Carmen Niklaus defenceless when stabbed by Ricky Charles Williams

Prosecutor Jordan Johnston said 40-year-old Ms Niklaus had passed out in a taxi on the way to the Everton Caravan and Tourist Park on December 6, according to the driver.

She was drug affected and vulnerable to the point she was unable to stand up in the shower in the lead up to her murder.

Williams, 44, stabbed Ms Niklaus three times in the attack which the prosecution says was motivated by his frustrations with their relationship, believing that she had lied to him and used him.

The Supreme Court has been told that Williams perceived a pattern of behaviour with Ms Niklaus, saying that when she decided to stop using drugs, or ran out of money for drugs, she would turn to him for somewhere to stay, for something to eat and a place to have a shower.

In sentencing submissions in the Supreme Court on Tuesday February 28, Mr Johnston said that the case was not "a frenzied murder", and Williams had an opportunity to stop" when Ms Niklaus cried, "please don't hurt me".

"This is sadly yet another situation in which a male partner in a domestic situation has responded to some provocative event, or perceived provocative event ... around a failure in the relationship and has responded with fatal violence," he told Supreme Court Justice Ross Champion.

Mr Johnston said Williams had plunged a kitchen knife with a 20-centimetre blade into Ms Niklaus three times, causing one wound that was 10 centimetres deep and two wounds 20 centimetres deep.

Judge Champion observed that those 20-centimetre wounds had meant the knife had struck "to the hilt", "full-depth stabs", causing catastrophic injuries to Ms Niklaus.

RELATED CONTENT

Mr Johnston said Williams had an opportunity to end his attack after inflicting the first wound, with his victim appealing for him to stop. Williams responded to Ms Niklaus by saying: "I don't want to hurt you, I'm not f***ing here to hurt you, I didn't get you out here to hurt you ...", and then proceeded to stab her more forcefully - twice.

"The opportunity to pause, reflect, cease ... the opportunity was there. It was not a situation of a frenzied altercation," Mr Johnston said.

The court was told that Ms Niklaus was not threatening Williams at the time but had been punching herself in the head and wanted to leave.

The prosecution said Williams admitted this had angered him.

"I was angry about spending $50 on a taxi for her to come and see me and now she wants to leave," he said.

But Williams defence barrister Diana Price said that to paint the $50 taxi fare as a motive for the murder would be "a gross misrepresentation of the circumstances here".

In the moments after inflicting the wounds that would be fatal, Williams told Ms Niklaus to "calm down", that he would go and get help and that "I'm not going to let you die".

Ms Price said Williams was immediately aware of the seriousness of what he had done, and sought help. He did not try to leave, and was upfront with police when they arrived telling them "she didn't deserve this, she's meant to be helped, not dead ..."

In every interaction with police when they arrived at the scene, Ms Price submitted, Williams had told them exactly what he had done.

She said the pair had had an "on and off, push and pull type of relationship" that went back about 18 months.

Questioned by Judge Champion as to the motivation for the attack, Ms Price said Williams felt he had been used and lied to.

"That's no explanation, but it is the context of what occurred," Ms Price said.

"He says he just snapped ... fed up, grabs it (the knife) ... and then immediately does the action."

Judge Champion raised Williams anger at the taxi fare, reflected in his record of interview with police.

"Well you just got a taxi Carmen... 50 more f***ing dollars and you wanna go. I lost me shit. Too many f***ing lies. she wasn't there to be with me, she just had nowhere else to go," Williams told police.

Judge Champion said: "It appears as though that was the inspiration for the attack, that anger over the fact he spent $50 to get her out there and she wanted to go.

"She had an entitlement to go.

"Why is this (not) just yet another example of a man getting angry and blaming a woman for wanting to do something she wanted to do?" he asked.

Ms Price said Williams did not blame Ms Niklaus, took total responsibility for his actions and said he had done "the worst thing imaginable".

He had a complex personal history, and an acquired brain injury.

Born and raised in Wangaratta, his life began to unravel at the age of 14 when he was punched to the head, and then hit his head on the ground.

After that, "everything changed," Ms Price told the court. Williams became unruly and unmanageable, and was asked to move out of the family home.

For the rest of his life, he would experience periods of homelessness. At the time of the murder on December 6, he was set to become homeless again.

The court was told that new owners of the caravan park were not going to renew some leases, and that Williams would be without a home from mid-December.

Support workers who had been engaged with him through the NDIS and homelessness services reported that his mental health had started to decline, and that he had started to express increased levels of suicidal ideation and helplessness.

Just hours before Williams killed Ms Niklaus, two of those workers had made separate calls to Wangaratta police to request a welfare check on him. That welfare check never happened, Ms Price said.

Judge Champion will consider the submissions by the prosecution and defence before handing down his sentence in weeks to come.

To read more stories, download The Border Mail news app in the Apple Store or Google Play.

Our journalists work hard to provide local, up-to-date news to the community. This is how you can continue to access our trusted content: