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Summary
1. Chapter 1 presents the background to the research and an outline of the research methodology. The research was commissioned to look at the sentencing of serious violent and sexual offenders, with the aim of determining how offenders who are given discretionary life sentences differ from those who receive lengthy determinate sentences for similar offences. The main element of the research involved the examination of the prisoner files and court papers relating to: (a) 19 offenders who received discretionary life sentences; and (b) 19 offenders who received long determinate sentences (10 or more years).
2. Chapter 2 is mainly concerned with reasons for imposing a discretionary life sentence and, in particular, the importance attached to the question of whether there is a serious risk that an offender will commit a similar crime in the future. The significance of the length of the designated part in a discretionary life sentence is also discussed.
3. Chapter 3 looks at the reasons for imposing a long determinate sentence. This includes consideration of the reasons for imposing a long custodial sentence and the reasons for not imposing an indeterminate sentence. Again, much of the chapter focuses on the question of whether there is a serious risk that an offender will commit a similar crime in the future.
4. Chapter 4 draws together some of the main differences between the sample of offenders who received discretionary life sentences and the sample who received long determinate sentences.
Background
1.1 The MacLean Committee on Serious Violent and Sexual Offenders was established in March 1999. It was asked to make proposals for the sentencing, and future management and treatment, of serious violent and sexual offenders who may present a continuing danger to the public. The present research was commissioned by the Scottish Executive Justice Department to inform the MacLean Committee in its deliberations. The remit was to look at the sentencing of serious violent and sexual offenders with the aim of determining how offenders who are given discretionary life sentences differ from those who receive lengthy determinate sentences for similar offences.
Main legal provisions
1.2 A sentence of life imprisonment is the only available sentence for adult offenders convicted of murder. However, in relation to certain other offences a judge dealing with a case at the High Court of Justiciary has the power, but is not obliged, to impose a life sentence. A life sentence imposed in such circumstances is, in this report, referred to as a 'discretionary life sentence'. (This report is not concerned with mandatory life sentences.)
1.3 The Prisoners and Criminal Proceedings (Scotland) Act 1993 (the '1993 Act') placed an obligation on trial judges, when imposing discretionary life sentences, either to stipulate the period that the prisoner must serve in the interests of punishment (the 'designated part') or to state reasons for not stipulating such a period. The Appeal Court in the case of O'Neill v. H.M. Advocate1 pointed out that a prisoner has the right to have his/her case considered by the Parole Board once this punitive period expires, and that it is for the Parole Board, having regard to any danger which the prisoner may continue to pose to the public, to determine the actual date of release.
1.4 The 1993 Act also changed the rules governing the early release of determinate sentence prisoners so that all prisoners serving sentences of four years or more became eligible for parole at half sentence.
Research design
1.5 The main elements of the research design were determined by the Criminological Research Branch of the Scottish Executive Justice Department. It was decided that it should take the form of a comparative study of all (adult) discretionary life sentence prisoners sentenced between 1994 and 1998 and a similar number of determinate sentence prisoners convicted of serious violent and sexual offences who received sentences of 10 years or more during the same period. The starting point of 1994 was chosen to ensure that all of the prisoners were sentenced under the regime set up by the 1993 Act.
1.6 The Criminological Research Branch identified all discretionary life sentence prisoners sentenced during this period (a total of 19 offenders)2, together with a further 19 offenders sentenced, during the same period, to determinate sentences of at least 10 years. The second group of offenders represented only a partial sample of all offenders receiving such a sentence during that period, and was weighted in favour of offenders sentenced for serious sexual offences so as to reflect the fact that a high proportion of the 19 discretionary life sentence prisoners were sentenced for such offences.
1.7 The main task during the research was to examine any information, which might be relevant to the sentencing of the two samples of offenders, which was contained in the relevant prisoner files (held by the Scottish Executive Justice Department and the Scottish Prison Service (SPS)) or court papers (held by the High Court of Justiciary). It was not possible (during the time available) to trace the court papers for five of the offenders who received determinate sentences, but the court papers were examined in relation to the remaining offenders and prisoner files were examined in relation to all of the offenders. There was an element of duplication in the two sets of files and it was not felt that the inability to trace some of the court papers detracted significantly from the quality of information available for consideration.
