George Pell’s appeal against his conviction of child sexual assault turns on one question that resists examination and another that must survive it. What is a reasonable doubt? Was it reasonable for the jury that convicted him not to have it?
Two days of courtroom submissions in early June left us little the wiser on the first question. The ensuing analysis was more intent on exploring the narrative possibilities than the basis for them. On Wednesday we’ll learn whether the jury’s guilty verdict is affirmed or set aside. Either way, the reasons provided will offer an overdue insight into the uncertain latitudes of reasonable doubt.
The High Court authority to which the Victorian Court of Appeal must defer is 25 years old and not overly expansive: “A reasonable doubt experienced by the court is a doubt which a reasonable jury ought to have experienced”. The court must examine the evidence afresh and decide for itself whether it proves the charges to the required standard.
Beyond reasonable doubt is a high standard of proof, that much we know. Beyond that, its meaning is still somewhere on the spectrum between self-evident and inescapably subjective.
Justice Chris Maxwell, President of the Court of Appeal and one of the judges who will decide Pell’s fate, spoke to the blurred contours of the task during the hearing. “It’s the very inscrutability of the verdict that is its most striking feature,” he said, contemplating the task of getting inside the jury’s mind. “We have to give reasons. They don’t.”
Even before the appeal it was difficult to understand how a jury could have been sufficiently doubt-free to convict. The uncorroborated evidence of a single witness usually isn’t enough to ground a conviction.
In this case the improbability of the offending was supported by about 20 witnesses at the trial and remarked upon by two of the judges during the appeal. Those witnesses placed Pell in locations that would have made it very difficult for him to commit the crimes at the specified times. It would have required a number of church officials and functionaries to coincidentally depart from their normal practices and for Melbourne’s (then) newly-appointed archbishop to push the extremities of risk-taking.
A dry recounting of the case details does little to dispel the reasonable doubts. The victim’s account changed during the investigation and again under cross-examination at trial. The case put to the jury by the Crown differed again from the victim’s final evidence. The abuse was only reported after the second victim died of a drug overdose in 2014, having denied being abused. The dates of the offending were also subject to variation — at least one other date was proffered and then withdrawn.
Inconsistencies in a victim’s recollection of sexual abuse are no longer regarded as inherently adverse to the victim’s credibility. There is general acceptance of forensic authority that the passage of time — in this case, 22 years — can affect a victim’s recollection of detail without rendering the memory inaccurate or unreliable. Nor is denial unusual in victims of abuse. But these belated acknowledgements go some way to negating a disadvantage rather than conferring an advantage. They don’t lower the standard of proof or shift the onus of establishing it.
That Pell was advised against taking the stand probably reflected a realistic concern that he would not make a particularly sympathetic witness. That the victim was plainly a most convincing witness suggests the renowned demolition tactics of Pell’s trial QC, Robert Richter, backfired badly. Richter said the victim was a “fantasist” and his story an impossibility. The witness held up. The question for the court is whether that is enough to overcome the significant improbabilities and high standard of proof.
A remark ventured by Justice Mark Weinberg on the first day of the appeal may prove instructive. “It’s unfortunate in some ways that the case was pitched at the level of impossibility”, the judge said. “The risk of running it that way is that the jury, faced with competing arguments, answers the wrong question. It answers the question: was it possible?”
We don’t know whether the jury applied the standard of proof correctly because juries don’t give reasons. We do know the victim’s testimony was given by closed-circuit television away from the court, and the first jury couldn’t reach a verdict. We know the second jury watched a recording of the same evidence and the appeal court judges watched the same recording. So the proper deference an appeal court owes to the jury is diminished.
Should the judgment go Pell’s way, it won’t be a victory for arcane legal logic over common justice. It will simply mean the high standard of proof that still applies was not met in this exceptional case. It will portend a great deal more if the trial verdict holds because it will vindicate the high value placed on the first-hand testimony of victims.
The two other grounds of the appeal are not likely to have occupied the court for long. The verdict will stand or fall on the question of reasonable doubt.
“Each of us has had very wide experience of the circumstances that can give rise to a doubt,” said Justice Maxwell, presumably in reference to his two colleagues.
There is every reason to believe they’ll get it right.
If you or someone you know is impacted by sexual assault call 1800RESPECT on 1800 737 732 or visit 1800RESPECT.org.au. Lifeline is on 13 11 14. In an emergency, call 000.
I don’t have any sympathy for George Pell, but I expect his appeal will succeed. His position is similar to that of Lindy Chamberlain, albeit that there was (deeply flawed) corroborating evidence in her case.
I disagree WR. In the Chamberlain case the convicting evidence (fetal spray in the car) was shown to be totally false and there was no history of child abuse. Neither is true in the Pell case.
Bref,
Do you have problems understanding what ‘deeply flawed’ means? There was forensic evidence. It just that is was deeply flawed, to the extent that it shouldn’t have been presented.
