The appellant, who suffered from schizophrenia and represented himself at trial, appealed his first-degree murder conviction.
He argued he was unfit to stand trial and urged the Court of Appeal to overturn or modify the 'limited cognitive capacity' test from R. v. Taylor to require that an accused be capable of making rational decisions in their best interests.
The Court of Appeal affirmed the Taylor test, clarifying that while an accused must have a reality-based understanding of their legal predicament and the ability to make decisions, they need not possess 'analytic capacity' to make decisions in their own best interests.
The Court also dismissed grounds of appeal relating to the voluntariness of statements made to a Crown psychiatrist and refused to admit fresh psychiatric evidence to substitute a verdict of not criminally responsible.
