Ontario Review Board
Re: Matthew Curran
ORB File No: 8122
Hearing held on: Tuesday, September 23, 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 Ms. K. Tomaszewski Mr. A. Mete
Parties Appearing:
Accused: Mr. Matthew Curran Counsel: Mr. F. Retar
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 July 25, 2022, Mr. Curran was found not criminally responsible (“NCR”) of charges of Utter Threats (x2), Use a Firearm While Committing an Indictable Offence, Assault with a Weapon (x3), and Possession of a Prohibited Firearm. 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 (the “hospital”) with privileges up to and including living in the community in accommodation approved by the person in charge.
On September 23, 2025, the Board convened a hearing at the hospital, to determine whether Mr. Curran represents a significant threat to the safety of the public as defined in s. 672.5401 of the Criminal Code and, if so, what is the necessary and appropriate disposition taking into account the factors set out in s. 672.54 of the Criminal Code.
Ms. Zamprogna represented the hospital. Mr. Rows represented the Attorney General. Mr. Retar represented Mr. Curran. Mr. Curran was present.
Mr. Curran’s mother and father and current girlfriend attended the hearing to support Mr. Curran. The Board wishes to acknowledge its appreciation of their support for Mr. Curran.
Initial Position of the Parties
- At the commencement of the hearing, the parties were requested to provide their initial positions with respect to the issues before the Board. Counsel on behalf of the hospital submitted that Mr. Curran did represent a significant threat to the safety of the public and that the necessary and appropriate disposition is a continuation of the current detention order with privileges up to and including residence in the community in approved accommodation, with several changes to clause 2, the most significant of which are set out below:
passes for up to 48 hours, in the Province of Ontario, accompanied by a person that is approved by the person in charge of the Southwest Centre, with approved itinerary;
passes for up to 48 hours, in the Province of Ontario, indirectly supervised, with approved itinerary;
passes for up to one week, up to 2 times per year, in the Province of Ontario, accompanied by a person that is approved by the person in charge of the Southwest Centre, with approved itinerary;
Counsel for the Attorney General supported the hospital’s position. Counsel for Mr. Curran conceded that for the purposes of the hearing, Mr. Curran remains a significant threat to the safety of the public and agreed with the hospital’s recommendations with respect to the necessary and appropriate disposition.
The Board had before it a joint submission.
Index Offences
- The allegations giving rise to the index offences are taken from last year’s Reasons as follows:
“It was noted that on February 13, 2021, police received a phone call from Mr. Mike Curran stating that his son, the accused, was in possession of an AKA-47 assault rifle with 47 rounds wanting to attend an address in Chatham to kill an individual named Chad Bloom. During the conversation with dispatch, it was also revealed that the accused wanted to go to 6 Daniels Place in Chatham to shoot his brother Josh Curran.
The accused was in a vehicle with his girlfriend, Melissa Lozon, at the time of the incident. It was also revealed that the accused might have consumed a 26-ounce bottle of rum prior to the incident. Information received was that Melissa was attempting to have the accused put the gun down and lock it in the trunk of the vehicle. The accused and Melissa Lozon were in a blue Ford Fusion just outside of the City of Chatham. Melissa was able to calm the accused somewhat and told him she was taking him back to his parents' residence. Melissa advised the accused to hold the firearm on his lap in the front passenger seat of the vehicle while being driven back to his family’s residence. T was noted that the police attempted a cell phone ping on Lozon’s cell phone due to information that the accused was being driven in a vehicle with what was described as a loaded assault rifle. The ping came back and put her location in Chatham. Upon the accused and Lozon’s arriving at 606 Daylight Place, (the father of the accused), Mike Curran, called the police, stating that the accused was pointing what he described as an assault rifle at him. The accused’s father was concerned for his safety and stated that if the accused sees him on the cell phone he would be shot.
