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Due process and parole in Queensland: The case of Lex Wotton
by Alisa Wicks
When the Palm Island community were informed of the autopsy results into Palm Island resident Mulrunji’s death, tension quickly escalated. The investigation into the death in custody had, in the community’s eyes, been far from satisfactory.[1] On 19 November 2004, Mulrunji had been arrested for offensive language, and during his forty minute stay in custody he suffered injuries including a black eye, broken ribs and ruptured liver. The autopsy report concluded that these fatal injuries were caused by an accidental fall on a step four inches high.[2]
One week after Mulrunji’s death, Mayor Erica Kyle addressed the community, urging them to accept the pathology report. Lex Wotton, a former member of the Palm Island Community Council, also addressed the crowd gathered at the Mall.[3] Angry and distressed, people walked towards the police station, yelling at police and throwing stones and mangoes. In the next three hours, the police station, barracks and court house were burnt down.
The Department of Public Prosecutions construed Wotton’s speech that day as a ‘call to arms’, resulting in him being convicted as the ‘principal’ of the riot[4] by an all-white jury in November 2008.[5] He was sentenced to six years in jail with two years non-parole for rioting causing damage to a building,[6] an offence which carries a maximum sentence of life imprisonment. The offence requires proof both of riot and destruction of a building, together with proof against the particular accused of participation in the offence charged.[7]
On 19 July 2010, Lex Wotton was released on parole after 19 months in prison. However, the case continues to be the subject of controversy due to the nature of Wotton’s parole conditions, which include bans on speaking to the media, attending public meetings without approval and gambling or attending venues where gambling is conducted.[8] This article explores the parole process in Queensland and existing human rights protections in Australia, in order to assess the validity of the conditions imposed on Wotton. It is argued here that they are unfairly punitive in character and appear to infringe particular human rights.[9]
To analyse the extent to which Wotton’s parole conditions are inappropriate or excessively punitive, it is useful to define the legislative framework of parole in Queensland and compare it to another jurisdiction; in this case, New South Wales. Queensland Corrective Services expressly state that the purpose of parole conditions is to protect the community and to help offenders get back on track.[10] Pursuant to the Corrective Services Act 2006 (Qld) (Queensland Act), the Queensland Parole Board (Board) considers applications for parole made by offenders serving terms of more than three years, sex offenders and serious violent offenders.[11] The Board reviews the prisoner’s submission, a report prepared by corrective services staff and statements from victims.[12] They may take into account the nature of the offence, the prisoner’s criminal history, any relapse prevention plan and specialist reports, the level of community support and the likely effect of release on the victim.[13]
Alongside a number of standard conditions, the Board imposed on Wotton special conditions relating to media contact, attending meetings and gambling. Although not mandatory, the Parole Board Guidelines stipulate that ‘if you are considering recommending parole, you need to consider special conditions’.[14] In prescribing these conditions, the Board must consider if they are ‘reasonably necessary’ to ensure the prisoner’s good conduct or to stop the prisoner committing an offence.[15]
Given that these conditions may be significantly restrictive and that there are harsh consequences for breach, there is surprisingly little direction available to guide the Board in the exercise of its discretion. There is no guidance provided in the Queensland Act as to what to consider when determining whether a condition is ‘reasonably necessary’ and the purposes of requiring special conditions are broadly defined.[16] The Queensland Act suggests special conditions that concern a prisoner’s place of residence, employment or participation in a program.[17] Notably, no conditions refer to the media or gambling. The Parole Board Guidelines provide some extra direction, stating that ‘parole with strict conditions would be appropriate for those offenders who require a gradual reintegration back into the community’.[18]
It is argued here that the test of ‘reasonably necessary’ does not impose a sufficient limit on the creative license granted to the Board, who are unelected and not directly accountable to the public.[19] The establishment of community corrections boards in Queensland was first recommended in 1988,[20] to bring decision-making ‘closer to the communities to which the offender returns’.[21] However, the Palm Island community’s serious dissatisfaction with the conditions imposed suggests that, contrary to this stated purpose, they were not adequately involved in the Board’s decision-making.
