JCPC/2025/0022
•
CRIME
Uriah Woods (Appellant) v The State (Respondent) No 2 (Trinidad and Tobago)
Case summary
Case ID
JCPC/2025/0022
Jurisdiction
Trinidad and Tobago
Parties
Appellant(s)
Uriah Woods
Respondent(s)
The State of Trinidad and Tobago
Issue
(1) Should fresh psychiatric evidence regarding the appellant, obtained after his conviction for murder, be admitted and considered by the Judicial Committee of the Privy Council? (2) Does the fresh psychiatric evidence show that the appellant was not guilty of murder but of manslaughter on the grounds of diminished responsibility or, alternatively, that the appellant was not fit to plead or stand trial? (3) Did the trial judge materially misdirect the jury as to the elements of the defence of provocation?
Facts
On 14 July 2005, Sandra Miller was killed. The appellant, Mr Uriah Woods, was indicted for her murder and his trial took place between 18 May 2015 and 9 July 2015. The prosecution’s case at trial was that Mr Woods committed a premeditated murder of Ms Miller. The prosecution led evidence that Mr Woods and Ms Miller had a fifteen-year relationship during which he abused her and threatened to kill her if she left him. In February 2005, Ms Miller left Mr Woods and moved to another property, Leeward Croft. Ms Miller then entered a relationship with another man, Lawrence Stewart. On 14 July 2005, Mr Woods came to Leeward Croft with a cutlass, found Ms Miller in bed with Mr Stewart and struck her 22 times. Mr Woods ran a defence of provocation, meaning that he accepted that he killed Ms Miller, but argued he was guilty of manslaughter, not murder. The only witness for the defence was Mr Woods. His evidence was that he did not know Mr Stewart and at the time of the offence he was in a relationship with Ms Miller. He said he would often visit Leeward Croft and, on 14 July 2005, he arrived, found Ms Miller in bed with Mr Stewart and “lost it”. On 9 July 2015, Mr Woods was convicted of murder and sentenced to death by hanging. Mr Woods appealed against his conviction and sentence, including on the ground that the judge had misdirected the jury as to the elements of the defence of provocation. On 14 December 2017, the Court of Appeal dismissed his appeal. On 10 June 2022, Mr Woods appealed to the Judicial Committee of the Privy Council arguing that a report from an expert psychiatrist he had obtained after his appeal supported a new defence of diminished responsibility. On 8 December 2022, the Judicial Committee refused Mr Wood’s application for leave to appeal on the grounds that the expert report recognised further psychological assessment needed to be carried out. However, the Board stated in its refusal that if further evidence did become available, the Board would reconsider the matter. Mr Woods has now obtained further expert reports. Additionally, on 26 June 2023, in Marcelline v The State the Court of Appeal overruled its previous decision in Mr Woods’s appeal in relation to the defence of provocation. Mr Woods therefore appeals for the second time to the Judicial Committee of the Privy Council.
Date of issue
28 March 2025
Case origin
PTA