During long‑term offender sentencing proceedings, the defence sought to qualify a psychotherapist as an expert in the risk assessment of sexual offenders.
The proposed expert had administered certain assessment tools and prepared reports concerning the accused’s treatment and recidivism risk.
The court applied the admissibility criteria for expert evidence from R. v. Mohan and examined the witness’s qualifications, training, and professional background.
The judge concluded that the witness lacked sufficient training and expertise in risk assessment methodology to qualify as an expert in that field.
The witness was permitted to testify about treatment methods and testing used in therapy but was prohibited from providing opinion evidence on the accused’s risk of sexual recidivism.
