Ross v. Ross

Ross v. Ross

The Court of Appeal found the sentencing judge erred in principle by treating the absence of a plan for supervised house arrest as decisive against a conditional sentence; because the appellant had purged his contempt and had mitigating characteristics, that error affected the sentence, and the 15‑day jail sentence...

Source-derived case information.

Citation
2019 ONCA 724
Parties
Appellant: J. Gordon Ross, Estate Trustee for the Estate of Mary Elizabeth Grafton, Deceased; Respondent: James H. Ross; Respondent: J. Grafton Ross; Respondent: S. Graeme Ross
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
16 September 2019
Procedural Posture
Civil Appeal / Appeal From Sentence for Contempt (court of Appeal Decision)
Outcome
Sentence suspended and set aside
Legal Topics
Contempt of Court, Passing of Accounts, Conditional Sentence, Purging Contempt, Costs
Source Language
en
Civil Contempt Estate Law Sentencing Contempt of Court Passing of Accounts Conditional Sentence Purging Contempt +1 more

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Parties

J. Gordon Ross, Estate Trustee for the Estate of Mary Elizabeth Grafton, Deceased

Appellant

James H. Ross

Respondent

J. Grafton Ross

Respondent

S. Graeme Ross

Respondent

Procedural Posture

Civil Appeal / Appeal From Sentence for Contempt (court of Appeal Decision)

  1. 1 Whether the sentencing judge erred by requiring an express plan for supervised house arrest before imposing a conditional sentence
  2. 2 Whether the 15‑day jail sentence for contempt should be suspended or set aside
  3. 3 Whether the appellant had purged his contempt and the effect of purging on sentencing

Ratio Decidendi

The Court of Appeal found the sentencing judge erred in principle by treating the absence of a plan for supervised house arrest as decisive against a conditional sentence; because the appellant had purged his contempt and had mitigating characteristics, that error affected the sentence, and the 15‑day jail sentence was suspended and set aside with directions to follow‑up on passing of accounts with diligence and counsel assistance.

Court Disposition

Sentence suspended and set aside

Orders

  • Sentence of 15 days' imprisonment suspended and set aside
  • Appellant ordered to follow up on any further order arising from the passing of accounts scheduled for October 31, 2019 with diligence and with the assistance of counsel