In a prosecution for possession of fentanyl and cocaine for the purpose of trafficking and possession of proceeds of crime, the Crown sought to qualify a police officer to give expert opinion evidence on drug trafficking practices.
Applying the Mohan threshold criteria and the White Burgess gatekeeper analysis, the court held that expert evidence concerning cocaine and fentanyl trafficking practices, including pricing, quantity, packaging, user consumption habits, purchase patterns, conduct, and indicia of trafficking, was logically relevant, necessary, and sufficiently reliable.
The officer's training and experience holistically established specialized knowledge outside the court's ordinary experience, and there was no realistic concern about impartiality.
However, the Crown failed to establish the relevance of proposed oxycodone evidence after staying the oxycodone charge.
The officer was therefore qualified only in relation to cocaine and fentanyl.
