R. v. Delagrave

R. v. Delagrave

The Court held the treating psychiatrist's evidence and the hospital's planned safeguards provided a sufficient evidentiary basis for the Board's discretionary order permitting limited, managed community access, but allowed the appeal in part to attach two conditions (absolute prohibition on intoxicant use and...

Source-derived case information.

Citation
2010 ONCA 116
Parties
Appellant: Her Majesty the Queen; Respondent: Jean Delagrave
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
11 February 2010
Procedural Posture
Criminal / Appeal From Ontario Review Board to Court of Appeal
Outcome
Appeal allowed in part and dismissed in part.
Legal Topics
Review Board Orders, Community Access, Risk Assessment, Conditions of Release, Intoxicant Prohibition, Weapons Prohibition
Source Language
en
Criminal Law Mental Health Law Administrative Law Appeal Review Board Orders Community Access Risk Assessment Conditions of Release +2 more

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Parties

Her Majesty the Queen

Appellant

Jean Delagrave

Respondent

Procedural Posture

Criminal / Appeal From Ontario Review Board to Court of Appeal

  1. 1 Whether the Board's order allowing the Hospital discretion to grant limited community access was unreasonable or unsupported by the evidence
  2. 2 Whether the Board's order should be amended to include conditions prohibiting use of intoxicants and possession of firearms/ammunition/other offensive weapons
  3. 3 Whether the psychiatric evidence sufficiently addressed risks including unanticipated stresses

Ratio Decidendi

The Court held the treating psychiatrist's evidence and the hospital's planned safeguards provided a sufficient evidentiary basis for the Board's discretionary order permitting limited, managed community access, but allowed the appeal in part to attach two conditions (absolute prohibition on intoxicant use and prohibition on possession of firearms, ammunition or other offensive weapons) that had been recommended by the hospital and previously accepted by the Board but omitted from its order.

Court Disposition

Appeal allowed in part and dismissed in part.

Orders

  • Attach condition that the respondent absolutely refrain from the use of intoxicant substances to the Board's order
  • Attach condition that the respondent refrain from having in his possession any firearms, ammunition or other offensive weapons to the Board's order