The appellant, a police constable appealing a conviction for deceit, brought a preliminary motion requesting that a Commission member disqualify himself on the ground of perceived bias.
The motion was based on a newspaper article written by the member criticizing the Special Investigations Unit, and a letter from the Police Association of Ontario expressing a lack of confidence in the member.
The Commission dismissed the motion, finding that an informed person, viewing the matter realistically and practically, would not conclude that the member had a bias that would impede his ability to decide the appeal objectively and impartially.