R. v. Puttonen

R. v. Puttonen

Although the conduct of Steele and Melville on January 6, 2026 displayed indifference and was calculated to delay and disrupt the proceeding, the judge exercised discretion not to convict for contempt after weighing mitigating factors—Crown's prior agreement to proceed on January 7, the subsequent stay of...

Source-derived case information.

Citation
2026 BCSC 320
Parties
Crown: Rex; Accused: Nathaniel Cochise Puttonen; Defence Counsel: Jerry Steele; Defence Counsel: Dale Melville
Court
Supreme Court of British Columbia
Jurisdiction
Canada
Judgment Date
26 February 2026
Procedural Posture
Criminal (contempt Arising From Trial Counsel Conduct) / Show Cause Contempt Hearing (post Commencement of Voir Dire)
Outcome
Judge declined to find either Dale Melville or Jerry Steele guilty of contempt of court.
Legal Topics
Contempt of Court, Adjournment Applications, Disclosure Obligations, Duty of Counsel to the Court, Double Booking, Jordan Delay
Source Language
english
Criminal Law Professional Responsibility Court Procedure Contempt of Court Adjournment Applications Disclosure Obligations Duty of Counsel to the Court Double Booking +1 more

Source-derived case record

Summary, issues, holding and outcome

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Parties

Rex

Crown

Nathaniel Cochise Puttonen

Accused

Jerry Steele

Defence Counsel

Dale Melville

Defence Counsel

Procedural Posture

Criminal (contempt Arising From Trial Counsel Conduct) / Show Cause Contempt Hearing (post Commencement of Voir Dire)

Legal Issues

  1. 1 Whether defence counsel's conduct on January 6, 2026 amounted to contempt in facie curiae
  2. 2 Whether counsel's conduct was deliberate, indifferent, or merely inadvertent/negligent
  3. 3 Whether mitigating factors (Crown consent, apology, subsequent stay) preclude a contempt finding

Ratio Decidendi

Although the conduct of Steele and Melville on January 6, 2026 displayed indifference and was calculated to delay and disrupt the proceeding, the judge exercised discretion not to convict for contempt after weighing mitigating factors—Crown's prior agreement to proceed on January 7, the subsequent stay of proceedings, a sincere apology by Steele, and the overall consequences—which collectively made a contempt conviction inappropriate in all the circumstances.

Court Disposition

Judge declined to find either Dale Melville or Jerry Steele guilty of contempt of court.

Orders

  • No finding of contempt; admonition and formal warning to both counsel; no fines or custodial sanctions imposed