"Worst case scenario" crime ... Kenneth Brooks.
A contract killer's culpability is higher than that of the woman who hired him to murder her estranged grazier husband, a Sydney court has been told.
Kenneth Brooks "undertook the job to kill a complete stranger for money", a crime falling "within the range of a life sentence", according to Crown prosecutor Wayne Creasey.
I should have said, 'Love you, too, Dad, bye'
"In relation to Helen Ryan, she was motivated not only by financial advantage, but also in terms of exacting some sort of revenge. Whereas [Brooks] was motivated solely by financial gain," Mr Creasey said today.
Killed ... Jeffery Ryan.
He was making submissions in the NSW Supreme Court at the sentencing hearing of Brooks, 45 at the time of the crime, who was found guilty last December of murdering Jeffrey Ryan.
Mr Ryan, 48, was gunned down at his property at Duri near Tamworth, in northwest NSW, on October 23, 2009.
His 51-year-old second wife, who recruited her mother and sister to help arrange the $30,000 contract killing, was jailed for at least 27 years last October.
Behind bars ... Helen Ryan, right, at her husband's funeral.
The sentencing judge described Ryan's plot as "wicked and gravely reprehensible", saying her purely selfish and financial motives "demonstrated a heinousness of significant degree".
Mr Creasey submitted that Brooks's crime fell within the "worst case scenario".
"It is a killing, using a firearm, of a completely defenceless person, shot from behind, at night," he said.
But Carolyn Davenport SC, for Brooks, argued that his sentence should not be dissimilar to Ryan's, submitting his criminality was not more serious than hers.
Earlier, Brodie Ryan broke down as he read a victim impact statement describing the pain of losing his father who had been his "friend and an all-round good bloke".
The last time he saw him was when his father came to Melbourne to surprise him for his 21st birthday, which was "the most happiest memory I have left".
Mr Ryan said he last spoke to his father on the phone hours before he died, when he told him he was one of two workers being considered for a promotion.
"My father will never know, yes, I got the promotion," he said.
At the end of the call, his father said: "Bye, love you", and Mr Ryan said goodbye.
"I should have said, 'Love you, too, Dad, bye'."
Two sisters of Mr Ryan also read impact statements on how much they missed their brother.
Jenny Ryan spoke of the family's "sense of unfairness, injustice and stupidity" and asked why nobody said no to Helen Ryan's plot.
"Pain is our companion," she said.
Justice Elizabeth Fullerton will sentence Brooks in the Newcastle Supreme Court on May 18.