The NSW Parole Authority (Authority) appears to be given slightly more guidance than its Queensland counterpart. The Crimes (Administration of Sentences) Act 1999 (NSW) (NSW Act) indicates factors to consider when determining whether release is in the ‘public interest’.[22] The 2008 Annual Report of the Authority also explains that additional conditions will be selected to protect victims and meet post-release plans and long-term supervision requirements.[23] In contrast to the five examples given in the Queensland Act, the 2008 Annual Report provides 25 non-exhaustive, additional conditions.[24] It should be noted that whilst gambling is mentioned, none of the example conditions in either statute refer to media contact.
Prisoners are a vulnerable population with limited bargaining power and few remedies. While Queensland prisoners may be represented by an ‘agent’, this person is engaged by Corrective Services and cannot be a lawyer.[25] By comparison, lawyers from the NSW Prisoners Legal Service represent prisoners at parole hearings.[26] Lack of representation may exacerbate the helplessness of prisoners ‘who because of their limited communication skills or their cultural or linguistic background are unable to represent themselves effectively’.[27] This is also likely to compound the disadvantage of Indigenous peoples, who constitute 30% of the Queensland prison population[28] and have statistically lower literacy levels.[29] The 2005 Review of the Corrective Services Act 2000 (Qld)[30] (2005 Review) reported ‘a need for lawyers to be able to represent prisoners at Board meetings’ as part of the sentencing process to allow for procedural fairness; this was not adopted in the 2006 amendments.[31]
Whereas the NSW Act provides that offenders may make oral submissions in regard to their release,[32] there is no provision in the Queensland Act for oral submissions to the Board.[33] A 2008 investigation into Queensland prisoner literacy revealed that 81% of male offenders and 50% of female offenders have literacy levels of NRS2 or lower.[34] Similarly, Peter Collins, Director of Legal Services at the WA Aboriginal Legal Service, describes the literacy levels of many Aboriginal prisoners in WA as limited to being able to write only their name when filling out a form.[35] As such, prisoners may not be able to make a written request for an agent at the time of their parole application[36] and may be reluctant or unable to seek an amendment of conditions imposed.[37] Only in rare circumstances will a prisoner be granted leave to appear before the Board.[38] While the 2005 Review noted submissions that ‘personal appearances may disadvantage prisoners from other cultures or with limited language skills’,[39] other responses maintained that prisoners should be entitled to make an oral submission in person.[40] Again, this was not adopted in the 2006 legislation.
Review under the Queensland Act is only available to amend, suspend or cancel parole conditions if prisoners can establish that the condition is not necessary to ensure their good conduct or to prevent reoffending.[41] In contrast, NSW offenders may request a review hearing on any aspect of their parole order.[42] Furthermore, while NSW offenders are entitled to make submissions, the Queensland Board is only required to give the prisoner notice and a ‘reasonable opportunity’ to be heard ‘if practicable’.[43] The Explanatory Memorandum to the Corrective Services Bill 2006 (Qld) notes that ‘this possible breach of the fundamental legislative principle of natural justice must be balanced against the need to make decisions ensuring the immediate safety of the prisoner ... or the community’.[44]
The lack of public access to parole orders may further limit Wotton’s ability to challenge his order. In contrast to the New Zealand Parole Board, which publicises decisions of public interest online, decisions by Australian parole boards are not available to the public, minimising their accountability. Prisoners could make a request pursuant to the Freedom of Information Act 1992 (Qld), but they are still likely to be hampered by the barriers outlined above. While the rights of prisoners such as Wotton are appropriately restricted to reflect the punitive and deterrent purposes of their status,[45] one could argue that this should not extend to these types of restrictions on their access to due process within the legal system.
Current Palm Island Mayor Alf Lacey has publicly questioned the benefit of Wotton’s parole order, arguing that it will restrict his ability to ‘fit into the community again’.[46] Community leader Rob Blackley has similarly told media that Wotton is ‘being denied a political voice and the ability to contribute’.[47] The anger and sense of oppression felt by the community is further reflected by Gracelyn Smallwood from the Townsville Indigenous Human Rights Committee, who insists that Queensland is the only state that does not allow parolees to talk to the media.[48]
The Queensland government has repeatedly defended the conditions.[49] A spokesman for the Queensland government responded to claims that Wotton’s conditions are unfair by stating ‘there is nothing unusual about the no media access condition on a parole order. It is a standard part of the legislation and applies to all people under a parole order’.[50] However, as discussed above, neither the Queensland Act, nor the Board Guidelines or the Probation and Parole booklet refer to media bans.[51] The NSW legislation and Parole Authority guidelines[52] are similarly silent on restricting contact with media. There is an understandable link between Wotton’s conviction for rioting and the condition preventing him from attending public meetings; however, the gambling and media restrictions are not as clearly related.
