A review of the past 12 months by Susan Jones.
Susan Jones is a specialist inquest practitioner who also practices in personal injury, clinical negligence and licensing.
In addition to continuing to build on her inquest practice involving complex medical cases including recently appearing in cases concerning missed cancer diagnosis, sepsis, and complex cardiology issues, Susan’s inquests practice is increasingly focusing on joint emergency service interoperability, including missing persons (land and sea) searches, air accidents, marine accidents and mass fatalities. Recent notable inquests include the inquests into the Plymouth/Keyham shootings and the 12-week inquest into the death of Gaia Pope.
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Susan has experience of appearing before a variety of public law and regulatory forums.
In 2016 Susan appeared for a Local Authority in a long running case involving an appeal against refusal to renew a license under the Animal Boarding Establishments Act 1963. The licence being necessary for carrying on a business of providing accommodation at premises, including a dwelling, for other peoples cats and dogs.
Susan is regularly instructed to appear in taxi licensing appeals and will consider acting on a direct access basis.
In 2016 Susan appeared for a local authority in a number of appeals against revocation of Hackney Carriage Licences with immediate effect under the Local Government (Miscellaneous Provisions) Act 1976, when drivers breached a Traffic Regulation Order by a pedestrianised areas.
In 2017 Susan represented a Licensing Authority in a taxi licensing appeal in which the license holder was accused and acquitted of rape. Upon learning of the allegation the Licensing Authority revoked the driver’s license with immediate effect in the interests of public safety. During the course of the licensing appeal, Susan highlighted the burden of proof depends on the nature of proceedings and the purpose of criminal and licensing proceedings are very different. Susan relied on a transcript of the complainant’s ABE interview, the driver’s PACE police interview and Crown Court Transcript when questioning the officer in the case and the driver. The driver’s appeal was refused.
Susan has appeared before a taxi and private hire licensing sub-committee on behalf of a taxi conglomerate for consideration of fitness of two directors to continue holding Private Hire Operator Licences. This involved issues of natural justice and responding to a report from the Head of Transportation Services.
Before the Traffic Commission, Susan represented four Lorry companies in a multi day, multi issue inquiry arising from five reports concerning professional competence, good repute, satisfaction of fundamental licensing requirements and financial standing. The case involved a history of receipt of a large number of PG9’s including some serious roadworthiness prohibitions. Concerns were raised relating to third party trailers, inadequately of checks, driver failings and issues surrounding nominated Transport Managers. The licences of each company had previously been suspended due to failure to provide evidence of appropriate financial standing. Susan ensured the financial suspension was lifted on the first day of the inquiry. Following the evidence and submissions, all parties received Formal Warnings.
Susan has represented Duty Premises Supervisors before licensing sub-commitees and appeared in review hearings and applications for extension of opening hours. She has also represented publicans in criminal sentencing hearings involving consideration of suspension of their personal licence under the Licensing Act 2003.
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Susan accepts instructions in a wide range of personal injury matters and acts for Claimants and Defendants.
Susan regularly attends:
- Costs and Case Management Hearings (CCMCs)
- Interim applications, including relief from sanctions
- Trials involving liability, causation and quantum disputes
- Infant and protected party approval hearings for a wide range of injuries including fatal injuries
- Conciliation hearings
Susan has experience of personal injury claims concerning occupier’s liability, the Highway Act, food poisoning, accidents at work, road traffic accidents, sporting accidents and fatal injuries arising in a wide range of circumstances.
Susan has acted or is currently acting for Defendants in cases in which:
- Fundamental dishonesty is alleged, made out and qualified one-way costs shifting (QOCS) has been disapplied.
- Breach of duty is admitted but causation disputed based on Late Notification, in which following cross examination the Claimant did not make out their case.
- Following discontinuance Defendant costs are pursued based on fundamental dishonesty.
- Arguments have been raised regarding purported discontinuance and strike out has been sought in addition or as an alternative to fundamental dishonesty.
- After trial liability has been made out against one Defendant but not the Defendant Susan represented in which case Susan secured an enforceable Defendant costs order up to the extent of damages awarded.
- Only quantum is disputed but the Claimant has failed to better a Defendant Part 36 offer, with costs consequences.
- A quantum only dispute was allocated to the Fast Track, but Susan successfully argued the claim unreasonably left the Portal resulting in the Claimant being limited to Portal costs with significant cost savings for the Defendant.
- The Claimant’s claim has been struck out for not having a direct cause of action against the Defendant with an enforceable costs order granted.
Susan successfully represented a Claimant in a 5 witness public liability and quantum trial following which the Defendant appealed to the High Court on grounds of procedure and findings of fact. Susan advised on the appeal, drafted a skeleton argument and made oral submission before Mrs Justice Lambert. The Defendant’s appeal was dismissed in its entirety.
