Charles C. Conroy

The appellant appealed a disposition of the Ontario Review Board.

The Court of Appeal dismissed the appeal, finding that there was evidence to sustain the Board's finding of significant risk and that the order was not unreasonable when issued.

However, noting that the appellant's regular review was overdue and that fresh evidence suggested an emerging consensus that the appellant was fit to reside in the community under supervision, the Court ordered the Board to expedite the review.

The Crown appealed the sentence imposed on the respondent, arguing that the trial judge erred in failing to impose house arrest as a term of the conditional sentence order.

The Court of Appeal upheld the conditional sentence but varied the order to include house arrest, noting that the respondent's counsel conceded the error.

The appellant appealed a trial judgment that upheld a separation agreement.

The Court of Appeal assumed without deciding that the trial judge erred regarding the limitation period, but dismissed the appeal on the basis that the separation agreement was not unconscionable.

The uncontradicted evidence showed the respondent had assumed $112,000 in joint debts, resulting in a monthly deficit, justifying the agreement's terms.