Ontario Review Board
Re: Christine Strickland
ORB File No: 8261
Hearing held on: Monday, June 23, 2025
Place of hearing: Centre for Addiction and Mental Health 1001 Queen Street West, Toronto
Pursuant to: Section 672.81(1) of the Criminal Code
Before:
Alternate Chairperson: Mr. J. Weinstein
Members: Dr. L.E. Cappe Dr. L.O. Lightfoot Ms. M. den Haan Mr. A. Mete
Parties Appearing:
Accused: Christine Strickland Counsel: Ms. L. Shafran
The person in charge of hospital: Counsel: Ms. A. Marshall
Attorney General of Ontario: Counsel: Ms. S. Cressman
REASONS FOR DISPOSITION
(Dated August 6, 2025)
Introduction:
On March 15, 2023, Ms. Christine Strickland was found not criminally responsible on account of mental disorder, on charges of indecent acts and assault, both contrary to the Criminal Code of Canada (“Criminal Code”).
Ms. Strickland is subject to the terms of a Disposition of the Ontario Review Board (the “Board”), dated July 24, 2024, which orders that she be detained at the General Forensic Unit of the Centre for Addiction and Mental Health, Toronto (“CAMH”).
On June 23, 2025, the Board convened a hearing at CAMH to conduct the annual review of the current Disposition.
Ms. Strickland was present and was represented by her counsel, Ms. Shafran.
A Hospital Report (the "Hospital Report"), dated June 2, 2025, was entered as Exhibit 1.
The issue at this hearing is whether Ms. Strickland is a significant threat to public safety, as defined in s. 672.5401 of the Criminal Code. If so, the necessary and appropriate Disposition in the circumstances must be determined, bearing in mind the factors enunciated in s. 672.54 of the Criminal Code.
For the reasons set out below and based on the expert evidence and opinions before it, the Board concluded that Ms. Strickland continues to represent a significant threat to the safety of the public. The Board further ordered that the continuation of the existing Detention Order is the necessary and appropriate Disposition in the circumstances.
Current Psychiatric Diagnoses:
- Schizoaffective Disorder
Stimulant Use Disorder
Borderline Personality Disorder
Index Offences:
- The circumstances giving rise to the Index Offences are extracted from last year’s Board Reasons, as follows:
“Charges: Assault
Date of Offence: December 5, 2020
The following summary is based on a Synopsis for Guilty Plea dated December 5, 2020.
Ms. Strickland entered a streetcar and walked toward the rear. She approached the victim, who was a stranger to her, and without provocation, slapped and punched the victim on the right side of her face. Ms. Strickland then continued to the rear of the streetcar. The victim sustained minor injuries in the form of swelling and pain to her right temple. Paramedics were called to the scene; however, the victim did not attend hospital. Police located and arrested Ms. Strickland on the streetcar.
Charges: Assault x2, Mischief Under $5000
Date of Offence: January 3, 2021
The following summary is based on a Synopsis for Guilty Plea dated January 3, 2021.
Ms. Strickland entered 7-Eleven without a facial covering and was observed to be behaving erratically. When she was asked to leave, she became verbally aggressive and physically violent. She threw pebbles at the two victims and spat in their direction. Ms. Strickland also threw merchandise throughout the store, including a bar code scanner. Police arrived and placed Ms. Strickland under arrest.
Charges: Assault
Date of Offence: June 28, 2021
The following summary is based on a Synopsis for Guilty Plea dated June 28, 2021.
Ms. Strickland exited a streetcar and immediately ran towards a father who was walking his two-year-old child in a stroller, and slapped the child on the top of her head, causing the child to cry. Police were nearby and witnessed the unprovoked assault. Police approached Ms. Strickland, who became resistive to arrest. She was arrested after a brief struggle. The child sustained minor injuries in the form of soreness to the head.
Charges: Indecent Act, Assault Peace Officer
Date of Offence: July 19, 2021
The following summary is based on a Synopsis for Guilty Plea dated July 19, 2021.
Ms. Strickland was at Wellesley subway station and witnesses at the location noted she was without pants, socks, or shoes, engaging in indecent behaviour by touching her genital area, directly in front of the collector’s booth. Police officers arrived on scene and Ms. Strickland spat at the officer, striking her on the right side of her face and head. Ms. Strickland was placed under arrest."
Background Information:
- Ms. Strickland’s criminal history, background and personal history are outlined in the Hospital Report and are accurately summarized in last year’s Reasons, as follows:
“Ms. Strickland had no criminal history prior to the commission of the index offences.
Ms. Strickland was born and raised in the Toronto area. She has an older brother and a maternal half-sister. Her parents separated when she was approximately nine years of age and her mother passed away two years later. It was reported that her mother suffered from a bipolar disorder. At about age 14 Ms. Strickland began to display odd behaviour and affect and was observed speaking to herself. After becoming involved with an older boyfriend she left school during grade 10 and did not return. After her mother passed away, Ms. Strickland resided with various family members and in a number of different foster care settings. She was under the care of the Children's Aid Society.