Officers that arrived on scene and contained the residence in question observed the accused pacing throughout the residence yelling and screaming and pointing firearm at the victims inside the house. It was noted that the officers could hear loud yelling and screaming coming from inside the residence. Numerous times offers officers could hear the accused yelling, “You need to help me, you need to get the charges dropped, this is your fault, all I ever wanted was to be a police officer, you gave me up to them, why wouldn't you protect me.” During this period police were able to observe the accused through a large window walking throughout with an assault rifle. The accused pointed the assault rifle at the victim several times and appeared to have the rifle strapped around his neck. The accused’s father advised that numerous times the accused would switch the safety to armed and off as a sign of intimidation.
It was noted that upon the accused realising the residence was surrounded by police, he became more irate. He learned this by opening the front door. Police observed the accused in possession of the assault rifle and pointing it towards the victims while continuing to yell at them. The accused then opens the back door and walked outside to the yard. This is when Lozon comes to the front door in bare feet and starts running out; she is taken into police custody.
It was noted that the accused continued to walk around the rear yard and the accused’s father followed him and pleaded with him to surrender to police. The accused continued to accost his father and point the assault rifle at him and blaming him. While continuing to yell the accused pointed the assault rifle in the direction of where the officers were staged. The accused’s father continued to plead with the accused to stop and give him the assault rifle. The accused’s mother was unable to come out the open front door while the accused was in the backyard was taken into police safety. At one point, the accused’s father was on his knees pleading while the accused pointed the firearm towards him and yell at him. The accused then went back inside the residence and presented himself at the front door while pointing the assault rifle towards the direction of officers. The accused’s father, then came back inside the residence and closed the front door.
Police were also able to listen through an open phone line inside the house. The Critical Incident Response team arrived on scene and were able to set up successful negotiation contact with the accused. From approximately 02:44 hours 03:15 hours negotiations were successful and prompted the accused to exit the residence.
Prior to coming out of the residence, the accused’s father was able to secure the assault rifle. The accused was arrested and placed into custody without further incident and was transported to Police Headquarters.
It was noted that at 02:24 hours, the accused’s mother advised the officer that “this incident is over Matthew receiving a phone call regarding his firearms officer badge. Matthew felt like he was being questioned and challenged on his authority.
Background
Mr. Curran is currently 27 years of age, was born in London Ontario and raised in the Chatham Ontario area. His father worked as a sergeant with the Chatham police. In 2014, around the time he was 15 years of age he spent time with his half-brother who was living on a military base in New Brunswick after having served tours of duty in Afghanistan. While there he was exposed to the suicide of two individuals.
Mr. Curran has a grade 12 education and aspired to become a police officer. He also was enrolled in a Police Foundations Program at Lambton College but has not completed the program. In elementary school he was identified as having ADHD and attended a residential school program when he was 12 where he was prescribed Vyvanse 50 mg and is reported to have had a “robust” response.
Mr. Curran family report that in 2020 Mr. Curran would dress up in military uniforms and told them he was going to a stake out. He would also wear police clothing.
Although Mr. Curran has no criminal record, he did have at the time of the index offences an outstanding charge of impersonating a peace officer shortly before the index offences. The Crown withdrew that charge subsequent to Mr. Curran’s NCR finding.
Psychiatric History
A summary of Mr. Curran’s psychiatric history is taken from last year’s Reasons.
Mr. Curran had never been hospitalized due to mental health related issues prior to the index offences. In September 2019 Mr. Curran attended an appointment with a psychiatrist who indicated that he believed Mr. Curran suffered from PTSD, generalized anxiety disorder, panic disorder, depressive disorder (current episode moderate), ADHD, alcohol use disorder moderate, cannabis use disorder mild and borderline personality disorder. He was prescribed an antidepressant and referred to psychological services.
On initial admission to Hospital Mr. Curran was largely cooperative and polite and denied any hallucinations or delusional thoughts. However, during the initial period of his admission he was noted to have rapid speech at times, presented as grandiose, asserting experience beyond his years and intrusive. He had difficulty with a redirection with respect to his grandiose claims and attempted to dominate many conversations with staff and peers and talk about his past experiences claiming to have training with the police in evasive driving, a black belt, and two golden gloves.
