Vancurenko (RE)

Vancurenko (RE)

The Court held the Ontario Review Board's finding that the appellant continued to pose a significant threat to public safety and its decision to maintain a conditional discharge was reasonable because the Board considered the evidence as a whole, was not bound by expert opinion, and properly accounted for factors...

Source-derived case information.

Citation
2011 ONCA 249
Parties
Appellant: George Vancurenko; Amicus Curiae: Jill Presser; Amicus Curiae: Crystal Tomusiak; Respondent: Ontario Review Board
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
31 March 2011
Procedural Posture
Appeal From Ontario Review Board Under the Criminal Code / Court of Appeal Decision on Whether to Uphold Conditional Discharge (oral Hearing)
Outcome
Appeal dismissed; Ontario Review Board disposition maintaining conditional discharge affirmed
Legal Topics
Conditional Discharge, Significant Threat to Public Safety, S.672.54 Factors, Standard of Review
Source Language
en
Criminal Law Mental Health Law Administrative Law Conditional Discharge Significant Threat to Public Safety S.672.54 Factors Standard of Review

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Parties

George Vancurenko

Appellant

Jill Presser

Amicus Curiae

Crystal Tomusiak

Amicus Curiae

Ontario Review Board

Respondent

Procedural Posture

Appeal From Ontario Review Board Under the Criminal Code / Court of Appeal Decision on Whether to Uphold Conditional Discharge (oral Hearing)

  1. 1 Whether the Ontario Review Board erred in ordering that the appellant continue to be subject to a conditional discharge
  2. 2 Whether the Board adequately considered and applied the factors in s.672.54 of the Criminal Code
  3. 3 Whether the Board's finding that the appellant poses a significant threat to public safety was unreasonable

Ratio Decidendi

The Court held the Ontario Review Board's finding that the appellant continued to pose a significant threat to public safety and its decision to maintain a conditional discharge was reasonable because the Board considered the evidence as a whole, was not bound by expert opinion, and properly accounted for factors (ongoing criminal behaviour, impulsivity, lack of judgment, monitoring needs) militating against an absolute discharge.

Court Disposition

Appeal dismissed; Ontario Review Board disposition maintaining conditional discharge affirmed

Orders

  • Appeal dismissed
  • Order of the Ontario Review Board continuing the appellant on conditional discharge is affirmed