On 3 March 2009, the Attorney-General referred the case of Phillipa Curtis to the Court of Appeal on the basis that the 21 months imprisonment for causing death by dangerous driving was unduly lenient.

In early February 2009, Curtis was convicted of causing death by dangerous driving by sending text messages while driving, causing her to collide with a parked car, killing one person. In addition to the 21 months prison sentence, she was also disqualified from driving for 3 years.

The Court of Appeal will now look at the case once again. If they decide that the 21 months imprisonment was unduly lenient, they have the power to increase the sentence. If they do not think that the sentence was unduly lenient, it will remain the same.