R. v. King
The Court dismissed the appeal, holding the Board's finding that the appellant was unfit was not unreasonable because the evidence showed delusional beliefs (believing himself subject only to the laws of Moses and separate from the charged individual) that rendered him unable to understand the nature and object of...
Source-derived case information.
- Citation
- 2010 ONCA 42
- Parties
- Respondent: Her Majesty the Queen; Appellant: Rodney King; Intervenor: Brockville Mental Health Centre Hospital
- Court
- Court of Appeal for Ontario
- Jurisdiction
- Canada
- Judgment Date
- 21 January 2010
- Procedural Posture
- Criminal / Appeal to Court of Appeal From Ontario Review Board Fitness Determination
- Outcome
- Appeal dismissed
- Legal Topics
- Fitness to Stand Trial, Unfitness Due to Mental Disorder, Adequacy of Reasons, Standard of Review
- Source Language
- en
Source-derived case record
Summary, issues, holding and outcome
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Parties
Her Majesty the Queen
Respondent
Rodney King
Appellant
Brockville Mental Health Centre Hospital
Intervenor
Procedural Posture
Criminal / Appeal to Court of Appeal From Ontario Review Board Fitness Determination
Legal Issues
- 1 Whether the Ontario Review Board's finding that the appellant was unfit to stand trial was unreasonable
- 2 Whether the Board's reasons were adequate for appellate review
Ratio Decidendi
The Court dismissed the appeal, holding the Board's finding that the appellant was unfit was not unreasonable because the evidence showed delusional beliefs (believing himself subject only to the laws of Moses and separate from the charged individual) that rendered him unable to understand the nature and object of the proceedings; the Board's reasons, though not fully fleshed out, were adequate for appellate review.
Court Disposition
Appeal dismissed
Orders
- Appeal dismissed
Full Case Text
Judgment text and source record
1 paragraphs
R. v. King Collection Decisions of the Court of Appeal Date 2010-01-21 Neutral citation 2010 ONCA 42 Docket numbers C50469 Judges Winkler, Warren Keith; Goudge, Stephen Thomas; Watt, David Subject Criminal Decision Content CITATION: R. v. King, 2010 ONCA 42 DATE: 20100120 DOCKET: C50469 COURT OF APPEAL FOR ONTARIO Winkler C.J.O., Goudge and Watt JJ.A. BETWEEN: Her Majesty the Queen Respondent and Rodney King Appellant Rodney King, appellant appearing in person Michael Davies, amicus curiae Alexandra Campbell, for the respondent B. Walter Renshaw, for the Brockville Mental Health Centre Hospital Heard: January 15, 2010 On appeal from the decision of the Ontario Review Board dated January 22, 2009. APPEAL BOOK ENDORSEMENT [1] The appellant, ably assisted by Mr. Davies as amicus curiae, appeals the Ontario Review Board’s decision of January 22, 2009 that he was unfit to stand trial. Mr. Davies fairly concedes that there was evidence before the Board sufficient to avoid the conclusion that its decision was unreasonable. [2] The main argument was that the Board’s reasons are simply inadequate. In our view, the Board concluded, in light of the record before it, that the appellant was unfit due to his untreated mental disorder. He believed that he is subject only to the laws of Moses, and that he is a separate entity from the Rodney King who is charged with these offences. The Board clearly concluded that because of this delusion, the appellant was unable to understand the nature and object of the criminal proceedings, and was therefore unfit to stand trial. [3] While the Board’s resolution of the dilemma presented by the appellant could well have been more wholesomely explained, its reasons are sufficient for appellate review and that is the standard that it must meet. The appeal must therefore be dismissed.