ONTARIO COURT OF JUSTICE
BETWEEN:
HIS MAJESTY THE KING
— AND —
DYLAN FARROW
REASONS FOR SENTENCE
Findings of Guilt on February 24, 2026
Submissions on June 24, 2026
Reasons delivered on July 23, 2026
Before Justice C.A. Brannagan
Mr. S. Dudani....................................................................................... counsel for the Crown
Ms. C. Barry ................................................................................ counsel for the Defendant
OVERVIEW
Dylan Farrow appeared before me on February 24, 2026, on what was scheduled to be the first of a multi-day trial. That morning, he pleaded guilty to eight charges. The Crown elected to proceed summarily.
Mr. Farrow pleaded guilty to a single count of assault causing bodily harm against Mr. Morgan Nicholson, a stranger to him. The next seven offences involved his former intimate partner, Summer Vincent, including: unlawfully in dwelling; threaten bodily harm; assault simpliciter; assault by choking x 2; assault with a weapon; and assault causing bodily harm.
The intimate partner violence (IPV) offences for which Mr. Farrow was found guilty spanned a period of 10 months. This is a classic case of domestic violence and coercive control.
These are my reasons for sentence.
FACTUAL BACKGROUND OF THE OFFENCES
The facts that were pleaded to, and acknowledged by Mr. Farrow, are as follows.
On September 14, 2024, just before noon, Mr. Farrow and another offender attended at the area of a McDonald’s restaurant on Dunlop Street in the City of Barrie. The two involved themselves in an altercation with a third man. A fourth man, Morgan Nicholson, attempted to intervene and stop Mr. Farrow and his associate from accosting the third man. With a closed fist, Mr. Farrow punched Mr. Nicholson in the face. He then spat on him. Mr. Farrow’s associate picked up a bicycle and threw it at Mr. Nicholson. Mr. Farrow and his associate then fled on bicycles, returning shortly thereafter on foot with baseball bats. By this time, police had arrived. Mr. Farrow tossed his baseball bat into a construction site and fled. Mr. Nicholson lost his tooth as a result of Mr. Farrow striking him in the face.
The balance of the allegations relates to Mr. Farrow’s (now-former) intimate partner, Summer Vincent. Their relationship lasted approximately 13 months, from November 2023 to December 2024.
On April 20, 2024, Mr. Farrow attended at Ms. Vincent’s residence. In the common hallway of her 2nd floor apartment, Mr. Farrow kicked Ms. Vincent in the stomach. He then punched her in the face, which caused her head to snap back, hit the wall, and fall to the ground; she lost consciousness. When she came-to, Mr. Farrow was gone. She attended at the Stevenson Memorial Hospital in the Town of Alliston where she was diagnosed with a concussion and a fractured left wrist. Ms. Vincent received five stitches to her upper lip.
On August 3, 2024, inside Ms. Vincent’s apartment, Mr. Farrow began yelling at Ms. Vincent. He slapped her in the face. He then grabbed a bottle containing an alcoholic beverage and poured it over her head. After he dumped the contents of liquid on her, he grabbed her by the neck and began choking her. He then spat in her face and told her that she deserved it.
On September 21, 2024, Mr. Farrow attended at Ms. Vincent’s apartment while intoxicated by alcohol. He accused Ms. Vincent of cheating on him. He grabbed her and forcefully threw her into the wall, before punching her on the left side of her face. Ms. Vincent suffered bruising on her left and right arms, and a contusion to the left side of her face.
On October 12, 2024, at approximately 1:20 a.m., again inside Ms. Vincent’s residence, Mr. Farrow recorded a video of her using her cell phone. He accused her of cheating on him. A short time later, while she was asleep on the living room couch, he took an empty glass jar and hit her in the face with it. He left the apartment, only to return 30 minutes later with a friend. Mr. Farrow entered the apartment and approached Ms. Vincent while screaming at her. He then punched her in the face and spat on her.
On December 29, 2024, at approximately 1 a.m., Ms. Vincent returned to her residence after a night out with a friend. A mutual friend was on the couch in the living room when she returned home, and Mr. Farrow overheard the two of them talking. Mr. Farrow accused Ms. Vincent of cheating on him with that person. He grabbed her by the neck with one hand and applied pressure, choking her. He then punched her in the face.
On February 10, 2025, while at her workplace, Ms. Vincent received a phone call from Mr. Farrow. He told her that he was going to smash her teeth in. He also told her that his girlfriend was going to smash her teeth in. Ms. Vincent reasonably feared that Mr. Farrow would make good on these threats.
