Accessory after the fact to murder
R. v. Cox
Sentence and the Crown's position
What the law allows
Tatiana Cox pleaded guilty to being an accessory after the fact to murder after helping the shooter dispose of the gun and flee to Annapolis Royal following a fatal shooting in Dartmouth in December 2021. Crown and defence jointly recommended two years' imprisonment going forward, after 59 days of remand credit, followed by two years of probation. Justice Chipman accepted the joint submission, finding it emphasized deterrence and denunciation while accounting for her youth, Indigenous background, guilty plea and relatively short involvement.
In the judge's words
1Having reviewed all of the materials and listened to the submissions of Crown and Defence counsel, I am of the view that the joint submission is within the acceptable range and is compliant with the directions set out in R v Anthony Cook, 2016 SCC 43.
The record
- Convicted of
- Accessory after the fact to murder (CC 240)
- Prior convictions
- Not recorded
- At the time of the offence
- Not stated1
- Defence asked for
- 789 days in custody1
- Appeal
- Not yet checked
- Counsel
- Crown: Robert Kennedy, K.C. and Scott Morrison
Defence: Qui Linh
Sources
- R. v. Cox, 2026 NSSC 153 Court decision, CanLII, May 8, 2026
[3] On sentencing the Court has received a joint submission recommending a period of imprisonment of two years on a go forward basis, followed by two years probation. … [4] … The joint submission has factored in this remand credit. Accordingly, the joint submission is for two years imprisonment on a go forward basis.
[3] On sentencing the Court has received a joint submission recommending a period of imprisonment of two years on a go forward basis, followed by two years probation.
[13] The offence of accessory after the fact to murder contrary to s. 240 of the Criminal Code carries a maximum term of imprisonment of life. There is no minimum sentence.
[2] A judge and jury trial was scheduled to commence on June 3, 2026 for approximately 18 days. Today Ms. Cox entered an informed guilty plea to the single count on the Indictment.
[24] Having reviewed all of the materials and listened to the submissions of Crown and Defence counsel, I am of the view that the joint submission is within the acceptable range and is compliant with the directions set out in R v Anthony Cook, 2016 SCC 43.
[4] Ms. Cox was arrested and charged for this offence on December 20, 2021. She remained in pre-trial detention until January 27, 2022 (39 days), when she was released on bail conditions. Applying a ratio of 1.5 to 1 (R v Summers, 2014 SCC 26), Ms. Cox has 59 days of remand credit. … [24] … Accordingly, I hereby sentence Tatian Faye-Anne Cox to imprisonment of two years on a go forward basis, followed by two years probation.
- R. v. Cox, 2026 NSSC 153 Court decision, Courts of Nova Scotia