Ontario Review Board
Re: Jamie Douglas Hall
ORB File No: 7911
Hearing held on: Wednesday, September 24, 2025
Place of hearing: Southwest Centre for Forensic Mental Health Care 401 Sunset Drive, St. Thomas
Pursuant to: Section 672.81(1) of the Criminal Code
Before: Alternate Chairperson: Mr. G. Beasley Members: Dr. T. Verny Dr. G. Stones Ms. K. Tomaszewski Ms. M. McKinnon
Parties Appearing: Accused: Mr. Jamie D. Hall Counsel: Mr. N. Gehl
The person in charge of hospital: Counsel: Ms. J. Zamprogna
Attorney General of Ontario: Counsel: Mr. D. Rows
REASONS FOR DISPOSITION
(Dated November 14, 2025)
Introduction
On June 21, 2021, Jamie Hall was found not criminally responsible on charges of being in possession of a weapon dangerous to the public peace, uttering a threat to cause bodily harm or death, failing to appear for court and failing to comply with a recognizance, all contrary to the Criminal Code of Canada. He is currently subject to a disposition of the Ontario Review Board (the Board), dated October 7, 2024, detaining him at the Southwest Centre for Forensic Mental Health Care, St. Joseph’s Healthcare London (the hospital). The disposition also provides him with discretionary privileges up to and including the ability to live in the community of Southern and Southwestern Ontario in accommodation approved by the person-in-charge.
On September 24, 2025, the Board convened to conduct an annual review of Mr. Hall’s current disposition. The Board and all parties appeared in person at the hospital. Mr. Hall was present and was represented by Mr. Gehl.
Initial Position of the Parties
At the outset of the proceedings the parties were canvassed as to their respective positions on the two issues to be examined by the Board: whether Mr. Hall continues to represent a significant threat to the safety of the public, and if so, the necessary and appropriate disposition having regard to the criteria set out in s. 672.54 of the Criminal Code of Canada.
Ms. Zamprogna, on behalf of the hospital, submitted that Mr. Hall continues to represent a significant threat to the safety of the public and the necessary and appropriate disposition is a conditional discharge with various conditions including a named residence clause, and a consent to treatment clause pursuant to s. 672.55(1) of the Criminal Code of Canada.
Mr. Rows, on behalf of the Ministry of the Attorney General, agreed with the hospital’s position.
Mr. Gehl conceded the issue of significant threat and agreed that the necessary and appropriate disposition was a conditional discharge as recommended by the hospital at the outset of the hearing. The Board had before it a joint submission.
For the reasons that follow, the Board finds that the threshold for significant threat has been met and that the necessary and appropriate disposition is a conditional discharge as recommended by the hospital.
Mr. Gehl, speaking for Mr. Hall, indicated that Mr. Hall consents to the treatment clause pursuant to s. 672.55(1) of the Criminal Code of Canada.
Index Offences
- This information was taken from the arrest report dated February 12, 2021, as found in the Hospital Report:
On Monday 06JUL2020 Jamie HALL (63/09/19) of No fixed address, entered into a Release Order (Recognizance - Toronto Police Service Case 2020-1243183.D14) before Justice Anne Judith MONTREUIL at the City of Toronto in the Province of Ontario. Hall is to abide by the various conditions listed in the abovementioned Release Order including 'Condition 7.' which specifically stated as follows: Do not possess any knives outside of a shelter, your residence or a food service establishment and only for the purpose of cutting food that you are consuming.
Counts 1 & 2:
On Thursday 11FEB2021 at 21:45hrs, the Police were dispatched to a weapons incident at Cedar St & Connaught St, Woodstock. The complainant Timothy David GEE [redacted] reported that a male brandished a knife in his face and threatened to slit his and his friend's throat.
According to GEE, he was sitting in his parked blue Ford F-150 pickup truck with his friend Kristopher GARDYNE [redacted] at the abovementioned location when an older male walked by them. GEE and GARDYNE looked at him and the male walked back to their truck. GEE and GARDYNE observed a knife the male's hand. GEE was sitting in the driver seat and GARDYNE was in the front passenger seat. The male approached the truck on GARDYNE's side and said "I am gonna slit your throat". The male waited there with the knife for a moment and walked away. GARDYNE's dog present outside the vehicle started barking, the male then walked back towards GARDYNE's dog before walking away. The male then returned towards GEE and GARDYNE's vehicle for the third time before heading northbound on Cedar St.
GARDYNE corroborated GEE's version of events and recalled the male stating that he was going to slit their throat and the dog.
Due to statements made by the male with the knife, GEE contacted the police and provided the male's description and direction of travel.