1.8 The judge sentencing an offender should, both in relation to discretionary life sentences and long determinate sentences, prepare a report setting out the factors which led to the selection of the particular sentence. This report (the 'trial judge report') is generally prepared shortly after the offender is sentenced and is intended to inform the deliberations of the Parole Board when they come to consider the case. These reports formed a vital element of the research since it was decided that the consideration of reasons for imposing a particular sentence should focus on those factors which the various judges themselves put forward as being important. The relevant trial judge report was examined in relation to each of the 38 offenders.
1.9 Information was also gathered from any other relevant papers contained in the prisoner files and court papers (e.g. schedules of previous convictions, psychiatric reports and social enquiry reports). This allowed some of the information outlined in trial judge reports to be checked against the original source (e.g. where the trial judge stated that certain factors set out in a psychiatric report were important in determining sentence). It also enabled the research to investigate whether or not there were any factors which might have been thought relevant to sentencing but which were not highlighted by the trial judges.
Chapter 2: Discretionary life sentences
Offender sample
2.1 The 19 offenders receiving discretionary life sentences (all offenders receiving such sentences during the relevant period - see paragraphs 1.5 to 1.6 above) were all male. Fourteen of the offenders were sentenced for offences of a sexual nature, the other five being sentenced for serious violent offences (not involving a sexual element).
Reasons for imposing a discretionary life sentence
2.2 The following information, on reasons for imposing a sentence of life imprisonment, was taken from the reasons advanced by the trial judges themselves in the relevant trial judge reports (i.e. those prepared in relation to the 19 offenders receiving a discretionary life sentence). The trial judge should have considered both whether or not a life sentence was required and, if so, the appropriate length for the designated part. It is only those reasons which were advanced as justification for imposing a life sentence which are considered at this point.
Nature of the offence
2.3 The nature of the offence was highlighted in most cases. This included consideration of the nature of the act(s) committed by the offender and of the impact on the victim(s). It was apparent that the nature of the offence was considered relevant in more than one way. The serious nature of the offence was sometimes discussed in punitive terms (i.e. relating to the need for severe punishment). However, the nature of the offence was also highlighted as an indicator that the offender was likely to re-offend in a similar way in the future. Both approaches were used in a number of cases (sometimes both in the same case) although it was not always easy to determine the exact significance which the trial judge had placed on the nature of the offence.
2.4 The connection between the nature or seriousness of an offence and the question of punishment is probably clear enough. The connection between the nature of the offence and the risk of re-offending requires further clarification. The trial judge reports suggest at least two ways in which judges considered that it could be relevant to an assessment of the risk of re-offending. First, where an offenders was convicted of a series of analogous crimes (on the same indictment) spanning a number of years, the fact that he had continued to offend in the same way for a prolonged period was sometimes seen as evidence that there was an established pattern of offending which would be difficult to break. This tended to be highlighted in relation to offenders convicted of sexual offences. Second, an offender whose crime(s) appeared to be indiscriminate was sometimes thought to be at greater risk of re-offending. The latter point was illustrated where a trial judge stated:
'This was plainly a motiveless, random, mindless stabbing. That alone indicated the accused presented a significant threat to the public in general'
Previous convictions
2.5 Analogous previous convictions were highlighted by the trial judge in relation to nearly all of the offenders receiving discretionary life sentences. Such convictions were generally referred to in terms suggesting that they were seen as an indicator that the offender was more likely to re-offend in a similar way in the future. This fear was likely to be heightened if previous long determinate custodial sentences for similar crimes had not stopped him re-offending, particularly if he had re-offended shortly after release from a custodial sentence.
2.6 Previous convictions (particularly if they relate to analogous matters) may also be seen as relevant to the question of punishment. This is, for instance, apparent in the legislation relating to the determination of the appropriate length for the designated part in a discretionary life sentence (see paragraph 2.20 below). However, although the precise significance attached to previous convictions was not always wholly clear, they were generally referred to as an indicator of the risk of re-offending when the judge was giving reasons for imposing a life sentence.
Assessment of other professionals
2.7 Trial judges also referred to the views of other professionals in most cases where an offender was sentenced to life imprisonment. Psychiatric reports (normally prepared with a view to sentencing) were by far the most commonly referred to source, although the opinions of clinical psychologists and social workers were also considered.
