LaForme J.A.

The appellant, previously found not criminally responsible for criminal harassment and other offences, appealed a disposition of the Ontario Review Board continuing her detention.

She argued she was entitled to an absolute discharge as she only posed a risk of minimal harm.

The Court of Appeal dismissed the appeal, finding the Board's disposition was reasonable and supported by the evidence, though it encouraged the Board to explore community integration at her upcoming annual review.

The appellant, an Ontario corporation, sued its former North Carolina legal counsel in Ontario for professional negligence arising from a North Carolina action.

The motion judge stayed the action for lack of a real and substantial connection to Ontario, but failed to consider the appellant's argument that Ontario should assume jurisdiction as a forum of necessity.

On appeal, the Court of Appeal held that while the motion judge erred in ignoring the argument, the appellant failed to meet the high threshold for the forum of necessity doctrine.

The appellant's inability to retain counsel in North Carolina did not make it an exceptional case justifying the assumption of jurisdiction.