Re: Omar Haddad
ORB File No: 8605
Hearing held on: Tuesday, August 5, 2025
Place of Hearing: St. Joseph’s Healthcare Hamilton, West 5th Campus
Pursuant to: Sections 672.81 (1) & 672.81 (2.1) of the Criminal Code
Before: Alternate Chairperson: Ms. J. Mills Members: Dr. J. Kis Dr. S. Swaminath Mr. E. Siebenmorgen Mr. A. Mete
Parties Appearing: Accused: Omar Haddad Counsel: Mr. A. Confente
The person in charge of hospital: Counsel: Mr. S. O’Brien
Attorney-General of Ontario: Counsel: Mr. B. Adsett
REASONS FOR DISPOSITION AND DECISION (Dated August 22, 2025)
Introduction
On July 26, 2024, Omar Haddad was found not criminally responsible on account of mental disorder (“NCR”) on a charge of arson – damage to property, contrary to the Criminal Code. Mr. Haddad was most recently subject to his initial Disposition of the Ontario Review Board (“ORB” or “the Board”) dated October 21, 2024 pursuant to which he is ordered detained at the Forensic Psychiatry Program of St. Joseph's Healthcare Hamilton, West 5th Campus (“SJHCH” or “the Hospital”), subject to various conditions and privileges, up to and including community living in the Hospital’s catchment area in supervised accommodation approved by the person in charge.
By way of a letter dated May 30, 2025, the Hospital provided Notice to the Board, pursuant to s. 672.56 (2) of the Criminal Code, of an increased restriction on Mr. Haddad’s liberties (a readmission to the Hospital from the community) that exceeded seven (7) days.
On Tuesday, August 5, 2025, a panel of the Board convened in person at the Hospital to inquire into the circumstances and to determine: (a) whether the Hospital’s actions constituted a significant increase in the restrictions upon Mr. Haddad’s liberties; and (b) if so, whether the increased restrictions were warranted and justified, both at the time that they occurred and for their duration. In addition, the panel conducted the annual review of Mr. Haddad’s Disposition. The issues to be determined at the annual review were: (a) whether Mr. Haddad represents a significant threat to the safety of the public within the meaning of s. 672.5401 of the Criminal Code and, if so, (b) what is the necessary and appropriate Disposition having regard to the factors in s. 672.54 of the Code.
Mr. Haddad attended the hearing and was represented by his counsel, Mr. Confente. Mr. Haddad’s mother and one of his sisters had intended to attend the hearing as well. However, the hearing time had been moved forward, and they were unable to attend at the revised time. The panel offered to delay the hearing until Mr. Haddad’s family arrived; however, counsel advised that his client’s instructions were to proceed with the hearing without delay. Accordingly, the hearing proceeded without the attendance of family members. The panel notes, with appreciation, their support of Mr. Haddad.
The evidence for the hearing consisted of the Hospital’s Restriction of Liberties (“ROL”) Report dated July 10, 2025, the Hospital Report dated July 18, 2025, and the oral evidence of Dr. Y. Naidoo, Mr. Haddad’s attending psychiatrist.
Circumstances of the Readmission to the Hospital
- Mr. Haddad had been discharged to reside in his apartment at First Place in Hamilton on April 7, 20251. He was readmitted to the Hospital on May 22, 2025, and discharged back to his residence on June 10, 2025. According to the July 10th ROL Report:
“Mr. Haddad was admitted to Waterfall 3, Forensic Inpatient Unit, from the community on May 22, 2025, because of concerns regarding decompensation of his psychotic symptoms. He displayed behaviour that was not in keeping with his baseline mental status. He raised his voice and was described as being quite oppositional with his case manager. He had been smoking cigarettes increasingly, which was suspected to have lowered his Clozapine blood level.”
Positions of the Parties
- When canvassed for their initial, without prejudice positions at the start of the hearing, counsel for all parties expressed agreement that the Hospital’s actions in readmitting and subsequently maintaining Mr. Haddad as an inpatient from May 22 to June 10 were warranted in the circumstances and represented the least onerous and least restrictive measures available. The parties further agreed that Mr. Haddad represents a significant threat to the safety of the public and that the necessary and appropriate Disposition is a Detention Order containing the same terms and conditions as found in the Disposition dated September 16, 2024. They maintained their respective positions at the conclusion of the evidence.
