Staniszewski (Re)

Staniszewski (Re)

The Board correctly applied the Winko test and the evidence supported its conclusion that the appellant continues to pose a significant threat to public safety, so discharge was not appropriate; however, because North Bay could not receive the appellant, the condition providing for community placement at North Bay...

Source-derived case information.

Citation
2017 ONCA 37
Parties
Appellant: David Staniszewski; Respondent: Brockville Mental Health Centre; Respondent: Attorney General of Ontario
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
16 January 2017
Procedural Posture
Criminal Review Board Appeal (part Xx.1 Criminal Code) / Appeal to Court of Appeal Against Ontario Review Board Disposition Dated May 13, 2016
Outcome
Appeal allowed in part; Board's finding that the appellant remains a significant threat and refusal to discharge upheld; condition #5 of the disposition amended to permit Brockville Mental Health Centre discretion to place the appellant in approved community accommodation.
Legal Topics
Winko Test, Review Board Disposition, Absolute Discharge, Conditional Discharge, Community Living Condition
Source Language
en
Criminal Law Mental Health Law Administrative Law Public Safety Winko Test Review Board Disposition Absolute Discharge Conditional Discharge +1 more

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Parties

David Staniszewski

Appellant

Brockville Mental Health Centre

Respondent

Attorney General of Ontario

Respondent

Procedural Posture

Criminal Review Board Appeal (part Xx.1 Criminal Code) / Appeal to Court of Appeal Against Ontario Review Board Disposition Dated May 13, 2016

  1. 1 Whether the Ontario Review Board properly applied the Winko test in refusing an absolute discharge
  2. 2 Whether the Board erred in failing to order a conditional discharge
  3. 3 Whether condition #5 of the Board's disposition should be amended to allow Brockville Mental Health Centre discretion to place the appellant in community accommodation because North Bay cannot receive him

Ratio Decidendi

The Board correctly applied the Winko test and the evidence supported its conclusion that the appellant continues to pose a significant threat to public safety, so discharge was not appropriate; however, because North Bay could not receive the appellant, the condition providing for community placement at North Bay was properly amended to allow Brockville Mental Health Centre discretion to place the appellant in approved community accommodation.

Court Disposition

Appeal allowed in part; Board's finding that the appellant remains a significant threat and refusal to discharge upheld; condition #5 of the disposition amended to permit Brockville Mental Health Centre discretion to place the appellant in approved community accommodation.

Orders

  • Appeal allowed in part.
  • Ontario Review Board disposition dated May 13, 2016 is upheld except that condition #5 is amended to allow Brockville Mental Health Centre, in its discretion, to permit the appellant to live in approved community accommodation.