As set out in the Hospital Report in detail, Ms. Strickland has had numerous admissions for psychiatric care to hospitals in the Toronto area. Her first admission to hospital was in 2014 when she was admitted on a Form 1 then a Form 3 for primary psychotic episode with manic features. It was also noted that substance abuse played a part in contributing to her symptoms. Over the course of the following seven years Ms. Strickland had approximately 20 different admissions to hospital. The last significant admission was from March 15, 2021 to June 7, 2021 to Ontario Shores. She was an involuntary patient during that time and was discharged on a Community Treatment Order (CTO). Her diagnoses at discharge included schizophrenia, antisocial personality disorder, and polysubstance use disorder.
Position of the Parties:
Counsel for the hospital, the Attorney General and for Ms. Strickland advised that this was a joint submission: all were adopting the hospital recommendation of a continuation of the existing Detention Order Disposition.
For the purposes of this hearing, counsel for Ms. Strickland advised that significant threat was not in dispute.
Course Since Last Disposition:
- Ms. Strickland’s course since her last Disposition is set out in detail in the Hospital Report. The following extracted paragraphs are relevant to this hearing:
“Ms. Strickland had a very positive year. She continued to reside on the Women’s General Forensic Unit, first under the care of Dr. I. Ray and later Dr. J. Dupré. There were no instances of unauthorized leaves of absence (ULOAs), substance use, or aggression requiring locked seclusion.
In the fall of 2024, Ms. Strickland agreed to optimize her clozapine dosage, which was gradually increased from 350 mg to 475 mg. She tolerated this increase well, with no reported adverse effects. This led to a significant improvement in her mental state, which became notably more organized, alongside a reduction in the intensity and frequency of auditory hallucinations. Her attention span and ability to engage in programming and discussions with staff also significantly improved.
Ms. Strickland’s participation improved throughout the year, with a notable shift in program engagement from recreational to therapeutic programming. Initially, she worked 1:1 with unit staff for programming, but Ms. Strickland ultimately joined and benefited from group programming, including forensic systems, dialectical behavioural therapy (DBT), and social skills. Additionally, she began weekly sessions with an individual therapist from FORCAT, Ms. Johnson, in psychotherapy starting in September 2024.
Ms. Strickland achieved indirectly supervised passes on hospital grounds for programming in January 2025. She participated in these passes successfully and without issues, attending the Therapeutic Neighbourhood and sessions with Ms. Johnson independently. In March 2025, she began indirectly supervised passes on hospital grounds for socializing. This represented significant progress for Ms. Strickland, considering her historical challenges with impulsivity.”
Evidence at the Hearing:
- The Board had available to it the evidence and documents forming the Record, the Exhibits, and oral evidence from Dr. Dupré. Dr. Dupré is Ms. Strickland’s attending psychiatrist and co-authored the Hospital Report. She testified as follows:
a) She has read, and adopts, the contents of the Hospital Report.
b) There is one positive update to the Hospital Report: Ms. Strickland has now agreed to participate in a neuropsychological assessment.
c) A further update is that Ms. Strickland returned late from an indirectly supervised hospital and ground passes last week, so the treatment team have placed these passes on hold. They are currently reassessing her behavioural plan, to ensure that she understands the expected behaviour when she is enjoying indirectly supervised hospital and ground passes.
d) The treatment team is hopeful that Ms. Strickland will qualify for DSO housing, based on her upcoming neuropsychological assessment. Qualification would expand the opportunities to find appropriate housing in the community for her, when she is ready to move there.
e) Ms. Strickland has had a very positive trajectory this year. She has been able to manage her behaviour, despite the many social stimuli that she is exposed to while on hospital and grounds. Ms. Strickland has been offered substances, and, to her credit, she has declined. She has not engaged in any substance use, as evidenced by her negative urine drug screens.
f) Ms. Strickland is currently participating in substance relapse prevention planning. As set out on page 14 of the Hospital Report, she began weekly sessions with an individual therapist from FORCAT.
g) With the continued optimization of her medication regimen, particularly the increases in her clozapine dosage, Ms. Strickland has improved her attention span and has participated more fulsomely in programming.
h) Ms. Strickland’s therapist is working with her on her distress tolerance and coping skills, to deal with stressors in the community. The treatment team is increasing her pass levels gradually, to ensure they can catch any signs of decompensation resulting from her limited ability to cope with stressors in the community or to manage her impulses when encountering them.
i) Ms. Strickland is currently on 465 milligrams of clozapine, and the treatment team is titrating this dose up very slowly, to avoid any side effects. The treatment team has noticed that her mental state has stabilized with the increase in dosage. However, she still is displaying symptoms of disorganization and some auditory hallucinations, especially when facing stressors in the community.