Findings
- For the following Reasons, the panel accepted the parties’ joint position and found, independently, that the Hospital’s actions in readmitting and subsequently detaining Mr. Haddad were warranted and represented the least onerous and least restrictive measure available for the management of Mr. Haddad’s risk to public safety. The panel also found that Mr. Haddad represents a significant threat to the safety of the public and that the necessary and appropriate Disposition is a Detention Order, unchanged from his initial Disposition.
Index Offence
- The basic circumstances surrounding the index offence are found in the Hospital Report. In the late evening of April 11, 2023, Mr. Haddad’s sister called police to report an arson involving her brother, Omar. He was observed on surveillance on that date igniting an accelerant on the main floor of his family’s residence in Brampton. He then left the area in a motor vehicle. He was located and arrested approximately one hour later in Orangeville, Ontario. A jerry can was seized by police at the time of his arrest. Damage to the family residence exceeded $100,000. Fortunately, no injuries were reported.
Background Information
Mr. Haddad was 38 years of age as of the hearing date. He was born in Lebanon and came to Canada with his family when he was four years old. He is single and has no children. He was involved in one intimate relationship that ended after five years. He has a limited employment history and has a diploma in culinary arts from a community college. His personal and psychiatric history are detailed in the Hospital Report. As the Report is in evidence as an Exhibit at the hearing, the information need not be reproduced here for the purpose of these Reasons. Some features, reviewed below, provide helpful context for the issues at the hearing.
Mr. Haddad is currently capable to make treatment decisions and is financially capable. He had feen found incapable of consenting to treatment on several occasions in the past. His diagnoses as reported in the ROL Report are:
- schizoaffective disorder, bipolar type;
- other hallucinogen use disorder (mushrooms); and
- cannabis use disorder, in remission in a controlled environment.
Substance Use History
Mr. Haddad has a significant history of substance use that is associated with his mental state and behaviour. He self-reported starting to drink alcohol at age nine and stated that he first became intoxicated at age 15. He also began using cannabis at age 15. He consumed alcohol regularly during a period while employed in the roofing industry. Subsequently, he drank daily, consuming an average of two to four beers per day, until 2009 when he was diagnosed with schizoaffective disorder. During his criminal responsibility assessment, Mr. Haddad denied all history of cravings for alcohol or any difficulties in cutting back on his alcohol use.
Returning to Mr. Haddad’s cannabis consumption, he described a pattern of regular use, with intermittent periods of abstinence and relapses over the years from age 17 onward. Clinical records noted that Mr. Haddad endorsed smoking between one and two grams of cannabis daily for many years. He recently reported having stopped smoking cannabis regularly in November 2023, due to cannabis-induced paranoia. However, clinical records indicated ongoing use to the date of the NCR verdict.
Mr. Haddad acknowledged that he enjoyed the positive effects of cannabis, noting, “sometimes it made me very happy.” Clinical records revealed that Mr. Haddad has also previously endorsed agitation, worsening delusions, and religious preoccupation related to his cannabis use. His sister reported, at the time of his psychiatric admission in September of 2020, that Mr. Haddad had exhibited psychotic symptoms since 2009, coinciding with his cannabis use. During a psychiatric admission in the spring of 2021, it was reported that Mr. Haddad’s substance use, along with his psychosis, was a reason why his family did not allow him to return to the home, requiring the hospital to find accommodation for him in the shelter system.
Mr. Haddad reported also having consumed hallucinogens (mushrooms) starting at age 19. He started consuming mushrooms daily in 2022 and estimated that he was “microdosing” 0.3 to 0.4 grams of mushrooms twice per day. He said that he stopped using them after two or three months. He accessed his supply of mushrooms online. At the time of his criminal responsibility assessment, he acknowledged having cravings for mushrooms.
Mr. Haddad was hospitalized at SJHH from June 29 to November 15 of 2022. He had initially presented to the Emergency Department with thoughts of suicide in the context of substance use and non-compliance with medications. He reported using one to two grams of cannabis daily for several years and had also using hallucinogens (mushrooms) in the last month. Mr. Haddad exhibited command auditory hallucinations, delusions of grandeur, delusions of reference, religious delusions, persecutory delusions, and somatic delusions. He also endorsed intermittent active suicidal ideation and active homicidal ideation directed toward his sister.
Prior Psychiatric History
Mr. Haddad’s psychiatric history prior to the index offence is summarized in the Hospital Report and was touched upon above in relation to aspects of his substance use history. It is helpful to note the following specific features.
