 hours of unpaid work and 20 days of rehabilitation activity. A Sexual Harm Prevention Order of indefinite duration was also imposed.


The Solicitor General referred the sentence to the Court of Appeal under section 36 of the Criminal Justice Act 1988, arguing it was unduly lenient. The Court reviewed the case, considering the seriousness of the offences and the impact on the victims.


Ambrose, aged 72, had committed the offences between 1981 and 1991 while coaching at a youth football club. The victims, anonymized as 'W' and 'C', provided detailed accounts of the abuse, which included indecent assaults and acts of indecency.


The sentencing judge initially considered a custodial sentence of seven years but reduced it significantly due to Ambrose's personal circumstances, including his health and the delay in prosecution. The judge suspended the sentence, citing the 'unconscionable' delay as a major factor.


Upon review, the Court of Appeal found the reduction excessive, given the gravity of the offences and the limited weight of personal mitigation. The Court determined an appropriate sentence would have been five and a half years, reduced to four years and four months after accounting for the guilty plea.


The Court quashed the original suspended sentences and imposed immediate custodial terms. Ambrose was sentenced to four years' imprisonment for the indecent assault counts and 18 months for the indecency with a child counts, to be served concurrently.


Ambrose was ordered to surrender to Hatfield Police Station by noon on 6th June 2024. He will also be subject to the notification requirements under the Sexual Offences Act 2003 for life.



Legal representatives: Miss J Faure-Williams for the Attorney General, Mr. R Taylor for the Offender.

Judicial Panel: Lord Justice William Davis, Mr. Justice Lavender, The Recorder of London (His Honour Judge Lucraft KC).

Case Citation Reference: [2024] EWCA Crim 632


Tags
Criminal Law Sexual Offences Court Of Appeal

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