- In response to questions from counsel for Ms. Strickland, Dr. Dupré testified:
a) Ms. Strickland is not experiencing any side effects from the gradual increase in her dosage of clozapine. The treatment team is worried about risk of seizures, but Ms. Strickland is on appropriate anti-epileptic medication. She is very compliant with her medication regimen and her blood work, providing urine samples as requested.
b) It will be several months before a neuropsychological
c) assessment can occur. The treatment team is hopeful that they will be able to apply for both Passport funding and DSO housing, once they get the results of this assessment.
d) The treatment team’s plan is to increase Ms. Strickland’s clozapine levels in the coming reporting year, to not more than 550 milligrams.
e) The treatment team would like to see Ms. Strickland continue to engage in structured programming over the coming reporting year, as she greatly benefits from it.
- In response to questions from the Panel, Dr. Dupré testified:
a) Ms. Strickland is currently enjoying accompanied passes into the community. The next step in her progress is the use of indirectly supervised passes into the community.
b) Ms. Strickland’s mother passed away when she was a child, and Ms. Strickland was placed in many different Children's Aid Society (“CAS”) homes. There is no accurate report of any developmental issues during her youth. Ms. Strickland’s family describe her behaviour as having been odd; however, it is hard to know whether this behaviour was the result of her psychosis or her neurocognitive issues.
c) It would be helpful for the treatment team, and for Ms. Strickland’s applications for DSO funding and housing, to see what the CAS’s reports indicate regarding Ms. Strickland’s presentation as a child. The team will reach out to the CAS.
d) The treatment team has not yet started discharge planning for Ms. Strickland; they do not expect that she would be able to move into the community in the coming year. Ms. Strickland still needs to engage with the occupational therapist, to determine what housing would be appropriate. Ms. Strickland would need housing that would provide both monitoring of her oral medication and help with meals and upkeep of her apartment.
- No other evidence was called.
Analysis and Conclusions:
Having heard, and considered, the entirety of the evidence as well as the submissions from the parties, the Board agrees with the joint submission: Ms. Strickland remains a significant threat to the safety of the public. The Board further agrees that the continuation of the existing Detention Order is the necessary and appropriate Disposition.
In Winko, the Supreme Court outlined that, in coming to the conclusion on the issue of significant risk, a Review Board should closely examine a range of evidence, including: the circumstances of the original offence; the past and expected course of the accused’s treatment; the present state of the NCR accused’s medical condition; the NCR accused’s own plans for the future; the support existing for the NCR accused in the community; and most importantly, the recommendations provided by experts who examined the NCR accused. In coming to our conclusion in this matter, the Board relies on the uncontroverted expert evidence of Dr. Dupré, in addition to the documentary evidence before us.
Ms. Strickland has limited insight into her illness and its relationship to her risk of violence. She continues to experience residual symptoms of her major mental disorder and negative symptoms of schizophrenia. The treatment team is still optimizing Ms. Strickland’s medication regimen.
In particular, the Board relies on the Re-offence Scenario and the Composite Assessment of Risk, set out in the Hospital Report:
“Re-offence Scenario
In risk assessment, one of the best predictors is a patient’s history of violence. Ms. Strickland has a history of disorganized, dysregulated, aggressive, and sexually inappropriate behaviour while unwell. She has done relatively well since the alleged offences while admitted to CAMH, though she has required ongoing treatment with antipsychotic medications, and a detailed behavioural plan in order to reduce her intrusive, disruptive, and sexually inappropriate behaviours at times. If she were to reoffend, it would likely be in the context of suboptimal supervision, non-adherence to her medication regimen and/or substance use. In the event of a psychotic decompensation, Ms. Strickland would become increasingly unwell, with irritability, impulsivity, and would be at a heightened risk of acting out violently towards others.
Composite Assessment of Risk
Ms. Strickland’s alleged offence consisted of violence and aggression in the context of psychotic symptoms. While she has done well while residing on the inpatient unit at CAMH and being treated with antipsychotic medications, this could change rapidly in the event of increased stress, substance use, or medication non-compliance. She remains with limited insight into her mental illness and has yet to undergo formal psychoeducational programming. Given the above factors, Ms. Strickland represents a significant risk to the safety of the public absent ORB supervision.”
Ms. Strickland has had a very positive year, and we wish to commend her for her progress and for agreeing to engage in neurocognitive assessments. The Board also wants to congratulate Ms. Strickland on her participation in programming and her abstinence from substances.
In light of the Board's finding of significant threat, it is charged with shaping a Disposition for the coming year. The Board agrees with the team’s conclusions that Ms. Strickland’s risk of future violence would be moderate-to-high in the context of premature Conditional Discharge. The uncontroverted evidence before us is that Ms. Strickland would need some form of supportive housing in the community, to ensure adherence to her medication regimen and to monitor her mental stability when encountering stressor in the community. Therefore, the hospital needs the ability to approve her housing.
In consideration of all the evidence, submissions of the parties and criteria set forth in s. 672.54, the paramount consideration being public safety, in addition to the mental condition of Ms. Strickland, her reintegration into society and her other needs, the necessary and appropriate Disposition is to continue with the current Detention Order.
DATED this 6th day of August, 2025, at the City of Toronto, in the Region of Toronto.
Mr. J. Weinstein
Alternate Chairperson
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Office of the Registrar
Ontario Review Board