Dr. Marc Patry

The defendant, Liban Omar, charged with first degree murder, sought to admit expert psychological evidence from Dr. Marc Patry regarding false confessions and "Mr. Big" operations during a voir dire concerning the admissibility of Omar's statements to undercover officers.

The court applied the Mohan and Abbey tests for expert evidence admissibility, finding that while Dr. Patry was qualified and the evidence logically relevant, it was not necessary to assist the jury.

The court concluded that the dangers of "Mr. Big" confessions could be adequately addressed through jury instructions, as established by Supreme Court of Canada jurisprudence in R. v. Hart and R. v. Mack, and was bound by R. v. Osmar.

The expert evidence was deemed unnecessary and therefore inadmissible.