Further, these conditions were arguably not ‘reasonably necessary’ at the time of Wotton’s release on parole, as the riot occurred in a highly specific context: shortly after Mulrunji’s death, as a response to the autopsy results and in an atmosphere fraught with grief and a sense of grave injustice. At Wotton’s trial, Shanahan J found that ‘the background to this matter is not particularly relevant for the purpose of the sentence … as rioting is so intrinsically dangerous that no circumstances could warrant consideration’.[53] However, courts have previously found context to be highly relevant. For example, in 1987, the NSW Court of Criminal Appeal held that a recent death in custody was a relevant and mitigating factor to setting aside convictions of riotous assembly and assault.[54] Professor Thalia Anthony argues that by denying the context in Wotton’s trial, ‘the Court could not properly recognise that the community anger was a reaction not only to the death of an Indigenous man in police custody but also the product of much deeper, long running, tension in Indigenous-police relations.’[55] This focus on the offence as divorced from the reason ‘demonises Indigenous people as criminal and situations the police in the position of the victim’.[56]
The circumstances surrounding Wotton’s parole conditions are important and distinct from the (largely discounted) context of the riot in 2004. Wotton remains the only person to have been punished for the events surrounding Mulrunji’s death. Smallwood insists that the conditions imposed on Wotton ‘muzzle the truth about justice against Indigenous peoples in Queensland’.[57] They are strikingly disproportionate to the extensive opportunity that the police have had to defend their case during three coronial inquiries. While the Palm Island community remain angry and dissatisfied with the investigation, six years have passed since the incident and these severe conditions are not ‘reasonably necessary’ to Wotton’s good conduct as an otherwise upstanding and involved community member.[58] The only highly publicised case where conditions of a similar nature were mandated was that of David Hicks, who was also ordered not to speak to media pursuant to a control order under the Anti-Terrorism Act 2005 (Cth) on his return to Australia from Guantanamo Bay. As Community leader Rob Blackley says, ‘Lex Wotton is certainly no terrorist’.[59]
Despite the limited options for appealing Board decisions under the Queensland Act, the order may nevertheless be contested as breaching human rights pursuant to the Australian Constitution and international law ratified by Australia.
In the absence of a Bill of Rights, Australians have limited sources of protection. Wotton may be able to challenge the constitutional validity of his parole order on the grounds that it is a legislative or executive breach of the implied freedom of political communication in ss 7 and 24 of the Constitution.[60] The scope of political communication is broadly defined to include discussion of political parties, public office and discussion of the views and public conduct of persons who are engaged in activities subject to political debate.[61] Pursuant to this, Wotton should arguably be able to speak to the media about the ‘political’ debates surrounding his conviction and Mulrunji’s death in custody.
The imposition of a media gag takes away the individual’s voice and indeed that of the community, for whom the silenced person is an advocate. Professor Don Rothwell argues that the imposition of similar conditions on David Hicks may have been an unconstitutional breach of the right to freedom of political communication.[62] However, it is worth noting that this implied freedom does not permit a general freedom of speech. According to Professor George Williams:
[the] freedom of political communication has an institutional rather than individual foundation in that it is designed to facilitate the operation of representative government and not, except incidentally, to promote the general welfare of the individual.[63]
This may limit the justiciability of a claim brought by Wotton before the Court pursuant to this right.
Wotton's lawyer and director of the Black and White Justice Foundation, Stewart Levitt, argues that the conditions are unusual for a ‘former politician and public spokesman’ and breach international human rights law.[64] While there is no international treaty dealing solely with the rights and treatment of prisoners,[65] there are unenforceable instruments[66] which may be influential in this regard. Principally, the UN Body of Principles for the Protection of Detained or Imprisoned Persons (UN Principles) outline the right of prisoners to be given an adequate opportunity to communicate with the outside world, subject to reasonable conditions and restrictions by law.[67] The UN Principles also stipulate that imprisonment can only be effected by a judicial or other authority under the law, with the strongest possible guarantees of competence, impartiality and independence.[68] An unelected parole board may fall short of these criteria and the restriction on Wotton’s right to communicate may be beyond the power of the Board; however, the UN Principles remain unenforceable.
