Joanna Elizabeth Bliss

Following convictions for sexual exploitation, sexual assault, incest, and assault against a child family member, the Crown sought a dangerous offender designation under Part XXIV of the Criminal Code.

The court considered whether the pre‑2008 or post‑2008 dangerous offender regime applied and held the earlier regime governed because the offence period straddled the legislative amendments and the offender was entitled to the benefit of the lesser punishment.

Expert psychiatric evidence established alcohol abuse disorder, coercive sexual preference paraphilia, and mixed personality disorder, together with actuarial assessments placing the offender in a high risk category for violent and sexual recidivism.

The court concluded there was no reasonable possibility that the offender’s risk could eventually be controlled in the community, even with intensive supervision, medication, or treatment under a long‑term supervision order.

The offender was therefore declared a dangerous offender and sentenced to an indeterminate period of detention.

Following convictions for multiple violent offences including assault with a weapon, threats, forcible confinement, and assaults on police, the Crown applied to have the offender declared a Dangerous Offender under s. 753 of the Criminal Code.

Expert psychiatric evidence established a high risk of violent recidivism, particularly in intimate partner relationships, and demonstrated a pattern of repetitive and persistent aggressive behaviour.

Although the statutory criteria for a Dangerous Offender designation were met, the court accepted expert evidence that intensive institutional treatment followed by community supervision could reasonably manage the offender’s risk.

The court therefore imposed a determinate penitentiary sentence followed by a long-term supervision order rather than an indeterminate sentence.

Parole eligibility was delayed to ensure sufficient institutional programming before release.