Around the same time, police received a call from Ms. Vincent’s neighbour, who identified Mr. Farrow in the hallway outside Ms. Vincent’s apartment, yelling obscenities directed at Ms. Vincent.
When Ms. Vincent returned home from work that day, she found that her front door was unlocked, the inside of her apartment ransacked. In addition to property damage, she discovered a second set of her apartment keys, and her bank card, left on the kitchen island. These items had been in Mr. Farrow’s possession and were to be returned to her the following day. In the week leading up to this incident, Ms. Vincent had advised Mr. Farrow through a series of text messages and phone calls that he was not welcome at her residence.
VICTIM IMPACT
Section 722 of the Criminal Code requires courts to consider the harm suffered by victims of crime and the impact of the offence on them through victim impact statements.
Mr. Nicholson declined to provide a Victim Impact Statement (VIS).
Ms. Vincent completed a VIS (Exhibit #3), and she read into the record a poem she had written (Exhibit #4).
Concerning the role of victim impact statements in cases of domestic violence, the Court of Appeal for Ontario has directed that “Courts must be attentive to the effects of intimate partner violence and strive to understand the complainant’s experience and the full impact of the offences”: R. v. Greer, 2026 ONCA 222, at para. 32.
Victim impact should not, however, overwhelm the sentencing analysis: R. v. Fraser, 2016 ONCA 745, at para. 30.
In her VIS, Summer Vincent described profound and ongoing emotional trauma arising from abuse perpetrated by Mr. Farrow. She reports suffering from chronic fear, hypervigilance, panic attacks, nightmares and night terrors that leave her waking in fear and unable to feel safe, even within her own home. She expressed overwhelming feelings of heartbreak, guilt and shame, explaining that she had normalized and endured Mr. Farrow’s abuse while prioritizing his wishes over her own safety and the well-being of her young daughter.
Consequently, she reports a diminished sense of self-worth, difficulty trusting her own judgment and memories, and significant impairment in her daily functioning. She continues to receive extensive mental health treatment, including therapy, psychiatric care, medication, and participation in domestic violence and healing programs, while awaiting further inpatient treatment.
Ms. Vincent also detailed significant physical and lasting effects resulting from Mr. Farrow’s vicious assaults. She sustained injuries that required hospitalization, including a concussion, a split lip requiring five stitches, and a wrist injury requiring casting. She continues to bear a visible scar on her lip and experiences ongoing headaches and trauma-related symptoms.
Ms. Vincent described the impact of the domestic violence on her daughter, who witnessed repeated injuries to her mother and subsequently developed fearfulness, aggression, and sensitivity to raised voices and loud noises.
CIRCUMSTANCES OF THE OFFENDER
A pre-sentence report (PSR) was prepared and filed on consent. It is Exhibit #2 on this proceeding. Its purpose is to aid the court in assessing the offender’s background, character, attitude and risk of recidivism to craft a fit sentence: s. 721.
Mr. Farrow is 29 years of age. The PSR describes a difficult childhood marked by family instability, financial hardship, child welfare involvement, inconsistent parenting, and exposure to domestic violence and parental substance abuse within the home. Although Mr. Farrow denied experiencing significant trauma, collateral sources reported that he was exposed to domestic conflict and periods of neglect during his upbringing. The report notes that these childhood experiences may have contributed to later difficulties with emotional regulation, interpersonal relationships, substance abuse, and offending behaviour.
Mr. Farrow completed high school and subsequently obtained certification in HVAC studies, though he did not work in that area. He otherwise has a history of relatively stable employment, principally in the roofing industry. His most recent job was doing landscaping in Meaford in 2025, which ended with the change in season. He has not been working since he was released from custody on these charges and has been in receipt of Ontario Works to support himself.
The PSR identifies a significant history of substance abuse. Mr. Farrow reported longstanding alcohol misuse and an addiction to crack cocaine. He acknowledged that his substance use negatively affected his employment, family relationships, mental health, and involvement with the criminal justice system.
Impressively, at the time of the PSR, he self-reported abstention from drugs for more than one year, and alcohol sobriety for some six months. In 2025, he entered and successfully completed an outpatient addiction treatment program through the Brightshores Health System Wellness and Recovery Centre. Counsellors described him as highly engaged in treatment and reported meaningful progress in his insight, emotional regulation, and recovery efforts.