Wotton may nevertheless have a claim for breach of the International Covenant on Civil and Political Rights (ICCPR),[69] which protects the right to freedom of expression, including the ‘freedom to seek, receive and impart information and ideas of all kinds’.[70] While the freedom is restricted as far as is necessary to, inter alia, protect national security, public order, public health or morals,[71] for the reasons outlined above, restricting Wotton’s right to communicate is arguably not necessary to achieve these aims and his right to freedom of expression should still be afforded protection. However, despite ratifying the ICCPR in 1980,[72] free speech provisions are yet to be incorporated into Australian law and therefore they are not enforceable domestically.[73] Internationally, Australia acceded to the First Optional Protocol to the ICCPR,[74] so Wotton may bring a human rights complaint before the UN Human Rights Committee (UNHRC). However, the New South Wales Council for Civil Liberties reports that despite 17 findings by the UNHRC of breach by Australia of the ICCPR, three have been ignored and responses to six are still pending.[75] One can see that successful reliance on international law for a remedy may be limited.
Ordering Wotton to ‘bite his tongue’ appears to be another attempt by the Queensland Government to protect its own interests in the investigations surrounding Mulrunji’s death. It is unfortunate and ironic that their vehicle for doing so is through parole, which is intended ‘to help offenders get their lives back on track’.[76] Wotton’s case highlights the lack of candour in the Queensland parole system and the limited rights of prisoners as a vulnerable population. This is exacerbated by the minimal human rights protection in Australia. Whilst the Queensland Government insists that the conditions imposed on Wotton are standard, they appear unnecessary, inappropriate and in stark breach of human rights, compounding the sense of oppression felt by the Palm Island community and increasing hostility towards the instruments of justice.
Alisa Wicks is in her final year of a Combined Bachelor of Social Work/Law at the University of New South Wales. Alisa completed a Social Justice Internship at the Indigenous Law Centre in 2010.
[1] ABC Radio National, ‘The Sentencing of Lex Wotton’, The Law Report, 11 November 2008 (Damien Carrick) <http://www.abc.net.au/rn/lawreport/stories/2008/2416076.htm> .
[2] Ibid. See also Office of the State Coroner, Finding COR 2857/04(9), 14 May 2010, [354].
[3] Black and White Justice Foundation, Defending Lex Wotton (2009) <www.blackandwhitejustice.org.au/campaigns>.
[4] Ibid.
[5] ‘Activists fight for Wotton’s freedom’, ABC News (online), 27 October 2008 <http://www.abc.net.au/news/stories/2008/10/27/2401796.htm> .
[6] Criminal Code 1899 (Qld) s 65.
[7] R v Wotton [2007] QDC 181, [10], (Nase DCJ); The Queen v Lex Patrick Wotton, 07/11/2008 Townsville District Court, Shanahan J.
[8] Robyn Ironside, ‘Palm Island riot ringleader Lex Wotton set free but banned from speaking to media’, The Courier Mail (online), 19 July 2010 <http://www.couriermail.com.au/news/queensland/palm-island-riot-ringleader-lexwotton-set-free-but-banned-from-speaking-to-media/storye6freoof-1225893772320> .
[9] International Covenant on Civil and Political Rights, opened for signature, ratification and accession by General Assembly resolution 2200A (XXI) of 16 December 1966 (entered into force 23 March 1976) art 19; Australian Consitution ss7, 24: implied right of political communication per Lange v Australian Broadcasting Commission [1997] HCA 25; (1997) 189 CLR 520, 560.
[10] Queensland Parole Boards, Queensland Corrective Services, Annual Report 2007/2008 (2008), 4.
[11] Queensland Corrective Services, Queensland Corrective Services, Probation and Parole (2007), 2.
[12] Queensland Parole Boards, Queensland Corrective Services, Annual Report 2008/2009 (2009), 9.
[13] Ibid.
[14] Queensland Corrective Services, Parole Board Assessment Report Guidelines (October 2009), 11.