Susan represented a Claimant at trial where the Claimant alleged, he burnt his hand while working for the Defendant when required to set fire to sawdust on the Defendants premises. The matter was defended on the basis that the Defendant never employed the Claimant (there was no contract of employment, no evidence of payments and the Claimant did not have a UK work permit) and in any event that the incident did not occur on his premises (there being no accident book entry, or any other record and the incident described was not something tolerated by the Defendant). Following a full day trial, the judge found for the Claimant and heard submissions on quantum for burn injuries.
Susan recently advised a local authority in respect of life long dental treatment required by a child following a liability admitted accident. On behalf of the Defendant Susan attended the approval and informed the Court that the settlement was fair, excluded double counting suggested in the Claimant’s schedule of loss and applied the correct discount rate.
Susan represented a child at an assessment of damages hearing, who sustaining deep facial laceration requiring surgery under general anaesthetic, leaving permanent scarring with a likelihood of further future treatment. The Claimant also suffered post traumatic anxiety that resolved.
Susan provides advice on quantum and attends infant and protected party approval hearings, including for dependents following fatal accidents. She has considered issue relating to hostile litigation friends and matters arising when Defendant's potentially lack capacity in areas of law outside the remit of personal injury.
Susan is happy to draft pleadings and advise on prospects and quantum.
Susan is a member of PIBA and attends their annual March conference.
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Susan is a busy inquest practitioner. In the past 12 months Susan has appeared in inquests representing HM Coastguard, Police Forces, Care providers, Education Providers, individual police and nursing practitioners, Cruise Ships, local authorities, and families.
Susan regularly appears in Article 2 and jury inquests and has appeared in lengthy inquests in which the determination of the cause of death are complex and involve the assessment of factual evidence and numerous experts.
Susan has experience of inquests involving:
- Firearms licensing and mass shootings
- Deaths in custody
- Modern Slavery
- Emergency services attendance, including multi agency response
- Search and rescue (land and sea)
- Jet-ski collisions
- Deaths in care homes
- Covid-19, in custody, and the community
- Hospital deaths, including complications in cardiology, urology procedures, elective surgeries, and labour
- Hyponatremia (including from excessive water intake)
- Sudden Infant Deaths
- Suicides, in the community and voluntary, and involuntary inpatients
- Prescription medication (including opioids, and post-mortem redistribution)
- Prescribing errors
- Canine attack
- Accidents at work, including construction sites and docks
- Road traffic accidents
In the 2023 inquests into Keyham/Plymouth mass shooting Susan was sole counsel representing the Firearms Licensing Supervisor. The inquests took place over 6 weeks and heard from over 60 witnesses. 11 interested persons were involved, 3 of whom were represented by silks and juniors. The inquest considered firearms licensing systems and culture within the police firearms unit, the shotgun licence application and a further review, the applicable legal framework for shotgun licences at the time including Home Office Guidance and the British Medical Associations response to that Guidance. These inquests received national media attention.
In 2022 Susan, acted as sole counsel, representing HM Coastguard in the inquest into the death of Gaia Pope. In November 2017, 19-year-old Gaia was reported missing. The 12-week jury inquest into her death, involved counsel to the inquest, 15 interested persons and over 70 witnesses. The inquest explored mental health and epilepsy management, recent pre-death contact with the police, ambulance service and social services and an 11-day multi-agency search following Gaia going missing. The inquest heard expert evidence in pathology, entomology, neurology, psychiatry, and missing person search strategies and also included a jury scene view to where Gaia was found.
In 2022 Susan represented a police force in an inquest concerning the death of a sex worker who fell from a cliff. In advance of death the deceased disclosed she was a victim of modern slavery. The inquest explored a number of aspects of police involvement, including police interactions within the multi-agency safeguarding response, police offers of sanctuary, police investigation into the alleged offences, police response when attending a safeguarding concern on the day of death and the police force control room’s response to a 999 call from the deceased whilst on the cliff edge.
In 2021, in a week-long inquest, Susan represented the family of a prisoner, on the shielding list, who died from covid-19.
Susan represented a registered mental health nurse in a 5-week Article 2 jury inquest. TD was a remand prisoner on a prison healthcare unit for mental health concerns who unexpectedly died from gastro-intestinal haemorrhage. The inquests considered complications arising from prescription medication, methods of requesting GP assessment, communication between prison and healthcare staff and the interaction of mental health issues on physical health care.
In a 12-day, Article 2, jury inquest Susan represented a police force following the deceased having been recently discharged from a mental health ward and on the day of death telephoning mental health services reporting an intention to drive or jump into the Thames, following which mental health services called the Police call centre. In addition to considering the appropriateness of mental health care this inquest explored communication between mental health services and police, police call grading, application of the police national decision-making model, communication between the police call handling centre and force control room and police conduct at the riverside.
In an 8-day jury inquest Susan represented a novice jet skier involved in a fatal collision resulting in the death of an experienced jet skier. The inquest involved complex factual and expert evidence, including expert evidence regarding water collision reconstruction and medical causation. The Coroner requested submissions on the appropriateness of leaving unlawful killing to the jury.