All of you are incorrect – in the Chamberlain case the forensic evidence could not be verified by repeating the analysis because the evidentiary material was disposed of after a verdict was given and not be accessed upon further appeals so further scrutiny was not available.
Desmond,
The forensic evidence was deeply flawed. Joy Kuhl, the forensic scientist, used an analysis designed to detect foetal haemoglobin in the maternal circulation in order to decide whether the mother required more anti-Rhesus antibody (actually anti-Rhesus D antibody) to prevent Rhesus disease in the newborn, in a completely novel manner to detect foetal haemoglobin in purported blood sprays in a car exposed to months of baking Queensland summer heat.
The defence expert witness noted in his testimony that according to Joy Kuhl’s analysis there was more foetal haemoglobin in a baked blood spray from a 3 month old infant than there is in the fresh blood of a newborn, but unfortunately the jury didn’t appreciate this, and convicted.
Kuhl’s results meant that her method and her interpretation were both bogus.
This analysis by David Ward (legal credentials?) appears to be fundamentally wrong. Reasonable doubt is not the test for the appeal. Based on Ben Matthews analysis in The Age (Professor of Law at QUT) the test is whether ‘any reasonable jury could have returned a guilty verdict; the evidence must have “obliged” them to reach a not guilty verdict.’ See https://www.abc.net.au/news/2019-08-21/george-pell-has-lost-his-appeal-what-happens-next/11434216
Same thing, Brian D. I agree absolutely with your analysis.But I think this is the same as “reasonable doubt” and I think that the judges who say that it is not evident that “the jury must have had a doubt” have been hoodwinked by what to me is the gobsmacking bad faith of the rhetoric of the prosecution. In some tweets over the past months I have explained that various people including a Professor of Law (who write a book called Kafka’s Law) and Norbert Wiener, MIT mathematician who died in 1964 (I think it was in his book The Human Use of Human Beings), have written books and articles (a former judge of Federal Court in Australia) explaining the bad faith of arguments that are presented in court, that are intended to decieve. I think the prosecution in Pell’s case is a prime example of this).
If the jury did not have a doubt, this is not a reason to confirm the conviction, it is a reason that should guarantee an acquittal on the basis that the jury was not acting reasonably. The chief judge did not appear to understand this point. I am not a lawyer but am used to reading many hundreds of pages of a wide variety of plain English documents each week, from children’s books to university theses. I think this gives me the ability to recognise mumbojumbo when I see it in a court report.
Richard Mullins portal1943@gmail.com
Your last line is interesting: “There’s every reason to believe they’ll get it right”. I’d be interested in what you mean by “right”. The only way in which the appeal decision can really be “right” is by being guilty if he actually did it and “not guilty” if he didn’t; but the Court of Appeal can never actually know that any more than any member of the public can.
Or do you mean “legally right”, in that their decision about whether or not a reasonable jury could have convicted beyond reasonable doubt is right? Ultimately that can really only be a matter of opinion.
One possibility of course is a split decision. That’s unlikely; the three judges will be fully aware of how unsatisfactory it would be and will strive to agree if they can. But it’s definitely possible.
Exactly. It is sad that our legal system is adversarial rather than inquisitorial. Surely finding the truth of a matter is far more just than who has the best lawyers?
Why do you think an inquisitorial system is any more likely to produce the “correct” result. There have been just as many injustices in such systems as in countries where the adversarial system applies.
There’s no perfect system and there never can be.
An inquisitorial System can produce the correct result provided it’s in a setting with rule of law instead of rule of might, as in dictatorships.
Well it can, just as the adversarial system can; but neither of the systems produces the correct result every time, even in the most ideal political environment. Whichever system applies, the result is always the opinion of one or more human beings based on the evidence available to those human beings. Both systems usually get to the right result, but both of them occasionally produce injustices. That’s inevitable, as both systems involve human judgement, which is always fallible.
Well for a start we could improve our system if there was legal representation during the hearing for the victim. So often an “agreed Statement of facts ” is lodged about which the victim has absolutely no say. I see one of the problems of an adversarial system is, the richer you are, the better legal representation you have and the more procedural rejection on technicalities of evidence occurs.
The notion that George deserves his fate as a consequence of his failings as a leader of a flawed institutions whether he is guilty of the crime or not is dangerous. The failures of the Church were not criminal under the law and neither were Gorges actions.
The idea that someone should get what he deserves in the court of public opinion is appalling fascist nonsense. Something that belongs in the US or Chinese legal systems not Australia’s.
If you believe in criminals being judged by their peers rather than a “star council” then the decisions that a jury makes are correct under the law whether the person committed the crime or not.