Although it is observed that Mr. Haddad began to exhibit features of mental illness as early as 2008, the Hospital Report contains no details of his symptoms, treatment, or any hospital admissions or contact with outpatient services between 2009 and 2020. From 2020 to March of 2023, just a month prior to the index offence, Mr. Haddad had six distinct psychiatric admissions. Three admissions exceeded one month in duration, and one (during the last half of 2022, referred to above at para. 16) lasted over four and a half months. In addition, Mr. Haddad was subject to several Community Treatment Orders (CTOs), initiated under the Mental Health Act, during this period. Notably, earlier in 2020, prior to this series of hospital admissions, Mr. Haddad’s father passed away due to complications of COVID-19. It was reported by his sister that their father’s death significantly affected Mr. Haddad.
Despite his multiple psychiatric admissions and history of supervision under several CTOs, Mr. Haddad became non-adherent to his prescribed medications and as previously noted, continued to use cannabis.
Mr. Haddad’s last hospital admission prior to the index offence occurred on March 30, 2023. He was brought to Brampton Civic Hospital by the police pursuant to his CTO as he had missed his scheduled antipsychotic medication injection. He was being followed by the Transitional Outpatient Program of the Schizophrenia Service (TOPSS) at SJHH at the time. On admission to hospital, Mr. Haddad was described as guarded and reporting that he neither needed nor wanted antipsychotic treatment. His sister reported that his mental health had declined for the last few months, he was using cannabis and expressed religious preoccupations of being healed by God. He threatened to kill their mother, demanding that she leave her home (where he was also living at the time). He also threatened to burn their mother to death, had been talking to himself, and feared that their mother would harm him. Their mother had left the home, fearing for her own safety. Upon assessment in the Emergency Department, Mr. Haddad denied any symptoms or suicidal or homicidal ideation, intent, or plans. He was discharged from hospital the same day after receiving his injection. The index offence occurred 12 days later.
Mr. Haddad has no record of criminal convictions. However, records of his psychiatric admissions, starting in 2020, detail a history of aggressive outbursts and accusations against his mother, delusional thoughts about his family (including that he doubted that they truly were his family), and heightened distress and anxiety when around them. Two of his hospital admissions in 2021 followed police intervention after he assaulted one of his sisters. As previously noted (at para. 16 above), he endorsed active thoughts of killing one sister during an Emergency Room attendance in late June of 2022 and was ultimately admitted to the inpatient Schizophrenia Unit at SJHH for several months.
Approximately three months after the index offence, Mr. Haddad was admitted to SJHH under the Mental Health Act for assessment and treatment of his psychotic symptoms. He was considered “treatment incapable”, demonstrating poor appreciation for the severity of his mental illness and need for treatment. Even after improvement was observed following the commencement of a combination of clozapine and risperidone, Mr. Haddad persisted with delusions around his relationship with family members. He was discharged from hospital on April 3, 2024 to an apartment at First Place in Hamilton. His care was again transferred to TOPSS, and a Community Treatment Order was made, valid until August 1, 2024.
The risk assessment conducted prior to Mr. Haddad’s initial ORB hearing concluded that the local Schizophrenia Program would not be sufficient to manage his risk. He still saw his mother as a problem, was using cannabis daily until his NCR verdict, was non-adherent to his medications despite being on a CTO, and was seen as having no insight into his illness. He was accordingly admitted to the Mountain 3 unit at SJHH.
Risk Assessment
- The psychological risk assessment, prepared for Mr. Haddad’s initial ORB hearing in 2024, includes the following historical summary:
Many historical risk factors are present for Mr. Haddad. He has a longstanding history (i.e., since 2009) of psychotic symptoms and has been diagnosed with several psychotic disorders throughout the years (i.e., Schizophrenia, Schizoaffective Disorder). His psychotic symptoms appear refractory in nature. He continues to endorse delusional beliefs about persecution, undue influence, and religion – even during periods of intensive intervention. Moreover, despite frequent hospitalization, and intensive outpatient aftercare, he has exhibited a pattern of inconsistent follow-up with services, lack of follow-through with treatment plans, and medication non-adherence. This is of concern, as Mr. Haddad’s risk tends to be highly reactive to deterioration in his mental health, and he rapidly reengages in threatening (e.g., family, neighbour), violent, and antisocial behaviour (e.g., arson, property destruction, destruction of religious artifacts).