2.8 Although psychiatric reports generally dealt with the question of whether the offender was (either at the time of the offence or at the time of the trial) suffering from a mental disorder amounting to legal insanity, the main focus of these psychiatric reports was an assessment of the reasons contributing towards the offending and the risk of re-offending. This was found to be the case when looking at both the psychiatric reports themselves and the discussion of those reports contained in the trial judge reports. (Most of the following points made in relation to psychiatric reports are also applicable to reports from clinical psychologists and social workers.)
2.9 The main factors which were discussed in relation to the risk of re-offending were: (a) any connection between alcohol abuse and offending; and (b) sexually aggressive or deviant attitudes and behaviour. Thus, the fact that an offender was an alcoholic coupled with the fact that his offending behaviour (generally involving crimes of violence) was associated with his being intoxicated was sometimes characterised as a factor suggesting that he might be more likely to re-offend in the future. Equally, an assessment that sexual offences were connected with well established sexually deviant attitudes was often seen as an indicator that an offender might re-offend in a similar way in the future. A serious risk of re-offending was generally said to exist where it was thought that the offender either could not, or would not, successfully tackle the problem (i.e. alcohol abuse or sexually aggressive attitudes or behaviour) within the foreseeable future. Psychiatric reports generally dealt with the possibility of change by considering factors such as the response of an offender to previous treatment or the willingness of an offender to recognise and deal with the problem. Psychiatric opinions on this point were normally (but not always) accepted in the trial judge reports.
2.10 It may be noted that consideration of the nature of the offence and, in particular, the existence of previous analogous convictions, frequently formed part of the assessment of the risk of re-offending contained in psychiatric reports. Thus, there was often some overlapping between the independent reasoning of a trial judge in relation to these factors and the assessment of a psychiatrist. However, the psychiatric assessment would (of course) take into account other factors (e.g. the views expressed by the offender during interview).
Mental illness
2.11 Only one of 19 offenders sentenced to life imprisonment was said to suffer from a treatable mental illness (only amounting to diminished responsibility at the time of the offence). The judge formed the view (mainly on the basis of psychiatric reports) that the offender presented a serious risk of re-offending when his illness was not being controlled by medication. The judge went on to state that a hospital order was not appropriate given that the offender's illness was being successfully controlled by medication. He was not, however, willing to rely on community-based medical support for the offender, given the risk he considered the offender would present should his mental health again deteriorate. He stated that a supervised release order would be inappropriate (too restricted in its application according to the judge's stated opinion) and that an indeterminate sentence was required to deal with the risk posed by the offender and to ensure the proper supervision of his medical needs.
Interests of the offender
2.12 The view that an indeterminate sentence would be in the best interests of the offender himself was advanced in relation to a few of the 19 offenders receiving a discretionary life sentence. There was generally little explanation of why this might be the case although there was some indication that a life sentence was sometimes seen as the best way of ensuring that the offender received long-term treatment and/or support.
The risk of re-offending
2.13 The decision to impose a life sentence was nearly always supported in the relevant trial judge report by more than one reason. However, it was clear that it was the risk of the offender committing a similar (and possibly more serious) offence in the future which was at the heart of the judges' decisions to impose discretionary life sentences (as opposed to long determinate sentences). The fact that a serious offence was committed was certainly a vital element in raising the possibility of imposing a life sentence (any lengthy sentence can only be justified if a serious crime has been committed and it is the risk of re-offending in a similar serious manner which is of concern), but it was this factor of risk which was emphasised when considering the choice between a long determinate sentence or a sentence of life imprisonment.
2.14 Trial judge reports generally contained little discussion of exactly why a life sentence was thought to be more appropriate than a long determinate sentence in relation to offenders who presented a high risk of re-offending. However, two factors were mentioned: (a) a life sentence meant that there was no fixed date on or before which the offender had to be released irrespective of assessments of the likelihood of him re-offending; and (b) a life sentence meant that, after release from custody, he would remain on a life licence, and thus liable to recall for the rest of his life, should his future behaviour justify such action.
2.15 It was noted above that 14 out of the 19 offenders sentenced to life imprisonment had committed crimes of a sexual nature. The fact that there was such a high representation of offenders sentenced for sexual offences probably reflected a view that such offenders are, due to the nature of sexual offending, more likely to re-offend in a similar manner in the future than is the case for offenders convicted of other crimes.
