R. v. Holt

R. v. Holt

Because the trial judge materially misapprehended critical evidence about other employment—a misapprehension central to the finding of breach—the conviction could not stand; the appeal was allowed and, by agreement of the parties, the remaining conditional sentence was reinstated for the remaining 72 days under the...

Source-derived case information.

Citation
2008 ONCA 636
Parties
Respondent: Her Majesty the Queen; Appellant: Warren Holt
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
2 October 2008
Procedural Posture
Criminal Appeal / Appeal From Conviction
Outcome
Appeal allowed; remaining conditional sentence reinstated for 72 days under same conditions
Legal Topics
Conditional Sentence Breach, Burden of Proof, Misapprehension of Evidence, Reinstatement of Sentence
Source Language
en
Criminal Law Conditional Sentence Breach Burden of Proof Misapprehension of Evidence Reinstatement of Sentence

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Parties

Her Majesty the Queen

Respondent

Warren Holt

Appellant

Procedural Posture

Criminal Appeal / Appeal From Conviction

  1. 1 Whether the trial judge shifted the burden of proof to the appellant
  2. 2 Whether the trial judge materially misapprehended the evidence concerning the appellant's other employment, undermining the finding of breach

Ratio Decidendi

Because the trial judge materially misapprehended critical evidence about other employment—a misapprehension central to the finding of breach—the conviction could not stand; the appeal was allowed and, by agreement of the parties, the remaining conditional sentence was reinstated for the remaining 72 days under the same conditions.

Court Disposition

Appeal allowed; remaining conditional sentence reinstated for 72 days under same conditions

Orders

  • Appeal allowed
  • Conviction for breach set aside