Ontario (Attorney General) v. $44,425 In Canadian Currency (In Rem)

Ontario (Attorney General) v. $44,425 In Canadian Currency (In Rem)

The appeal was dismissed because the application judge gave cogent reasons, permissibly accepted the uncontradicted opinion of Sergeant Hawkes and rejected the appellant’s explanation, and those factual findings were supported by the record such that no reversible error warranted re‑weighing the evidence.

Source-derived case information.

Citation
2017 ONCA 201
Parties
Applicant (respondent in Appeal): Attorney General of Ontario; Respondent (appellant in Appeal): $44,425 In Canadian Currency (In Rem)
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
8 March 2017
Procedural Posture
Civil Forfeiture / Appeal (court of Appeal)
Outcome
Appeal dismissed
Legal Topics
Forfeiture, Civil Remedies Act, Burden of Proof, Adequacy of Reasons
Source Language
english
Civil Asset Forfeiture Criminal Law Civil Remedies Forfeiture Civil Remedies Act Burden of Proof Adequacy of Reasons

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Parties

Attorney General of Ontario

Applicant (respondent in Appeal)

$44,425 In Canadian Currency (In Rem)

Respondent (appellant in Appeal)

Procedural Posture

Civil Forfeiture / Appeal (court of Appeal)

  1. 1 Whether the application judge provided adequate reasons that the funds were proceeds or an instrument of unlawful activity under ss.3(1) or 8(1) of the Civil Remedies Act, 2001
  2. 2 Whether the appellate court should re-weigh evidence in absence of reversible error
  3. 3 Whether the uncontradicted opinion of police can be accepted as connecting funds to unlawful activity

Ratio Decidendi

The appeal was dismissed because the application judge gave cogent reasons, permissibly accepted the uncontradicted opinion of Sergeant Hawkes and rejected the appellant’s explanation, and those factual findings were supported by the record such that no reversible error warranted re‑weighing the evidence.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed
  • Forfeiture order confirmed: approximately $44,425 forfeited to the Crown