2.16 In relation to the offenders sentenced for serious crimes of violence (not involving a sexual element), it was notable that, in relation to four of those offenders, a link between offending behaviour and chronic alcohol abuse was a factor in the assessment that there was a serious risk of re-offending. Mental health problems were a factor in this assessment of risk for the remaining offender sentenced for serious crimes of violence.
Influence of the judge
2.17 Although it seems reasonable to suppose that different trial judges will have different views on exactly when a discretionary life sentence should be imposed, the information available to this research did not disclose significant differences in the approach to the question of whether a life sentence should be imposed. Concerns about the risk of re-offending appeared to be central to the reasoning of all of the trial judges. This does not, of course, mean that different judges could not reach different conclusions (the sometimes complex process of determining the level of risk and then balancing that risk against other relevant factors may certainly result in different judgements), but the general approach appeared to be similar.
2.18 It was discovered that one judge had sentenced three of the offenders receiving a discretionary life sentence and that another had sentenced two of them. It is not, however, possible to comment on whether these facts say anything about the likelihood of the judges concerned imposing a discretionary life sentence since information on the numbers and types of cases dealt with by those judges (as compared with the 'average workload' of a High Court judge - if there is such a thing) was not available.
Appeals against the imposition of a life sentence
2.19 Five of the offenders sentenced to life imprisonment appealed against the imposition of a life sentence3. The sample was originally selected (by the Criminological Research Branch of the Scottish Executive Justice Department) so as to exclude any offenders who had successfully appealed against a life sentence and thus all of the appeals, at least in so far as they concerned the life element of the sentence, were unsuccessful. However, it is worth noting that the Appeal Court gave clear support for the view that a discretionary life sentence was justified where there was an assessment that an indeterminate sentence was required to protect the general public (or particular groups of people such as women or children) from similar offending behaviour in the future. Thus, the Appeal Court decisions supported the view that the assessment that an offender presents a serious risk of re-offending in the future is central to the decision to impose a life sentence.
The designated part
2.20 It was noted in Chapter 1 (at paragraph 1.3) that the 1993 Act placed an obligation on trial judges, when imposing discretionary life sentences, either to stipulate the period that the prisoner must serve in the interests of punishment (the 'designated part') or to state reasons for not stipulating such a period. The significance of the designated part is that a prisoner has the right to have his/her case considered by the Parole Board once this punitive period expires. In relation to the length of the designated part, Section 2(2) of the 1993 Act states that it should be:
'such part as the court considers appropriate taking into account -
(a) the seriousness of the offence, or of the offence combined with other offences associated with it;
(b) any previous convictions of the designated life prisoner.'
2.21 Given the above, one might, by looking at the length of the designated part, hope to gain some further insight into how a trial judge sentencing an offender to life imprisonment viewed the seriousness of the factors set out in Section 2(2). A wide range in the lengths of the designated part set for each of the 19 life sentence offenders might support the view that factors, other than those set out in Section 2(2), can be more important in relation to the decision to impose a discretionary life sentence. This view might receive further support if it was also found that the length of the designated part was sometimes significantly shorter than the length of long determinate sentences.
2.22 Unfortunately, comparisons between the length of the designated part imposed in relation to one offender with either: (a) the length of the designated part imposed in relation to another offender; or (b) the length of a determinate sentence imposed in relation to another offender, are not as straightforward as one may have anticipated. This is due to the fact that a number of the offenders in the sample successfully appealed against the length of the designated part. The relevant Appeal Court judgements did help to clarify the factors which should be taken into account in determining the length of the designated part. In particular, the Appeal Court in O'Neill v. H.M. Advocate4 stated that the length of the designated part should bear a fair and reasonable relationship to the minimum period which an offender would actually have served in custody had a determinate sentence been imposed in similar circumstances. The Appeal Court pointed out that, under the terms of the 1993 Act, an offender serving a determinate sentence of four or more years may, on the recommendation of the Parole Board, be released on licence after serving one half of his sentence. This does suggest that it should be possible to compare the lengths of the designated part, in the discretionary life sentence sample, with one half of the lengths of the determinate sentences in the long determinate sentence sample. However, difficulties arise due to the fact that it was not possible to determine to what extent, if any, the length of the designated part for other offenders in the discretionary life sentence sample reflected a similar approach. Trial judge reports generally contained little explanation as to exactly how the length of the designated part had been determined.