[15] Corrective Services Act 2006 (Qld) ss 200(a)–(b).
[16] Under s 200(2) Corrective Services Act 2006 (Qld).
[17] Ibid.
[18] Queensland Corrective Services, above n 15.
[19] See Corrective Services Act 2006 (Qld) s 218 regarding membership of parole boards. Appointments to parole boards have been controversial in Western Australia, where a new appointment by the Attorney General has reportedly coincided with an increase in parole refusals. See Christian Porter ‘Supreme Court Judge heads up review board’, (Media release 2 April 2009) <http://www.mediastatements.wa.gov.au> ABC Radio National, ‘WA’s Prisoner Review Board’, The Law Report, 27 July 2010 (Damien Carrick) <http://abcaustralia.net.rn/lawreport> .
[20] Commission of Review into Corrective Services in Queensland, Final report, (Brisbane, 1988).
[21] Queensland, Parliamentary Debates, Legislative Assembly, 23 May 2006, 1843. Note: ‘Prior to the promulgation of the Corrective Services Act 1988, the Queensland Parole Board was the only authority in the state with the legislative power to release prisoners on parole. In order to involve the community in the decision making process relating to the release of prisoners, the Commission of Review recommended the abolition of the Queensland Parole Board and the introduction of a two-tier system of Community Corrections Boards.’ Ross Evans, ‘Increased utilisation of community based corrections in Queensland,’ in S McKillop (ed) Keeping people out of prison: Proceedings of a conference held 27-29 March 1990 (Australian Institute of Criminology, 1991).
[22] Crimes (Administration of Sentences) Act 1999 (NSW) s135(2). Factors include the need to protect the safety of the community and, maintain public confidence in the administration of justice, and the likelihood of the offender being able to adapt to normal lawful community life.
[23] NSW State Parole Authority, NSW Department of Corrective Services, Annual Report 2008 (2008), 41.
[24] Ibid, 42.
[25] Corrective Services Act 2006 (Qld) s 4.
[26] NSW Prisoners Legal Service, <http://www.legalaid.nsw.gov.au> .
[27] Queensland Corrective Services, Review of the Corrective Services Act 2000: Consultation Report for the Minister of Police and Corrective Services, the Honourable Judy Spence MP, 16 June 2005, 26.
[28] Department of Community Safety Queensland, ‘Annual report 2009-2010’, 53.
[29] S Mellor and M Corrigan, ‘The Case for Change, a review of contemporary research on Indigenous education outcomes’, (Australian Council for Educational Research 2005), 2.
[30] Queensland Corrective Services, above n 27.
[31] Corrective Services Act 2006 (Qld) replaced Corrective Services Act 2000 (Qld).
[32] Crimes (Administration of Sentences) Act 1999 (NSW) 140(2).
[33] Corrective Services Act 2006 (Qld) ss 180-189.
[34] The National Reporting System (NRS) is a framework that allows for the reporting of levels of English language, literacy, and numeracy competence (Levels 1-5) across six social aspects of life. See Jean Searle et al, Literacy Unbarred: Investigating the literacy and numeracy levels of prisoners entering Queensland correctional centres, (Griffith Institute for Educational Research 2008), 5.
[35] ABC Radio National, ‘Indigenous incarceration in WA’, The Law Report, 10 August 2010 (Damien Carrick) <http://www.abc.net.au/rn/lawreport> .
[36] Pursuant to form 29.
[37] Note: there are no publicly available statistics regarding the frequency of challenges to parole conditions in Queensland.
[38] Corrective Services Act 2006 (Qld) s 189(5). Note that in 2009 the Western Australia Parole Board found that video link up appearances by prisoners compromised objectivity. The chairperson of the Board interpreted the review provision s115A(7) Sentence Administration Act 2003 (WA) as requiring requests for review to be in writing and prisoners are no longer entitled to appear personally or by video link up. See Prisoners Review Board, Annual report for the year ending 30 June 2009, (2009) 7; ABC Radio National, above n 19.
[39] Queensland Corrective Services, above n 27.
[40] Ibid.
[41] Corrective Services Act 2006 (Qld) s 205.
[42] Crimes (Administration of Sentences) Act 1999 (NSW) s 139(4).
[43] Crimes (Administration of Sentences) Act 1999 (NSW) s 205(3).