In Victoria about 92% of courts return convictions based on the guilty plea, about 11% of the cases tried return a guilty verdict and 7% or so return not guilty. These stats do not demonstrate a “broken” system, but one where you have a reasonable chance of getting off if you plead innocent.
Have a look at the Chinese, Japanese and US statistics if you want to get your bearings on all of this.
Highly improbable events occur. Let’s recall the world’s most recognisable & closely guarded woman, Queen Elizabeth, awaking to an intruder lurking in her bedroom. The man, Michael Fagan had scaled Buckingham Palace’s 4.3m wall (topped with barbed wire & spikes), climbed a drainpipe, wandered about the royal apartments & triggered an alarm which was promptly silenced & reported by police as faulty. ERII telephoned security twice for help but none arrived. A fantastic scenario with unexplained loopholes (eg: why did security not respond to the Queen immediately – not once but twice?)
The event was most unlikely…but it happened. Despite a cavalcade of staff being on the premises that morning.
AND Donald Trump is the leader of the “free” world.
Of course the fact that these improbable events happened have absolutely no bearing on Georges crime, but it does open the mind wonderfully to improbable events.
All of which is completely irrelevant to a criminal trial. A trial does not seek to establish whether an unlikely event is possible, but rather whether it almost certainly occurred. If there was no independent evidence of a man breaking in to the Queen’s residence, if it was purely one person’s testimony, a jury might have good reason not to convict. If ERII was able to conclusively describe some detail about the intruder that no one could have known other than meeting him in person, her testimony becomes more compelling.
With Pell, the question is whether the alleged victim’s testimony was sufficiently compelling to outweigh all the other improbabilities. This may be a high bar, but rightly so. Allowing convictions based on a single, shaky witness takes us into the territory of show trials used to punish people for other reasons.
Ahh! But did we have a single SHAKY witness in this case?
I’m responding to reports his testimony changed considerably. Did the jury overlook this? Or did they find his testimony compelling? We can’t know.
No matter what the jury or the judge decides on Pell, the simple fact is he and his church covered up for years what the deviates in the priesthood and brotherhood did to innocent children and that alone is worthy of a lengthy jail term for anybody connected to these psuedo christian business`s masquarading as religions.
Exactly right BB. No matter what the result in this particular case, Pell and the church collectively have been as guilty as sin through their protection racket. But as several recent high profile court cases show, the big end of town looks after itself and the catholic church is one of the biggest.
These are not honourable men and this is not an honourable institution!
It will be interesting in this regard to see what happens under the new proposed Victorian laws.
I do note that senior sectarian managers are still arguing for the right to hide and harbour criminals
One thing you can be fairly sure of is that they will not provide for a person to be convicted of a crime he or she did not commit on the ground that the person has done other bad things, which seems to be the idea of Braddybear and Bref.
You are correct, of course Robin. It just pisses me off that there’s this huge ‘christian’ organisation which leaders and members are getting off scot-free after all the decades of hardship that they have and are causing!
I don’t think that it is legally wise to sentence Pell for the sins of the Church in general. If that was the case there would be a (ahem) hell of a lot of guilty people in gaol from all works of life and professions.
I think any person in a position of power in an organisation who is actively involved in covering up child abuse is as guilty as the abuser. With the catholic church it’s not as if we don’t know who they are. Extremely few are ever charged.
That’s why every management level preacher who covered up or otherwise aided and abetted a crime should be prosecuted as an accessory to that crime.
The notion that George deserves his fate as a consequence of his failings as a leader of a flawed institutions whether he is guilty of the crime or not is dangerous. The failures of the Church were not criminal under the law and neither were Gorges actions.
The idea that someone should get what he deserves in the court of public opinion is appalling fascist nonsense. Something that belongs in the US or Chinese legal systems not Australia’s.
Harbouring child molesters is not criminal under the law? Is the culpability of the catholic church in doubt?
It’s all going to irrelevant soon. ScoMo is going to legislate to make it lawful for sectarian bosses to sack and abuse others on homophobic grounds, even they were far less homophobic about the child rape they were happy to condone by concealing it.
So, bring him and the rest of the church to trial for those crimes.
There is no justification, moral or otherwise, for using a false allegation of one crime to serve as a proxy for others that we believe have been committed.
As much as I loathe Pell and the evil perpetrated and hidden by the church, there are principles of evidence and process that are far too important to set aside in the name of payback.
Isn’t that precisely the problem? When has the law ever brought any of the ‘bosses’ to trial over the systemic protection of perpetrators of child abuse? Like some old fashioned mafia organisation, the good ‘ol church just keeps on doing what it has always done and barring occasional articles in the papers or the odd program on TV, they get off scot-free!
So, go after them! Bring civil trials seeking damages if you can’t get traction with criminal charges.
As someone to whom his being Pell is adequate proof of his being guilty of causing so much ill will & tragedy for far too many years, I cannot see how this appeal will be unsuccessful.