Re: Richard James Easton
ORB File No: 7389
Hearing held on: Tuesday, April 29, 2025
Place of hearing: Southwest Centre for Forensic Mental Health Care 401 Sunset Drive, St. Thomas, ON
Pursuant to: Section 672.81(2.1) of the Criminal Code
Before:
Alternate Chairperson: Mr. R. Steinberg
Members: Dr. T. Verny Dr. M. Kalia Ms. K. Tomaszewski Ms. B. Little
Parties Appearing:
Accused: Mr. R. J. Easton Counsel: Mr. S. F. Gehl
The person in charge of hospital: Counsel: Ms. J. Zamprogna
Attorney General of Ontario: Counsel: Ms. K. Dalrymple
REASONS FOR ROL DECISION
(Dated May 13, 2025)
Introduction
On July 19, 2018, Mr. James Easton was found not criminally responsible on account of mental disorder on charges of uttering threats to cause death to unnamed members of the RCMP and to the Canadian military, all contrary to the Criminal Code of Canada. Mr. Easton is currently subject to a disposition of the Ontario Review Board (the “Board”) dated October 7, 2024, which ordered him detained at the Southwest Centre for Forensic Mental Health Care, St. Joseph's Healthcare London (the “hospital”), subject to a series of conditions with privileges up to and including living in the community in accommodation approved by the person in charge.
The Board received a letter from the hospital dated April 1, 2025, advising the Board that Mr. Easton had been subject to a restriction of liberty (the “ROL”) pursuant to section 672.56(2)(b) of the Criminal Code of Canada (the “Code”). The letter stated that “Mr. Easton was readmitted to the Southwest Centre on March 24, 2025. Prior to admission in hospital he had been living in an independent apartment, located at 700 King Street in London, Ontario, a housing property managed by St. Leonard’s Community Services, since April 12, 2024 [although]he had a brief return to hospital from August 7 to August 12, 2024, for concerns regarding his mental status.”
On April 29, 2025, the Board convened a hearing to review the ROL pursuant to s. 672.81(2.1) of the Code. Mr. Easton was present and represented by counsel, Mr. Gehl. Ms. K. Dalrymple represented the Ministry of the Attorney General and Ms. Zamprogna represented the hospital.
Initial Position of the Parties
At the outset of the hearing counsel were canvassed with respect to their positions. Counsel for the hospital took the position that the ROL was necessary and warranted at the time and continued to be so; that Mr. Easton poses a significant threat to the safety of the public; and that the necessary and appropriate disposition is a continuation of the existing detention disposition. Counsel for the Attorney General adopted the position of the hospital.
Counsel for Mr. Easton took the position that the ROL was necessary and warranted at the time it was initiated, but that he could take no position on whether the ROL continued to be necessary and warranted until he heard the evidence. Counsel for Mr. Easton took the position that he did not seek any changes to the current Disposition. Inherent in this position is that Mr. Easton did not challenge the hospital’s position that he poses a significant threat to the safety of the public.
In closing submissions counsel for Mr. Easton took the position that the ongoing ROL was necessary and warranted.
The Board had before it a joint position. For reasons discussed below, the Board adopts the joint position of the parties with respect to the ROL and the Disposition.
Index Offences
- The circumstances giving rise to the index offences are excerpted from last year’s Reasons:
"It appears that for some time prior to November 2017, Mr. Easton had been posting YouTube videos with bizarre content. He had over 5,000 followers. On November 4, 2017, he posted two videos, which were the subject matter of the index offences. One of the videos was directed towards the RCMP and the other to the Canadian military, though