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Susan uses experience gained in her personal injury and inquest practice to assess claims in this area. Susan has advised Claimants and Defendants in deaths of adults and children arising from alleged clinical failures.
Susan has recently advised on lifelong dental injuries and is interested in developing a cosmetic and dental negligence practice.
In light of Montgomery v Lanarkshire Health Board  UKSC 11 Susan has advised in cases relating to adequacy or otherwise of information given to patients upon which they are to decide whether or not to undergo a particular type of treatment. Susan is currently involved in a class action in this respect.
Powers, Purposes and Patterns of Coroners Prevention of Future Deaths Reports2nd May 2023
Event witnessed by father was not objectively shocking and horrifying23rd Jun 2021
Susan Jones analyses the High Court case of King v Royal United Hospital Bath NHS Foundation Trust  EWHC 1576 in which practitioners are reminded that the threshold for a shocking event is strictly objective in secondary victim claims. The judgment also provides a helpful insight into how damages would have been assessed for an actor who it was claimed was on the verge of a “big break".
Peter Mills Dammerman v Lanyon Bowlder LLP (2017)27th Apr 2017
3PB's Susan Jones relies on April 2017 Court of Appeal decision to defend a £49,000 costs application in its entirety. On 20th April 2017, in what is likely to be one of the first applications of the Court of Appeal decision in Peter Mills Dammerman v Lanyon Bowlder LLP (2017) Susan successfully appeared for a Defendant in a costs dispute following settlement of a small claim in favour of a Defendant's counterclaim for an offer made by the Claimant almost 3 years earlier.
Susan Jones is a talented inquests barrister who is highly skilled in sensitive matters examining deaths occurring in various circumstances, including where there are allegations of medical negligence. Her practice touches on complex issues such as mental health.
Strengths: “She is insanely hard-working and dedicated, and she has meticulous attention to detail.”
“Susan prepares clients well, and her oral submission was incredibly impressive.”
Chambers UK 2024/Inquests and Public Inquiries/The Regions Bar
Strengths: “Susan is an experienced inquests advocate who produces well-planned advocacy and submissions.”
Chambers UK 2023/Inquests and Public Inquiries/The Regions Bar
Strengths: "She is very reassuring, lays out exactly how matters will play out and gives the client certainty." "Her advice is timely and comprehensive and she makes herself readily available."
Recent work: Acted for Isle of Wight Adult Social Services at the inquest into the death of Frederick Joe Sheath, a care home resident who was transferred from a failing care home.
Chambers UK 2022/Inquests and Public Inquiries/The Regions Bar
Strengths: "She is phenomenal: the technicality and the expertise that she shows in inquests is incredible. She has superb attention to detail and she would be my first choice for any inquest."
Recent work: Instructed to represent family members at the inquest into the death of Elena Mondal. This matter examined the suicide of the teenager in her school and the adequacy of communication between the mental health services, school and NHS trust.
Chambers UK 2021/Inquests and Public Inquiries/The Regions Bar
‘Susan is fearless when representing clients in complex and sensitive matters against counsel more senior than herself.'
Legal 500 2024/Inquests and Inquiries/Leading Juniors/London Bar
‘Susan is an excellent advocate. During inquests she argues powerfully for the families she represents.’
Legal 500 2023/Inquests and Inquiries/Leading Juniors/London Bar
‘Susan is thorough and understands a case in minute detail. She leaves no stone unturned in acting for clients to get the answers that they want and need. Her attitude to clients is professional but kind, and she really gives a case her all.’
Legal 500 2022/Inquests and Inquiries/Leading Juniors/London Bar
‘Hardworking, focused and displays a maturity of approach beyond her year of call. Her personable approach puts clients at ease while reassuring them they are in safe hands. She also secures impressive results.’
Legal 500 2021/Inquests and Inquiries/Leading Juniors/London
“May I personally record my admiration of Susan Jones performance before Mrs Justice Lambert. I sat behind her as a solicitor with 25 years post qualification experience and witnessed a rising star. She stood her ground against Mrs Justice Lambert’s initially strident view that the judge below had reached a wrong decision on the facts and gently set out in a highly effective, forensic way how the judge’s opinion below should not be interfered with…...High Court Judges don’t mess around, neither did Susan" (Instructing solicitor in Susan Jones successfully opposition of High Court Appeal challenging both Procedural Matters and Findings of Fact)
“Speed and uptake was impressive to say the least, as was her energy and the commitment she made. Since this first encounter, we have sought to use her whenever possible. Having sat next to her I can say that she is an accomplished advocate with a compelling style of advocacy” (Partner, instructing and attending a 3 day hearing)
“Our client is very happy with the outcome and I would certainly not hesitate to use Miss Susan Jones in the future or recommend her to my colleagues”. (Solicitor)
“Thank you for your advice which is both thorough and lucid of its analysis of the case” (Associate Solicitor)
“Miss Jones was extremely helpful and professional. I do not see how we could have done any more to better present my case” (Lay Client)