The report also identifies longstanding difficulties with anger management. Mr. Farrow acknowledged struggling with anger throughout his life and participated in extensive individual counselling focused on anger, communication skills, authority conflicts, and emotional regulation. His counsellors reported substantial gains by the conclusion of treatment.
Despite these positive developments, the report raises concerns regarding Mr. Farrow’s attitude towards the offences. The author noted that he continued to place significant responsibility on the complainant for the domestic violence incidents, described the relationship as toxic, and maintained that much of his conduct amounted to self-defence. The report observes that he minimized aspects of his behaviour, made derogatory comments about the victim, denied having issues relating to power and control, expressed limited insight into the impact of his actions on the victim, and did not express remorse during the interview process.
Mr. Farrow has a prior criminal record (Exhibit #1). In 2022, he was convicted of obstruct peace officer and assault. In 2023, he was convicted of fail or refuse to comply with breath demand, dangerous operation of a conveyance, and unauthorized possession of a prohibited or restricted weapon.
THE POSITIONS OF THE PARTIES
Mr. Dudani for the Crown
The Crown submits that these offences constitute serious intimate partner violence and engage the statutory aggravating factors relating to the abuse of a vulnerable female intimate partner. The Crown emphasizes that the conduct formed part of a sustained pattern of abuse over approximately ten months.
The Crown submits that significant weight should be given to the profound and ongoing impact on Ms. Vincent, including substantial psychological harm and lasting physical injuries.
The Crown acknowledges various mitigating factors, including the guilty pleas, the conservation of court resources, the avoidance of a trial for the victim, and Mr. Farrow’s efforts to address substance abuse and anger-management concerns.
The Crown maintains, however, that the PSR reveals a continuing lack of full insight into his conduct and its effects on the victim.
The Crown submits that a fit sentence is 12 months’ imprisonment, less credit for pre-sentence custody (3 days), followed by a 24‑month probation order, and relevant ancillary orders. The Crown submits that such a disposition appropriately balances rehabilitation with denunciation, deterrence, and the protection of the victims.
Ms. Barry for the Defence
The defence acknowledges the seriousness of the offences and the prominence of denunciation and deterrence in intimate partner violence cases but submits that those objectives can be met through a community-based sentence. Ms. Barry seeks a 12‑month conditional sentence order followed by 24 months’ probation, together with the ancillary orders requested by the Crown.
The defence emphasizes Mr. Farrow’s guilty pleas, acceptance of responsibility, and meaningful efforts toward rehabilitation, including completion of addiction treatment, Partner Assault Response programming, ongoing counselling, and sustained sobriety. Defence submits that the concerns regarding insight identified in the PSR should be viewed in the context of those rehabilitative efforts and the positive support reflected in letters filed on Mr. Farrow’s behalf.
The defence also relies on Mr. Farrow’s lengthy compliance with restrictive bail conditions. Counsel notes that he has spent approximately 16 months under house arrest, largely confined to his residence, unable to work or pursue normal activities, while remaining sober and engaged in treatment.
The defence submits that the offences were committed during a period of significant alcohol and crack cocaine addiction, a circumstance relevant to moral blameworthiness and rehabilitation.
Given all of this, counsel argues that a conditional sentence order with strict house arrest, curfew, and counselling conditions would appropriately balance denunciation, deterrence, rehabilitation, and public safety.
THE LAW
The Crime of Intimate Partner Violence
Intimate partner violence is a grave and pervasive social harm that attracts particular attention from both Parliament and the courts: R. v. Cunningham, 2023 ONCA 36, at paras. 49-52; Greer, supra, at paras. 23, 26 & 29.
The Supreme Court of Canada has reaffirmed that intimate relationships exist between equals, and are founded upon trust, intimacy, interdependence, and respect. Violence within such relationships is qualitatively different from violence between strangers because it constitutes both an assault upon the victim and a profound breach of trust: Ahluwalia v. Ahluwalia, 2026 SCC 16, at paras. 104-107.
Modern understandings of intimate partner violence extend well beyond isolated acts of physical aggression and include coercive and controlling conduct designed to undermine a partner’s autonomy, dignity, and independence through intimidation, humiliation, surveillance, manipulation, threats, isolation, and other forms of domination: Ahluwalia, at para. 7.
The sentencing objectives of denunciation and deterrence assume prominence in cases of intimate partner violence. Appellate courts have repeatedly stressed that sentences for domestic violence must communicate society’s condemnation of such conduct, promote accountability on the part of offenders, and foster an environment in which individuals may leave intimate relationships without fear of harassment, intimidation, or further violence.