In early July 2022, his behaviour began to improve after his antidepressant medication was stopped and continued to improve when oral antipsychotic medication started at the end of July 2022. It was the opinion of the Hospital treatment team in 2022 that Mr. Curran is overall a prosocial individual and that the medication previously prescribed to Mr. Curran in fact made his illness worse.
Mr. Curran’s current Diagnoses are Bipolar Disorder, type 1, in remission; Attention Deficit Hyperactivity Disorder; Narcissistic Personality Traits (rule out narcissistic personality disorder); Substance Use Disorder (alcohol, cannabis by history); and Post-Traumatic Stress Disorder (PTSD) by history.
Evidence at the Hearing
The evidence at the hearing consisted of a Hospital Report dated August 11, 2025; an Update to the Hospital Report dated September 5, 2025; and the oral evidence of Dr. Arun Prakash, Mr. Curran’s attending psychiatrist.
Mr. Curran was discharged from the hospital to live in his parents’ home in Chatham on August 13, 2024. Mr. Curran remained in the community until January 13, 2025, when he was admitted to the Rehabilitation Unit B1. He remained in hospital until February 18, 2025, when he was placed on a 30-day Leave of Absence (LOA) to his parents' house. He was discharged from inpatient care on March 18, 2025.
On January 12, 2025, Mr. Curran’s mother initiated a telephone call with the Officer in Charge of the Southwest Centre, stating that Mr. Curran had been caught on camera hitting a parked car, that he failed to remain at the scene, and that the police were looking for him. It is not thought that alcohol was in his system at the time of the car accident. This incident is described on page 36 of the Hospital Report:
Mr. Curran stated that on December 26, 2024, around 9 am, he was driving, reportedly not intoxicated, to get coffee for himself and his father. He reported that he lost control of his vehicle, skidded, and hit a car, which then hit several other cars. He stated that he did not know how to react. He did not want to go to the police or tell his parents, so he drove home and told them that his car had been hit in the parking lot at Wal-Mart.
Due to the above information, it was arranged for Mr. Curran to be brought to hospital by his parents for an assessment of his mental status, to which he was cooperative. On January 13, 2025, he was admitted to Southwest Centre on the Rehabilitation Unit B1. During his admission meeting with treatment team members, Mr. Curran acknowledged drinking alcohol once, a few days before the above accident. He said he was alone and drank to help with his negative feelings. He reported drinking around seven shots of Rum and became intoxicated but did not black-out. He explained that drinking led to some levels of disinhibition, and he started to say his parents should not have saved him the previous time he wanted to kill himself (the index offence). His parents confirmed this information and also added that, unlike the index offence, Mr. Curran did not become violent towards them. Upon admission, his mood was sad, and he presented with somewhat a labile affect (restricted during the initial interview, reactive and bright when he met with peers on the unit, fearful and tearful in the late afternoon). He identified being laid off from his job and the termination of a tumultuous intimate relationship as adding to his distress.
Mr. Curran continued to make what the treatment team believed were impulsive decisions, and that there were changes to his daily structure and routine from week to week. He was noted to become intensely engulfed in the activities and tasks of his choosing, committing and spending vast amounts of his time participating in them, with an all or nothing approach. He was also noted to present with significant impression management, as he desired to appear as though everything was going great, that he was able to manage situations, and that he did not require assistance or formal support.
Mr. Curran frequently changes his employment plans. He volunteered to assist with coaching a university football team as a defensive coordinator. This transitioned to paid 1:1 personal training with a high-school student. The 1:1 work was terminated when he was admitted to the hospital in January 2025, and he did not restart following his discharge back to the community. He ceased volunteering for the football team in late May 2025, as he reported that the team moved him out of the Defensive Lineman position and into a Linebacker position, and he could not "grasp" the position.