2.23 Bearing in mind the need for caution when drawing comparisons, it is still worth noting that: (a) there was a wide variation in the lengths of the designated part set in relation to the 19 offenders receiving discretionary life sentences (between 3 and 15 years); and (b) there were some examples of offenders receiving a life sentence with a designated part which was less than one half of the length of some of the long determinate sentences.
Chapter 3: Long determinate sentences
Offender sample
3.1 The 19 offenders receiving long determinate sentences (defined, for the purposes of this research, as prison sentences of 10 or more years - see paragraph 1.5 above) were all male. Ten of the offenders were sentenced for offences of a sexual nature, the other nine being sentenced for serious violent offences.
Reasons for imposing a long determinate sentence
3.2 The following information on reasons for imposing a long determinate sentence of imprisonment was taken from the reasons advanced by the trial judges themselves in the relevant trial judge reports (i.e. those prepared in relation to the 19 offenders receiving a long determinate sentence).
Decision to impose a long custodial sentence
3.3 The very serious nature of the offences involved was, not surprisingly, generally cited among the reasons for imposing a long custodial sentence. The other factor which was referred to in relation to most of the offenders was the existence of previous analogous convictions. These factors were more frequently discussed in terms relating to the appropriate level of punishment for what had happened (rather than as indicators of the likelihood of re-offending) than was the case in relation to the offenders who were given discretionary life sentences.
Decision not to impose a sentence of life imprisonment
3.4 Although a few of the trial judge reports, prepared in relation to offenders receiving long determinate sentences, did include some discussion (and rejection) of the possibility of imposing a life sentence, the majority did not. This does not necessarily mean that a discretionary life sentence was not considered. It does, however, make the task of identifying any reasons for not opting for a life sentence more difficult.
3.5 It is possible that some of the offenders who received long determinate sentences might have received discretionary life sentences if their crimes had been even more serious. However, it has already been suggested (e.g. see the points made in relation to the length of the designated part at paragraphs 2.21 to 2.23 above) that any distinction between the life sentence and determinate sentence samples does not appear to centre on the seriousness of the offences involved.
3.6 Different opinions on the likelihood of the offender committing similar crimes in the future would appear to be a more promising basis for distinguishing the samples. It was noted in Chapter 2 (at paragraph 2.13) that the assessment that there was a serious risk of an offender committing a similar offence in the future appeared to be central to judges' decisions to impose discretionary life sentences in preference to long determinate sentences. However, this does not mean that the risk of re-offending was always thought to be low where the decision was taken not to impose a life sentence. This point was clearly illustrated by the following statement from a trial judge dealing with an accused convicted of the indecent assault of a young child:
'It is plain, from a consideration of his record and the reports before me and his behaviour during the preparation of these reports, that he has an aggressive violent streak in him which, combined with his inability to distinguish right from wrong and his lack of regard for the law, makes him a public danger. He is clearly capable of being violent in the most incredibly depraved ways. The offence itself was an extremely serious one. As punishment for that alone he required to be imprisoned for a significant number of years. In addition, I had to consider the need to protect the public from him. I considered whether it was necessary to impose a sentence of life imprisonment to provide that protection, but decided that was not necessary.'
3.7 Nevertheless, concerns about the likelihood of the offenders, who received long determinate sentences, committing further similar offences in the future were not expressed with the same regularity as was found in the trial judge reports relating to the offenders who received life sentences. Most frequently (in relation to approximately one half of the offenders) the relevant trial judge report made little or no mention of the risk of re-offending where a determinate sentence was imposed. This does not, however, mean that there was no such risk. It has already been noted (at paragraph 3.3) that one of the factors which was referred to in relation to most of the offenders receiving long determinate sentences was that they did have previous analogous convictions. In fact, it would be very difficult to say that one of the sample of offenders (i.e. either those receiving life sentences or those receiving long determinate sentences) generally exhibited a worse record of previous convictions than that found in relation to the other. Given that fact, it seems fair to say that many of the offenders who were given long determinate sentences did, even where the issue was not highlighted in the relevant trial judge report, present some risk of re-offending in a similarly serious manner. It was not possible, in these cases, to determine whether the judge: (a) decided not to mention the risk of re-offending because the future risk (following a long determinate sentence) was considered to be reasonably low; or (b) considered that there was no need to address the issue because he had not imposed a life sentence.