The Police arrived on scene at 21:49hrs and located a male matching the description walking northbound on Cedar St a short distance away from the incident location. The male had his hands concealed and walked towards an officer on the scene. Due to the nature of offence and threat assessment, the Police subdued the male by pointing a firearm and with tactical communication and successfully took him in custody. The male was known to the Police as Jamie HALL (63/09/19). The Police searched HALL incident to arrest which resulted in one silver/metallic folding pocket Knife in his possession. The knife was seized as evidence.
Count 3
A CPIC check revealed that HALL is not to possess knives as a condition listed in his Recognizance. HALL was not in his residence, a shelter, or a food establishment and was not cutting or consuming food. Therefore, HALL was in breach of his conditions contrary to the Criminal Code section 14S(S){a).
The Police arrested HALL for abovementioned weapons and breach of conditions offences.
Background
- The Hospital Report dated July 17, 2024, (Exhibit #1) provides a more detailed account of Mr. Hall’s history and background. They need not be repeated here but for the following material highlights, taken from last year’s Reasons and updated as necessary:
Mr. Hall is a 61-year-old man who was born and raised in Paris, Ontario. He was the youngest of five brothers. He dropped out of school after grade ten to work on the family farm and later worked in construction jobs. He has three children with whom he has not spoken for some time. His family did not want to be in contact with him due to safety concerns.
Mr. Hall has a significant criminal record beginning in 1981 when he was 18 years up to and including December 2020, shortly before the index offence. There are numerous convictions for violence and drug offences, and multiple mandatory weapons prohibitions. He has a history of problematic crystal methamphetamine and opioid use.
According to the Hospital Report, Mr. Hall’s first admission to hospital was in January1999. He presented at Woodstock General Hospital with symptoms of morphine withdrawal. He was diagnosed with narcotic addiction, a chronic pain syndrome and a personality disorder. Mr. Hall’s sister-in-law reported that Mr. Hall’s psychotic symptoms became apparent in the late 2010’s. For at least three years prior to the index offence, he would often speak about individuals persecuting him and stealing his money and inventions.
Between April and September of 2020, Mr. Hall was brought to hospital by police a number of times. On one occasion, he had tried to attack a security guard with a stick. On another, he threatened a stranger with a knife. In September 2020, he was found to be in possession of knives and Molotov cocktails. On each occasion, he endorsed psychotic symptoms, paranoia and delusional thought content in particular, he believed that he had a microchip in his teeth or his ear. Further, he was observed responding to internal stimuli.
Mr. Hall’s diagnoses are schizophrenia, substance use disorder (in remission within a controlled environment) and antisocial personality traits.
Mr. Hall has an extensive criminal record, as set out at pages 3 to 7 of the Hospital Report. The record includes numerous convictions for assault, threats, weapons offences, and failing to comply with bail conditions or probation orders.
Evidence at the Hearing
Dr. Ajay Prakash, Mr. Hall’s attending psychiatrist, adopted the Hospital Report dated July 18, 2025, and testified on behalf of the hospital.
Mr. Hall has had a very successful year in the community. Despite the removal of the abstain clause from his disposition in 2023, and despite access to alcohol and other substances during the reporting period, Mr. Hall has remained abstinent and has been able to communicate openly with the team about his refusal to drink alcohol with a neighbour. All toxicology screens have been negative for the use of alcohol and other substances.
Mr. Hall has had no symptoms of schizophrenia since prior to 2023.
On March 24, 2025, Mr. Hall moved to Visvacare Residence Group Home, an assisted living facility, located in London, Ontario. This home is less supervised as compared to Clark Centre but provides medication administration, meals, appointment reminders and laundry services. He continues to be supported by the Forensic Supportive Housing Program (FSHoP) staff through St. Leonard’s Community Services which provides ongoing case management and housing stability support, including bi-weekly check-ins during the transition period from Clarke Centre. He is also supported by the forensic outpatient treatment team.
Dr. Prakash commended Mr. Hall for remaining abstinent despite living in accommodations where substances and alcohol are available, and he is subject to less supervision than at the Clarke Centre.
Mr. Hall typically reported a stable mood, with some irritability, but this was not a management issue. He found it challenging when plans changed at short notice and more amenable to changes perceived ahead of time. He experienced some difficulty with his memory and complex multi-step tasks (e.g., financial support and applications).
Mr. Hall reported that his main source of stress was his decrease in income upon moving to his new home at Visvacare. With that said, he appeared to adapt well by rebudgeting his income, going to Tim Hortons less, and purchasing cheaper cigarettes. He initially expressed that not having a television (due to affordability) was going to be upsetting but proactively sought other activities to fill his time, such as reading. He was offered a recliner chair by the former residential Manager of Clarke Centre and able to organize the relocation of the chair to Visvacare independently.
