L. Madsen

The appellant appealed his convictions for sexual offences against children, which arose from guilty pleas.

He argued the pleas were involuntary due to pressure after his trial counsel was released and his adjournment request was denied, leaving him to face self-representation.

The Court of Appeal dismissed the appeal, finding the appellant failed to overcome the strong presumption that guilty pleas made in open court are voluntary.

The court held that emotional pressure and fear of self-representation did not impair his ability to make a conscious volitional choice.

The appellant, who was previously found not criminally responsible, appealed a Review Board disposition ordering his continued detention at a secure forensic psychiatric unit.

The appellant argued that he no longer posed a significant threat to public safety and that the detention order was not the least onerous disposition.

The Court of Appeal dismissed the appeal, finding that the Board's decision was reasonable and supported by evidence from a psychological risk assessment and the treating psychiatrist, which indicated a continued moderate-to-high risk of violent recidivism and a need for a gradual transition into the community.