R. Michael Rode

The appellant appealed his convictions for aggravated assault, assault with a weapon, and obstruction of justice.

At trial, the complainant was a hostile witness who claimed she could not remember making prior statements.

The trial judge admitted the complainant's out-of-court statements to a nurse and the police under the principled exception to the hearsay rule.

The Court of Appeal found no error in the trial judge's assessment of threshold reliability and dismissed the appeal.

The appellant appealed a decision refusing to grant a writ of habeas corpus regarding his transfer from a minimum to a medium security institution.

The appellant argued the transfer relied on confidential information that was not properly assessed for reliability.

The Court of Appeal dismissed the appeal, finding the transfer decision was procedurally fair, based on reliable evidence from a security information officer, and not unreasonable.