He continued to change his desired employment route based on the opportunities offered to him. He appeared well-networked and socially resourceful, which resulted in jobs being offered to him. He continued to encounter roadblocks to working in the security guard field, as he was often only working night shift hours, which were not conducive to maintaining his mental health, given his vulnerability to instability resulting from sleep disruption.
In early December 2024, Mr. Curran was laid off from his position at the car dealership with no return-to-work date indicated. Following this, he reported the desire to study the Ontario Motor Vehicle Industry Council’s information to sell cars and look for a sales job." However, upon returning from the Westover Resident Treatment program in May 2025, he was offered a casual position with an asphalting company, which he accepted.
Mr. Curran reported visiting a local tattoo parlour on May 8, 2025, discussing various styles of tattooing. During this visit, he reportedly asked how difficult it was to become a tattoo artist, and the owner handed him fake skin to try. He recalled doing "reasonably well,” and as a result was offered to apprentice at this location to become a tattoo artist. He estimated that the apprenticeship, before receiving payment, will take 6 weeks to 6 months. Since this time, Mr. Curran has spent significant amounts of time at the tattoo shop practicing and helping with the day-to-day functions. The tattoo apprentice position remains unpaid until he can work with paying customers.
In August 2025, Mr. Curran was offered a job opportunity with Auto Motion where he would be transporting purchased vehicles to the geographical location of their new owner. Initially he requested that the hospital support him, via recommendation to the ORB, with the ability to travel coast to coast within Canada. In reflection of the challenges the clinical team would have to manage this and in collaboration with Mr. Curran, it was decided that the team could only support travel within Ontario. Following this meeting, Mr. Curran approached Auto Motion about only travelling in Ontario, to which they agreed. His father reported to the Outreach team that he planned to travel with Mr. Curran for these jobs, if the Outreach team required that an approved person accompany him.
The sole purpose of expanding Mr. Curran’s community passes, as recommended by the hospital, is to support Mr. Curran’s latest job opportunity with Auto Motion.
As noted above, Mr. Curran completed the Westover residential substance relapse prevention program in May 2025.
On August 7, 2025, the Outreach contacted Mr. Curran and informed him that his urine sample from August 06, 2025, came back positive for cocaine. During the phone call, the Outreach team inquired if he had used any substances. He denied the use of cocaine, stating that he has not used cocaine since high school. He did suggest that he had been at some bars and parties lately, drinking cranberry juice, and that he had left his drink unattended, and wondered if someone had put some substance in his drink. He was informed that the team would confirm the sample, and it may be a false positive, however, the confirmation was also positive for cocaine. He was cautioned against attending parties and leaving his drink unattended in situations where someone could put a substance in his drink. He was also reminded that he is responsible for his drink.
Dr. Prakash told the Board that one week prior to the hearing, Mr. Curran was asked to provide a urine sample. He declined, saying that he was unable to provide a sample because he was fasting for Mohammed’s birthday. He was informed by Dr. Prakash that he was required to provide a urine sample prior to the annual hearing.
On the Friday prior to the hearing (the hearing was held on a Tuesday), Mr. Curran provided a urine sample. Drug screen tests indicated a positive result for cocaine. This will be confirmed with further testing.
Mr. Curran’s explanation for both positive cocaine tests is that he met with his ex-girlfriend, who lives in the encampment in Chatham, and uses substances. He met her in a bar/restaurant, to put closure to the relationship, and she spiked his drink with cocaine, on two occasions. Dr. Prakash indicated that he did not find this to be a credible explanation of Mr. Curran’s ingestion of cocaine on either occasion.
Mr. Curran agreed to be admitted voluntarily to the hospital, following the Board hearing.
Mr. Curran’s father told the treatment team that he had noticed that Mr. Curran had scattered thoughts, and had increased his spending, which Dr. Prakash noted are indications of hypomania. Cocaine is a stimulant. If Mr. Curran is already hypomanic, the use of cocaine will trigger mania. There are no medications which will curb the craving for cocaine.
