In Michaelides v The Queen, Chief Justice French and Justice Crennan refused to grant special leave to appeal against a unanimous decision of the Queensland Court of Appeal upholding the applicant’s convictions on two counts of extortion. The applicant contended that the jury verdict was unreasonable or could not be supported on the evidence before the QCA, and that the QCA applied the incorrect formulation in testing that claim. Their Honours agreed with the applicant’s argument that the formulation in MFA v The Queen was authoritative and did not precisely match that applied by the QCA, they refused special leave on the basis that there was no error in the QCA’s conclusion that the appeal provision the applicant sought to rely on was not enlivened, due to the facts of the case.