R. v. Gray

R. v. Gray

The appeal is dismissed because the absolute discharge was not raised before the Board and the Board reasonably concluded, on unchallenged evidence, that the appellant continued to pose a significant risk to public safety; the Board's denial of community living privileges and assessment regarding aboriginal status...

Source-derived case information.

Citation
2010 ONCA 803
Parties
Respondent: Her Majesty the Queen; Appellant: Arnold Gray; Respondent: Regional Mental Health Care St. Thomas; Amicus Curiae: Anita Szigeti
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
29 November 2010
Procedural Posture
Criminal / Appeal From Disposition of the Ontario Review Board (dated April 28, 2010)
Outcome
Appeal dismissed
Legal Topics
Review Board Disposition, Absolute Discharge, Community Living Privileges, Risk Assessment, Treatment Impasse, Consideration of Aboriginal Status
Source Language
en
Criminal Law Mental Health Law Aboriginal Law Review Board Disposition Absolute Discharge Community Living Privileges Risk Assessment Treatment Impasse +1 more

Source-derived case record

Summary, issues, holding and outcome

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Parties

Her Majesty the Queen

Respondent

Arnold Gray

Appellant

Regional Mental Health Care St. Thomas

Respondent

Anita Szigeti

Amicus Curiae

Procedural Posture

Criminal / Appeal From Disposition of the Ontario Review Board (dated April 28, 2010)

  1. 1 Whether an absolute discharge should be granted despite the request not being raised before the Board
  2. 2 Whether the Review Board was unreasonable in denying potential community living privileges
  3. 3 Whether the Board failed to adequately consider the appellant's aboriginal status

Ratio Decidendi

The appeal is dismissed because the absolute discharge was not raised before the Board and the Board reasonably concluded, on unchallenged evidence, that the appellant continued to pose a significant risk to public safety; the Board's denial of community living privileges and assessment regarding aboriginal status and treatment impasse were not unreasonable on the record, though the next review must include supplemented information and a forward-looking treatment plan.

Court Disposition

Appeal dismissed

Orders

  • The appeal is dismissed.
  • The record for the next review shall be supplemented with more information, a more complete analysis of the implications of the appellant's aboriginal status, and a future-looking plan of treatment.