In determining a fit sentence, courts must remain attentive not only to the immediate physical injuries suffered by victims, but also to the enduring psychological consequences that frequently accompany intimate partner violence. As our Court of Appeal has observed, domestic violence is an insidious crime whose effects often persist long after physical wounds have healed: R. v. Boucher, 2004 CanLII 17719 (ON CA), at para. 27; R. v. Ibrahim, 2011 ONCA 611, at para. 15; Fraser, supra, at para. 30; Cunningham, supra, at para. 26.
The seriousness of intimate partner violence can hardly be overstated. Parliament has directed sentencing courts to treat violence against intimate partners as an aggravating circumstance, reflecting society's heightened concern for this form of offending. The case law recognizes that prolonged patterns of coercive control and violence may attract substantial custodial sanctions, underscoring the gravity with which the law views violence within intimate partner relations and the paramount sentencing principles of denunciation and deterrence: Greer, supra, at paras. 25 and 39; R. v. Martin, 2009 ONCA 62; R. v. Young, 2003 CanLII 50102 (ON CA).
Relevant Sentencing Principles
- Every sentence must be proportionate to the gravity of the offences and the offender’s degree of responsibility, taking into account all relevant aggravating and mitigating factors: s. 718.1 and s. 718.2
Mitigating & Aggravating Considerations
- For Mr. Farrow, I find the following factors to be mitigating:
i. He pleaded guilty to these offences and took responsibility for his crimes. In doing so, he spared both victims from testifying and conserved considerable judicial resources. Given the nature of the allegations and the victim impact evidence, his plea carries meaningful weight, and I recognize his plea as a sign of his remorse.
ii. Mr. Farrow has engaged in significant rehabilitative efforts, including addiction treatment, counselling, and anger-management work. Historically, he has demonstrated an ability to maintain employment. He has shown encouraging prospects for reintegration.
iii. I also consider his difficult upbringing, including exposure to domestic violence and parental substance abuse, as contextual factors relevant to moral culpability and prospects for rehabilitation.
iv. Mr. Farrow has complied with restrictive release conditions for some 17 months. Those conditions significantly limited his liberty, employment opportunities, and daily activities. That carries mitigating value: R. v. Trudel, 2026 ONCA 403, at para. 5; R. v. Joseph, 2020 ONCA 733, at para. 108; R. v. Downes, 2006 CanLII 3957 (ON CA), at para. 33.
v. Mr. Farrow's prior criminal record, while not insignificant, is relatively limited and does not include previous convictions for intimate partner violence. This is not mitigating, but merely the absence of an aggravating factor.
- I find as aggravating the following factors:
i. The offences represent a prolonged course of coercive and controlling behaviour for close to a year. The violence repeatedly escalated, was frequently driven by possessive accusations of infidelity, continued after the relationship had deteriorated, and included threats and unlawful attendance inside the victim’s residence. Collectively, these circumstances demonstrate a sustained effort to dominate and control Ms. Vincent.
ii. Mr. Farrow repeatedly strangled Ms. Vincent on two separate occasions. Parliament has recognized strangulation as a particularly dangerous form of violence because of its inherent potential to cause death or serious bodily harm and its strong association with coercive control in intimate partner relationships. Section 267(c) was enacted to address crimes like those committed by Mr. Farrow in circumstances like these.
iii. The assault of April 20, 2024, resulted in significant physical injury, including a concussion, a fractured wrist, a laceration requiring five stitches, loss of consciousness, and a permanent scar. The extent of these physical injuries substantially aggravates the offender's conduct.
iv. The profound emotional impact of these offences upon the victim is a significant aggravating factor: 718.2(a)(iii.1); Exhibits #3 and #4.
v. The offending had a significant adverse impact beyond the immediate victim. Ms. Vincent's daughter was exposed to the aftermath of the violence and to her mother's repeated injuries. The foreseeable impact of intimate partner violence upon a child is an aggravating feature of this case.
vi. Mr. Farrow was in a relationship of trust with Ms. Vincent: s. 718.2(a)(iii); Cunningham, supra, at para. 27; Ahluwalia, supra at para. 106.
vii. The offender’s treatment of the victim – including multiple instances of spitting on her person, pouring alcohol over her, and attacking her while she slept – all within the confines of her own residence – constituted dehumanizing treatment intended to demean, humiliate, and subjugate her.
viii. Mr. Farrow abused his intimate partner, who is a vulnerable female person: s. 718.2(a)(ii); s. 718.201.
Conditional Sentence Orders, s. 742.1
The parties agree that a period of custody is warranted; the only question is where it should be served.
A sentencing court must be satisfied of four criteria before deciding to impose a conditional sentence order under s. 742.1: R. v. Proulx, 2000 SCC 5, at para. 46.
The first two statutory prerequisites are met in this case: the offences are not subject to a mandatory minimum penalty, and I am satisfied that a fit sentence would be less than two years’ imprisonment: s. 742.1; Proulx, at para. 46.
The third statutory prerequisite requires the court’s satisfaction that the safety of the community would not be endangered by the offender serving the sentence in the community. In Mr. Farrow’s case, he has proven through 17 months of strict bail compliance that he can manage himself in the community and that public endangerment is not a foregone conclusion: Proulx, at paras. 63 & 65.
The remaining issue, however, is whether the court is satisfied that a sentence served in the community would be consistent with the purpose and principles of sentencing set out in sections 718 to 718.2: Proulx, at para. 77-78; R. v. Faroughi, 2024 ONCA 178, at para. 102.
I have carefully considered whether the imposition of a community-based sentence would be a fit and appropriate disposition in the unique circumstances of this case, given Mr. Farrow’s unique offender profile.
Considering the sustained pattern of coercive control, repeated strangulations, serious bodily harm, profound victim impact, and the pressing need for denunciation and deterrence, I conclude that a conditional sentence order would not be consistent with the purpose and principles of sentencing. Accordingly, I decline to order that Mr. Farrow’s sentence be served in the community.
SENTENCING DISPOSITION
I sentence Mr. Farrow to 335 days of imprisonment, concurrent across all seven counts as they relate to Ms. Vincent, less 3 days pre-sentence custody enhanced at the usual 1.5:1 credit, leaving him 330 days to serve.
I sentence Mr. Farrow to a further 30 day’s jail on the assault causing bodily harm count against Mr. Nicholson, which sentence will be served consecutively to the global domestic violence sentence: s. 718.3(4)(b)(i).
Were it not for Mr. Farrow’s guilty plea, rehabilitative efforts, limited record, and the position advanced by the Crown, a substantially longer custodial sentence would have been warranted in these circumstances. Indeed, I would not regard an 18–24-month global sentence as being outside the appropriate custodial range for these crimes.1
Following completion of the custodial portion of this sentence, Mr. Farrow will be subjected to a Probation Order for 24 months, with the following terms:
i. Report to Probation within three business days of release from custody, and thereafter as directed;
ii. Reside at an address approved of by Probation;
iii. Take all counselling as directed by Probation and sign releases;
iv. Do not have any contact or communication, directly or indirectly, through any physical, electronic or other means with Summer Vincent or Morgan Nicholson;
v. Do not attend within 500m of any place either of the above-named persons are known to live, work, study, worship, frequent, or know them to be; and,
vi. Do not possess any weapon as defined by the Criminal Code.
- The threats count and each of the six assault-based convictions are eligible for a weapons prohibition order pursuant to s. 110(1)(a).
i. I make that order for a period of five years in relation to the count concerning Mr. Nicholson, pursuant to s. 110(2).
ii. With respect to the balance of the eligible counts concerning Ms. Vincent, I make that order for a period of 20 years, pursuant to s. 110(2.1)(a).
A DNA order is made on a primary basis pursuant to ss. 487.051 and 487.04(ix) for the convictions under s. 267, namely assault with a weapon, assault causing bodily harm, and assault by choking. I decline to make any DNA orders on a secondary or discretionary basis.
The $800 in victim fine surcharges is waived, pursuant to s. 737(2.1).
Pursuant to s. 743.21, Mr. Farrow is prohibited from communicating with either of his victims, directly or indirectly, during the custodial period of this sentence.
Released: 23 July 2026
Signed: Justice C.A. Brannagan
Footnotes
- The Court of Appeal for Ontario has previously found that a custodial disposition of six-to-eight months, followed by two years of probation, “appears to be at the low end” for a youthful first offender convicted of the offence of assault causing bodily harm under s. 267(b): see R. v. Huh, 2015 ONCA 356. More recently, it has been observed that similar sentencing considerations apply as between these elevated forms of assault and the offence of aggravated assault: see R. v. Seerattan, 2019 ONSC 4340, at paras. 35-36, where the range for these offences include non-custodial sentences in exceptional cases, intermittent sentences in the most mitigated cases, high reformatory sentences in the mid-range, and 4-8 years imprisonment in the most aggravated cases.