It was reported that following Mr. Hall’s transfer to Visvacare his affect appeared brighter. He adjusted well to his new environment by building a routine that worked for him. Visvacare staff reported that Mr. Hall has been kind and socialized well with the staff and peers. Visvacare Manager reported that she wished she had more tenants like Mr. Hall and that he is doing very well. He has developed his own daily structure. He spends his time watching television and reading books from the local public library. He engaged in walks around the neighborhood and visited Tim Hortons. There have been no reported concerns in the new home.
Mr. Hall is reported to be exhibiting a good sense of humour. Dr. Prakash told the Board that this is an indicator of how well he interacts with the team.
Over the past year, Mr. Hall has had no relapse into substance use and no decompensation of mental status. He has been more friendly and outgoing with the treatment team. He has been more able to handle stress, including the stress of moving. In the last few weeks, he was attacked by a peer in his home but did not respond with violence and was able to reach out to the treatment team for support.
Dr. Prakash attributed Mr. Hall’s success this year on the level of structure, supervision, and support he receives in his current living situation.
Mr. Hall is waiting for Indwell permanent supportive housing in Woodstock. This program offers enhanced support that is defined as: 24/7 staffing/support, supper meal provided, furnished one bedroom apartment, laundry and activities in house for social and recreational purposes. As of March 2025, Indwell staff reported processing applications from 2019. An additional two-year wait is anticipated before Mr. Hall will have Indwell accommodations in Woodstock.
Mr. Hall receives the Canada - Ontario Housing Benefit (COHB) which is portable and is being applied to his current residence. He is managing financially with this supplement and ODSP.
Mr. Hall likes living at Visvacare. Initially, he did not want to remain there but recently stated he might do so. Visvacare is available to Mr. Hall on a long-term basis.
Mr. Hall’s dose of suboxone was increased during the reporting period. Mr. Hall finds suboxone helpful. However, Dr. Prakash’s evidence was that Mr. Hall is now internally motivated to remain abstinent, and that in the doctor’s opinion, suboxone is not a main protective factor.
Dr. Prakash indicated that the level of supervision provided to Mr. Hall helps him to remain abstinent.
Dr. Prakash was asked about Mr. Hall’s comment in 2024 that he would stop his medication if given the choice. Dr. Prakash explained that Mr. Hall is adherent but requires a high level of supervision to remain adherent.
Mr. Hall is incapable of consenting to treatment and will need the support of a Community Treatment Order (“CTO”) and ACT Team if he is not in the forensic system.
In reference to Mr. Hall’s lengthy criminal record, Dr. Prakash opined that the onset of psychosis was in 2010, and that it was possible that the criminal record was a result of pre-diagnosis actions impacted by untreated mental disorder, financial difficulties, homelessness, and addiction. The key to preventing this history from repeating itself is appropriate treatment, structure, and support.
Dr. Prakash stated that currently, with structure, routine and medications, Mr. Hall is doing very well. The doctor expressed the hope that Mr. Hall will continue to maintain his current routines and structure if and when he moves to Woodstock.
Prior to the move to Woodstock, should that occur, the treatment team would need to take Mr. Hall there for visits to the community and with family, to assess his ability to maintain stability in that community.
Dr. Prakash was asked why the risk assessment provided the same level of risk for a detention disposition and a conditional discharge. The doctor responded that the key under both dispositions is the appropriate level of supervision, structure and support.
The plan for the coming year is to gradually reduce the amount of support and supervision provided by the treatment team, to assess Mr. Hall’s stability, as it is still “early days” living in the community with a reduced level of supervision.
Dr. Prakash told the Board that the mental Health Act will be sufficient to manage Mr. Hall’s risk in the community. He lives in close proximity to the hospital, and the treatment team can see him quickly. He has on-site supervision, and the treatment team has good communication with staff at his home. He is incapable of consenting to treatment. If he decompensates, he can be brought into the hospital under the Box B “substantial mental deterioration” criteria.
A detention disposition is not necessary, for the reasons set out in the Hospital Report. The residency clause is necessary and appropriate because Mr. Hall wants to move to Woodstock, and it is necessary this year to keep him close to the hospital in accommodation with an appropriate level of supervision and support.
No further evidence was adduced.
The parties maintained their initial joint submission.