[44] Explanatory Memorandum, Corrective Services Bill 2006 (Qld), 6.
[45] This is the position adopted by the Scrutiny of Legislation Committee, Parliament of Queensland, Alert Digest, No 10 of 2000, referred to in Explanatory Memorandum, Corrective Services Bill 2006 (Qld), 36.
[46] Ironside, above n 8.
[47] Ibid.
[48] ‘Gag order imposed as Palm Island rioter Lex Wotton is released on parole’, AAP (online), 19 July 2010 <http://www.theaustralian.com.au/news/nation/gag-order-imposed-aspalm-island-rioter-lex-wotton-is-released-on-parole/storye6frg6nf-1225894102403> .
[49] ‘Wotton: stay gagged or in prison’, National Indigenous Times (Australia), 19 July 2010.
[50] AAP, above n 48.
[51] Queensland Corrective Services, above n 11.
[52] NSW State Parole Authority, Operating Guidelines, (April 2005) <http://www.paroleauthority.nsw.gov.au/Guidelines_and_Conducts> .
[53] The Queen v Lex Patrick Wotton, 07/11/2008 4-5.
[54] R v Murray, R v Bates [1991] (New South Wales Court of Criminal Appeal, unreported, 6 April 1992). See Tahlia Anthony, ‘Sentencing Indigenous resisters as if the death in custody never occurred’, (Paper presented at the Australia and New Zealand Critical Criminology Conference 2009) 6-18.
[55] Tahlia Anthony, ‘The Disavowal of Context: Sentencing Lex Wotton’, (2009) 7(10) Indigenous Law Bulletin, 7.
[56] Ibid.
[57] ABC, ‘Qld Government accused of gagging activist’, Lateline, 19 July 2010 (Kim Lyell) <http://www.abc.net.au/lateline/content/2010/s2958401.htm> .
[58] In sentencing Wotton, Justice Shanahan noted that he had ‘been actively involved in the Palm Island Men’s Group, in an alcohol and drug rehabilitation program, and also in a program aimed at assisting young people and addressing suicide problems in the community.’ The Queen v Lex Patrick Wotton, 07/11/2008 [14].
[59] Ironside, above n 8.
[60] Lange v Asutralian Broadcasting Commission [1997] HCA 25; (1997) 189 CLR 520, 560. See also G Williams, Human rights under the Australian Constitution (Oxford University Press, 2002), 63.
[61] Theophanous v Herald & Weekly Times Ltd [1994] HCA 46; (1994) 182 CLR 104,124 per Mason CJ, Toohey and Gaudron JJ.
[62] Mark Coulton and Penelope Debelle, ‘Hicks gag my idea, says US general’, The Age, (Melbourne) 5 April 2007.
[63] Williams, above n 60, 168.
[64] AAP, above n 48.
[65] M Groves (2001) ‘International law and Australian prisoners’. 24(1) University of New South Wales Law Journal, 34.
[66] United Nations Standard Minimum Rules for the Treatment of Prisoners (1957) ESC Res 663C, UN Doc E/3408; UN Body of Principles for the Protection of Detained or Imprisoned Persons (1988) GA Res A43/173, UN Doc A/143173 (UN Body of Principles).
[67] UN Body of Principles, Principle 19.
[68] Ibid, principle 4, term (f).
[69] International Covenant on Civil and Political Rights 1966, above n 9.
[70] Ibid, art 19(2).
[71] Ibid, art 19(3).
[72] United Nations Treaty Collection ‘International Covenant on Civil and Political Rights’, 26 October 2010, <http://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY & mtdsg_no=IV-4 & chapter=4 & lang=en & clang=_en#EndDec> .
[73] Roy Jordan, ‘Free speech and the Constitution’, (Research Note no. 42 2001-02, Parliamentary Library, Parliament of Australia 2002).
[74] Optional Protocol to the International Covenant on Civil and Political Rights 1966, opened for signature, ratification and accession by General Assembly resolution 2200A (XXI) of 16 December 1966 (entered into force 23 March 1976).
[75] New South Wales Council of Civil Liberties ‘Does Australia violate human rights?’ (2009) <http://www.nswccl.org.au/issues/hr_violations.php> .
[76] Queensland Parole Boards, above n 10.
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