According to Dr. Prakash, Mr. Curran does not yet recognize, and has not internalized, the early warning signs of a relapse of Bipolar symptoms. He will be unlikely to accept the need for medication changes once his mood changes. On two occasions this year Mr. Curran either delayed or missed his injectable medication.
Mr. Curran’s main triggers for relapse of Bipolar symptoms are non-compliance with prescribed medications; psycho-social stressors (even while receiving pharmacological treatment); substance use; and sleep issues. Sleep is one of the most critical non-medication aspects of the management of Mr. Curran’s bipolar disorder.
At an abstract level, Mr. Curran understands that sleep hygiene is important, but he has not yet appreciated that he will need to forgo employment/careers that can put good sleep hygiene at risk.
With respect to Mr. Curran’s insight into how psycho-social stressors can impact his risk for relapse, Mr. Curran has tended to be overconfident about his ability to manage stress. Mr. Curran has a history of taking on more and more hours at work, while minimizing the potential impact on his sleep and stress levels.
Mr. Curran was diagnosed with Bipolar at an early age and has had mood swings with and without substance use. His risk of relapse is high, and substance use significantly enhances his risk of violent behaviour.
He is very vulnerable to substances that will alter the effect of his medications. Alcohol and substances will trigger hypomania. Mr. Curran should not use any alcohol or substances. During the reporting period, Mr. Curran used alcohol in December and cocaine in August and September. Mr. Curran admits to attending bars.
During Mr. Curran’s upcoming admission to the hospital, the treatment team will discuss medication changes, including a possible increase in mood stabilizer medication, and possible adjustments to his antipsychotic medication. Mr. Curran will not be able to accept employment which involves the operation of a motor vehicle until the treatment team has determined that the side effects (if any) from medication changes will not have a negative impact on driving safety.
During the upcoming hospitalization, the treatment team will also consider appropriate discharge planning and community placement. Although Mr. Curran’s goal is to live independently, Mr. Curran is not yet ready to live independently in the community. Mr. Curran will need to live in a supervised setting.
Dr. Prakash indicated that it is not clear at this point whether the hospital will approve a return to living with Mr. Curran’s parents. While Mr. Curran’s parents have been extremely supportive of Mr. Curran, it is a difficult role to be both parent and supervisor. Setting appropriate boundaries, and limits on spending, are crucial to Mr. Curran’s recovery, but are understandably extremely difficult for parents to enforce.
Prior to the admission to the hospital on January 13, 2025, there were instances where Mr. Curran’s parents provided inaccurate information or hid information from the treatment team (i.e. dates that Mr. Curran was not at work, information about the date he became intoxicated). When confronted with this, his parents explained that the poor communication with the treatment team was due to a fear of the Board and limiting his progress through the forensic system.
As a result, and prior to Mr. Curran's return to the parents' home in 2025, it was agreed that this placement could only occur with complete transparency of information for risk management. At this point, independent contact (telephone or in-person) with the parents increased to almost weekly. Mr. Curran's parents agreed that they would no longer comply with their son’s request for information to be kept confidential from the Outreach team, stating that they were "willing to share everything, not going back, Matt is not going to influence us.”
During last year’s hearing, Dr. Quinn expressed that the upcoming year would be an important period for assessing Mr. Curran’s ability to adhere to the limits set by his parents and the team; to remain stable without relapsing into substance use; to remain stable on his medications; and to manage stress realistically. If Mr. Curran is able to do these things, Dr. Quinn was of the opinion that it was possible that the team could consider a conditional discharge in a year. Recent events have shown that Mr. Curran was unable to avoid relapsing into substance use. He is not yet ready for a conditional discharge.
In Dr. Prakash’s opinion, Mr. Curran’s risk of relapse continues to be high. He is still at the early stage of his recovery, and he is in an early stage of community reintegration. He has recently relapsed into cocaine use.
Although there were some positive signs in his community integration this past year, there are also some warning signs around his increase in stress. The Mental Health Act (“MHA”) would be insufficient at this juncture to manage his risk and intervene in a timely matter in the community. By the time Mr. Curran is certifiable under the MHA, the risk of harm to the public will be intolerably high.
Dr. Prakash testified that if the recommendations of the hospital are accepted, the hospital will implement them in a stepwise fashion only after all medication changes and other adjustments, and his living situation, are in place.
Dr. Prakash stated that he has not had an opportunity to discuss any details with the treatment team since Mr. Curran’s most recent cocaine use and readmission to the hospital. However, speaking for himself and not on behalf of the treatment team, Dr. Prakash testified that if the most recent cocaine use had been known prior to the preparation of the Update, he would not have supported the Auto Motion job or the recommendations for changes to the passes which are designed to support that employment opportunity.
No further evidence was given by the parties.
In final submissions Ms. Zamprogna emphasized that Mr. Curran has experienced two relapses into substance use and that he has not been forthcoming with the treatment team about them. Mr. Curran will be admitted to the hospital when the hearing concludes for observation post cocaine use, to adjust his medications, and possibly to find different supervised accommodation. Mr. Curran’s insight is not fulsome. There has been no change in his risk since last year. A detention order is necessary and appropriate. The recommended changes to the disposition are designed to streamline Mr. Curran’s employment potential and simply shift discretion from the Board to the hospital. The hospital is not relying heavily on the proposed recommendations.
Mr. Rows confirmed the joint submission, and highlighted the hospital’s submissions, emphasizing that great care was appropriate with respect to increasing Mr. Curran’s privileges.
Mr. Retar urged the Board to accept the recommended changes to the disposition.
Analysis and Conclusion
For the Reasons that follow, the panel found that the threshold for significant threat is met, and that the necessary and appropriate disposition is a detention order with no changes to the current disposition.
The threshold issue for the Board to determine is whether Mr. Curran 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 finds that the joint submission that Mr. Curran represents a significant threat to the safety of the public is well supported by the evidence, and takes particular note of the following set out at pages 50-51 of the Hospital Report:
Mr. Curran has a major mental illness, bipolar disorder. While his symptoms have been relatively well controlled, in the past, when symptomatic, it has led to serious violence and dysregulation in the past.
Though Mr. Curran’s bipolar disorder symptoms were in remission, his personality disordered traits, which historically led to increased instability, were prominent over the year in review, and led to an admission to the hospital. He recently returned to live with his parents, who historically struggled to manage boundaries with him.
Mr. Curran’s insight into the index offence, illness triggers, treatment, and risk for violence is underdeveloped;
While Mr. Curran has been mainly concordant with his medication regimen with supervision, there were times when he did not have his medication readily available for the Outreach team to administer. He will continue to require supervision to be medication compliant.
Mr. Curran engaged in substance use over the year in review, which resulted in an increase in his risk to the community and an admission to the hospital.
Mr. Curran’s personal supports are primarily limited to his parents who are also the victims of the index offence; and
Mr. Curran’s professional supports are limited to the forensic outreach team, and he has not been forthcoming with professional supports, who have often had to double-check the reliability of his self-report over the year. He does not have any community-based mental health supports at this time.
The Board notes that the reoffence scenario, set out at page 49 of the Hospital Report is well supported by the evidence:
Absent forensic supervision and support, Mr. Curran would likely move out of his parents home to live independently. Initially, he would engage in several commitments, more than he would be able to take on, which would increase his stress. This would lead to conflictual relationships with others, such as coworkers/employers, romantic partners, and/or parents, and he would push boundaries. Increased stress would lead to a relapse of manic symptoms, which may be compounded by inappropriate stress-coping mechanisms (such as spending excessive money on cryptocurrency or relapsing into substance use). He would ultimately respond with violence to individuals who he believed had wronged him, as in the index offence.
- The Board agrees that:
Mr. Curran continues to require a detention disposition to provide him with the supervision, monitoring and support that is necessary, and it is felt that any other alternative disposition would be inadequate to manage the risk. His insight into his mental illness, need for treatment, and violence risk remains underdeveloped. Although he was agreeable with the most recent hospital admission, the incidents surrounding his admission again showed his lack of transparency with both his parents and the Outreach team. It is felt that it is essential for him to remain on a detention disposition to enable prompt intervention and return him to the hospital again if required. It will also allow his housing to be approved in order to ensure appropriate placements, as historically he has made poor choices regarding his living environment. The provisions of the Mental Health Act would not be sufficient to mitigate the risk to public safety. (Hospital Report page 51)
Given the seriousness of the potential risk and given that Mr. Curran could be living with the victims of the index offence, the evidence clearly supports that the hospital needs to have sufficient authority to return Mr. Curran to hospital should there be signs of decompensation prior to his risk becoming sufficient to justify hospitalization under the MHA.
While the Board commends Mr. Curran for having returned voluntarily to the hospital twice during the reporting period, Dr. Prakash’s evidence indicates that Mr. Curran is not aware of the early warning signs of a relapse of symptoms. He did not acknowledge his use of alcohol in December until after his mother had contacted the treatment team about the car accident. Similarly, he did not acknowledge his use of cocaine until after urine drug testing detected cocaine in August and September. On both occasions he did not admit to voluntarily using cocaine. The Board finds it likely that Mr. Curran will not be aware of his need to return to the hospital if he relapses. A warrant of committal is necessary to ensure his return to the hospital if he relapses.
The hospital also needs the authority to approve accommodation to ensure that Mr. Curran is in an environment conducive to his continued rehabilitation, particularly if Mr. Curran is not successful in maintaining stability in his parents’ home, as is potentially indicated by his recent use of cocaine.
A conditional discharge is not necessary or appropriate at this time.
The Board’s deliberations focused on the inclusion of the proposed expansion of passes. The Board declined to expand Mr. Curran’s passes for the following reasons.
The purpose of the expanded passes, as recommended jointly by the parties, is to support Mr. Curran’s employment opportunity with Auto Motion. Those recommendations were made before Mr. Curran’s most recent use of cocaine. Dr. Prakash indicated that if the second use of cocaine had occurred and had been known by the hospital prior to considering changes to the disposition to support the Auto Motion job, Dr. Prakash would not have supported the proposed expansion of passes, or the Auto Motion job.
Currently, the job opportunity with Auto Motion is speculative. Mr. Curran has recently been admitted to the hospital, and the length of his stay is unknown. His return to the Chatham area to live is not certain. It is unknown whether Auto Motion will hire Mr. Curran for the job when they become aware of his relapse into cocaine use. It is unknown whether medication side effects will have a negative impact on Mr. Curran’s ability to drive safely. It is unknown whether Mr. Curran will maintain stability and abstinence once he returns to living in the community, sufficient to enable the treatment team to safely manage Mr. Curran’s risk to the safety of the public if he accepts employment that requires him to travel throughout the Province of Ontario.
In addition, the recent use of cocaine increases the risk that Mr. Curran’s bipolar symptoms will return and also increases the risk that he will continue to use substances. Both of these types of relapses will increase Mr. Curran’s risk to the safety of the public. In this context, it is neither necessary nor appropriate to expand Mr. Curran’s passes.
It is not appropriate to delegate the issue of safety to the public to the hospital by expanding Mr. Curran’s passes for the purpose of a speculative employment opportunity.
After carefully considering the evidence and the parties’ submissions, the Board found no evidence to support a change to the current disposition.
Accordingly, Mr. Curran is ordered detained at the Hospital with privileges up to and including residence in the community in approved accommodation, with no changes to the provisions in the current disposition.
In coming to this decision, the Board has taken into account the factors set out in s. 672.54 of the Code, including the safety of the public, which is paramount, and has determined that a detention disposition with the terms described above is the necessary and appropriate disposition in the circumstances.
DATED this 14^th^ day of November 2025, at the City of Toronto, in the Region of Toronto.
Ms. K. Tomaszewski Legal Member
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Office of the Registrar Ontario Review Board