Analysis and Conclusion
The threshold issue for the Board to determine is whether Mr. Hall continues to represent a significant threat to the safety of the public. In analyzing the evidence at the hearing on this point, the Board has considered the judgement of the Supreme Court of Canada in Winko, 1999 CanLII 694 (SCC), [1999] 2 S.C.R. 625. The Board is also aware of a series of decisions from the Ontario Court of Appeal including Wall (Re), 2017 ONCA 713; Pellett (Re) 2017 ONCA 753; Marchese (Re), 2018 ONCA 307; Abdikarim (Re), 2017 ONCA 793; Medcof (Re), 2018 ONCA 299, Marmolejo (Re), 2021 ONCA 130, and Gibson (Re), 2022 ONCA 527. The risk must not be speculative but must be a real risk of serious physical or psychological harm arising from a criminal offence.
The Board has considered the Hospital Report, the evidence of Dr. Prakash and the joint submission and unanimously finds that Mr. Hall continues to represent a significant threat to the safety of the public. He currently has a diagnosis of Schizophrenia. He has a long history of substance use, which is currently in remission. His future ability to remain abstinent in a less structured/less supervised environment than the Clarke Centre has not yet been fully assessed. He also has a long criminal record that includes crimes of violence and failure to comply with supervision. Mr. Hall’s ability to remain stable with a gradual decrease in the level of supervision will need to be assessed over the upcoming year.
The Board relies on the reoffence scenario set out at page 85 of the Hospital Report:
Absent forensic supervision, Mr. Hall would likely become non-adherent to his antipsychotic medication and refrain from initiating mental health services to support his ongoing stability in the community. Without some level of supervision, future housing may become complicated without oversight, acknowledging that Mr. Hall requires assistance with more complicated processes. Mr. Hall remains content in living at Visvacare; however, this is not his long-term housing goal. Without added support and some level of supervision for his mental health and housing, he may resort to historic behavioural patterns of substance use to cope. He would likely then decompensate which would impact his current housing, illnesses and treatment.
The Board accepts the risk factors set out on pages 95-96 of the Hospital Report:
Mr. Hall's insight into his violence risk and mental illnesses remain limited. He would likely not adhere to antipsychotic medication if left to his own devices;
Mr. Hall requires some supervision around community application processes (e.g., FRO, housing, ODSP etc.) and to maintain his stability while living in the community; and
Mr. Hall has no personal or professional mental health support outside the forensic system. He will require community mental health supports and a psychiatrist to manage his ongoing treatment and medication in the community to which he would not obtain on his own.
The Board notes that many of these risk factors can potentially be addressed by a CTO combined with the support of an ACT Team. The Board strongly encourages the hospital to begin the process of obtaining this type of community support for Mr. Hall during the upcoming year, despite Mr. Hall’s stated long-term goal of living in Woodstock.
The timing of a potential move to Woodstock remains uncertain. The waitlist is anticipated to be as much as an additional two years, but this is only an estimate. Mr. Hall has not yet been assessed with respect to his stability when exposed to the stressors of moving to Woodstock and being in closer contact with his family. Mr. Hall enjoys where he now lives. He is doing very well and might decide to remain living in London.
Having found that Mr. Hall represents a significant threat to the safety of the public the Board must consider the necessary and appropriate disposition taking into consideration the criteria set out in s. 672.54 of the Criminal Code of Canada, which includes the need to protect the public from dangerous persons, the mental condition of the accused, the integration of the accused into society and the other needs of the accused.
The Board agrees with the joint submission that the necessary and appropriate disposition is a conditional discharge with the conditions proposed by the hospital.
The evidence indicates the Mental Health Act will be sufficient to manage Mr. Hall’s risk to the public, and to return him to the hospital promptly if his mental status deteriorates. Mr. Hall will be subject to a residency condition and will remain in accommodation which provides him with the necessary supervision and support. Mr. Hall consents to the treatment clause.
Mr. Hall is doing very well in his current accommodation and has remained abstinent from substances despite their availability and less supervision than at the Clarke Centre.
Dr. Prakash stressed that the most important factors in mitigating Mr. Hall’s risk to the public are externally applied supervision, structure and support. The Board is satisfied that the conditions proposed by the hospital will provide the necessary structure, supervision, and support and are sufficient to manage Mr. Hall’s risk to the public while promoting his integration into the community.
Having considered the factors set out in s. 672.54 of the Criminal Code of Canada, the Board unanimously agrees with the joint submission and finds that the necessary and appropriate disposition is a conditional discharge with the privileges as proposed by the hospital at the outset of the hearing and as set out in the Board’s Disposition.
The Board congratulates Mr. Hall and wishes him continued success in the upcoming year.
DATED this 14^th^ day of November 2025, at the City of Toronto, in the Region of Toronto.
Ms. K. Tomaszewski Legal Member
Office of the Registrar Ontario Review Board