3.8 Psychiatric reports, obtained to assist the trial judge in sentencing, were found with the papers relating to approximately one third of the sample of offenders receiving long determinate sentences. This is in contrast to the sample of offenders receiving a discretionary life sentence, where a psychiatric report (or similar) was found in most cases. However, both samples were similar in that the main focus of such reports was an assessment of the reasons contributing towards the offending and the risk of re-offending. It is possible that psychiatric reports were obtained less frequently in relation to offenders receiving determinate sentences precisely because they were less likely to be thought of as posing a serious future risk and thus an additional assessment of that risk was thought to be unnecessary. There was, however, no way in which this could be confirmed during the research. It was also impossible to say whether or not the existence of a psychiatric report might have altered any assessment of the risk of re-offending.
3.9 Although it was not always clear whether or not an offender receiving a long determinate sentence was considered likely to re-offend in a similar way in the future, there were some cases where the trial judge did express a view on this point. It has already been noted that some offenders receiving long determinate sentences were thought to present a serious risk of re-offending (see paragraph 3.6 above). Such an assessment was expressed in relation to approximately one third of the 19 offenders. However, unlike the sample of offenders receiving discretionary life sentences, there were also a few cases where the trial judge clearly stated that he did not believe that the offender posed such a risk. The most clear statement of this was in relation to an offender sentenced for the culpable homicide of his common law wife. The judge clearly formed the view that the offence had arisen from circumstances which were not likely to occur again and that the offender did not present a danger to the public. A long determinate sentence was, however, considered necessary in view of the serious nature of the offence.
3.10 The determinate sentence sample also included one case (involving an offender sentenced for various sexual offences) where the trial judge report suggested that the judge accepted views expressed in a psychiatric report to the effect that there was a reasonable chance that treatment and supervision could prevent future analogous offending. In contrast, it was notable that the psychiatric reports obtained in relation to the offenders who subsequently received discretionary life sentences tended to be less optimistic about the chances of treatment/support dealing with problems (e.g. alcohol abuse or sexually deviant attitudes) which were contributing towards the offending behaviour.
Chapter 4: Overview and conclusions
4.1 The research looked at the sentencing of serious violent and sexual offenders, with the aim of determining how offenders who are given discretionary life sentences differ from those who receive lengthy determinate sentences for similar offences.
Discretionary life sentences
4.2 The nature of the offence; the existence of analogous previous convictions; and the opinions of other professionals (primarily contained in psychiatric reports), were generally highlighted by trial judges when giving reasons for imposing life sentences.
4.3 The common factor, underlying the various reasons advanced by trial judges for imposing life sentences, was that they were primarily considered with a view to assessing the likelihood of the offender committing a similar crime in the future.
4.4 Of the 19 offenders sentenced to life imprisonment, 14 had committed crimes of a sexual nature. The fact that there was such a high representation of offenders sentenced for sexual offences probably reflected a view that such offenders are, due to the nature of sexual offending, more likely to re-offend in a similar manner in the future than is the case for offenders convicted of other crimes. In relation to the remaining five offenders, all sentenced for serious crimes of violence (not involving a sexual element), it was notable that a link between the offending behaviour and either chronic alcohol abuse or mental health problems was a factor in the assessment that there was a serious risk of re-offending.
Long determinate sentences
4.5 The serious nature of the offences involved and the existence of analogous previous convictions were the main reasons advanced by trial judges when imposing long determinate sentences. However, trial judge reports tended to contain much less discussion about the risk of the offenders involved committing similar offences in the future. Instead, a judge was more likely to highlight the seriousness of an offence or a bad record of previous analogous convictions as support for imposing a sentence with a long punitive element.
4.6 The fact that trial judge reports tended to contain less discussion of the risk of re-offending did not mean that the issue was never highlighted in relation to offenders who received a determinate sentence. Indeed, there were several instances where a trial judge stated that an offender did present a danger to the public but nevertheless decided not to imposed a life sentence. It was clear that the decision to impose a determinate sentence, rather than an indeterminate one, was sometimes a difficult one.
4.7 In contrast to the sample of offenders who received discretionary life sentences, there were a few cases where the trial judges clearly stated that they did not believe that the offender in question was likely to re-offend in a similar way in the future.
4.8 Psychiatric reports were less likely to be obtained in relation to offenders who subsequently received determinate sentences.
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