Williams (Re)

Williams (Re)

The Court dismissed the appeal because the Ontario Review Board’s disposition was reasonable, was supported by the evidence including the attending psychiatrist’s testimony, and properly found the appellant posed a significant threat to public safety; the Board’s decision on managing that risk is entitled to...

Source-derived case information.

Citation
2014 ONCA 42
Parties
Appellant: Jerome Williams; Amicus Curiae: Howard L. Krongold; Intervener: Centre for Addiction and Mental Health; Respondent: Attorney General of Ontario
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
17 January 2014
Procedural Posture
Appeal Under Part Xx.1 of the Criminal Code (ontario Review Board Disposition) / On Appeal From Ontario Review Board Disposition Dated April 8, 2013; Oral Hearing Before Court of Appeal
Outcome
Appeal dismissed; Ontario Review Board disposition dated April 8, 2013 upheld
Legal Topics
Review of Mental Health Review Board Disposition, Absolute Discharge, Risk to Public Safety, Standard of Appellate Deference
Source Language
en
Criminal Law Mental Health Law Administrative Law Review of Mental Health Review Board Disposition Absolute Discharge Risk to Public Safety Standard of Appellate Deference

Source-derived case record

Summary, issues, holding and outcome

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Parties

Jerome Williams

Appellant

Howard L. Krongold

Amicus Curiae

Centre for Addiction and Mental Health

Intervener

Attorney General of Ontario

Respondent

Procedural Posture

Appeal Under Part Xx.1 of the Criminal Code (ontario Review Board Disposition) / On Appeal From Ontario Review Board Disposition Dated April 8, 2013; Oral Hearing Before Court of Appeal

  1. 1 Whether the Ontario Review Board’s April 8, 2013 disposition was unreasonable
  2. 2 Whether the appellant was entitled to an absolute discharge
  3. 3 Whether there was an error of law or a miscarriage of justice warranting interference

Ratio Decidendi

The Court dismissed the appeal because the Ontario Review Board’s disposition was reasonable, was supported by the evidence including the attending psychiatrist’s testimony, and properly found the appellant posed a significant threat to public safety; the Board’s decision on managing that risk is entitled to deference and no legal error or miscarriage of justice was shown.

Court Disposition

Appeal dismissed; Ontario Review Board disposition dated April 8, 2013 upheld

Orders

  • Appeal dismissed