In March 2023, Mr. Haddad threatened to kill his mother should she not leave the house. His sister shared “He describes in detail two ways of killing her and advises that she has the choice of which way she would prefer. He says it will happen when God gives him the final word to do so.” Hospital records and family accounts indicate that a more pervasive pattern of violent and antisocial behaviour exists (e.g., from Jamena: “[H]e has a long history of severe psychotic symptoms which has resulted in violence and physical assault many times before”). Although violent attitudes are present, they appear tied to episodes of psychosis. For example, he shared that he slapped one of his sisters to “wake her up because I felt she was being influenced by [our] older sister or mom.”
- Mr. Haddad’s overall risk for violent reoffending in a manner similar to the index offences was assessed as moderate with the monitoring and supports in place at the time of his initial hearing. Absent the oversight of the ORB and support of the Forensic Psychiatry Program, his risk was considered to be high. This assessment was reviewed for the current year’s hearing and was determined to remain valid.
The Current Reporting Year
Mr. Haddad’s inpatient course went relatively well. He settled on his new unit (following transfer to Waterfall 3 from Mountain 3). He was described as pleasant and polite with staff and other patients, there were no issues with medication adherence, and he participated in recreational programs and times in the courtyard. He approached staff about his concerns. He denied thoughts of harm to himself or to others or perceptual disturbances and was not observed responding to internal stimuli. He eventually earned increased privileges, including community passes.
On November 26, 2024, in a conversation with his psychiatrist, Mr. Haddad displayed marked symptoms of decompensation. His thought process was disorganized, tangential, and circumstantial. He had loose associations to the extent that the conversation could not be followed. He also demonstrated increased delusions of reference and paranoia. Asked whether there had been recent stresses or changes in his routine, he volunteered having restarted smoking cigarettes in the previous week. He agreed with a plan to hold his level 3 (hospital and grounds) indirect privileges while his mental status stabilized, and to start on a low dose nicotine patch. Two days later, on November 28, he was accompanied to his apartment, bringing some kitchen and household items to the apartment. He continued to present in a more disorganized manner than his baseline, though was in good spirits, was pleased to visit his apartment, was cooperative with staff and followed direction.
One significant development during Mr. Haddad’s initial reporting year was his reconnection with his mother, Jeanette Haddad. They had a visit at the Hospital on December 23, 2024, said to have been the first time in two years that they had seen one another in person. Eventually, Mr. Haddad participated in separate family meetings with his sister, Jamena Haddad, and with his mother. Both became Approved Visitors for him.
The Hospital Report states that Mr. Haddad’s family are a strong support. Since resuming contact with his mother, he reported having daily phone calls. Notably, his sisters and mother visited with him at his apartment as he transitioned from hospital to the community and were made aware of the discharge plan.
Mr. Haddad’s discharge plan to First Place, a 24/7 staff supported housing program, is described in detail at p. 27 of the Hospital Report. Prior to his formal discharge on April 7, 2025, Mr. Haddad’s plan included 12, 24, 48, and 72-hour passes to his one-bedroom apartment, followed by a seven-day leave of absence pass. These were all successfully completed. On one occasion (March 17), however, while being visited at the apartment by his outpatient nurse, Mr. Haddad voiced paranoid and bizarre thought content. Specifically in relation to his mother, he thought that she was a witch before and he wanted to kill her then, but she is human now and he no longer feels that way. Since his discharge to the community, he has remained guarded about discussing his past paranoid beliefs about his family.
To his credit, Mr. Haddad has expressed no desire to return to substance use, and all his drug screens have been negative. Insight into his illness and need for medication, however, remain issues for him. He receives his oral medications (including clozapine, his only antipsychotic medication) from a First Place staff worker who attends his apartment. Since his discharge to the community, he has made several comments to the FOP team regarding stopping or reducing his clozapine dosage. In June 2025, Mr. Haddad reported that he will stop taking clozapine in the next 2-3 years.
Evidence at the Hearing
Dr. Naidoo testified that he has been Mr. Haddad’s attending psychiatrist since his discharge to the community in April of 2025.
Dr. Naidoo first addressed the increased liberty restriction issue. He briefly reviewed the contents of the ROL Report, which he authored. He noted that on the day of Mr. Haddad’s readmission to the Hospital, his colleague, Dr. Prat, met with Mr. Haddad. When seen by Dr. Naidoo a few days after the admission, Mr. Haddad presented as had been described by the case manager on May 22. Dr. Naidoo confirmed that Mr. Haddad’s clozapine level had been reduced due to cigarette smoking. Mr. Haddad agreed, following his readmission, to stop smoking and to have his clozapine dose increased. To Dr. Naidoo’s knowledge, Mr. Haddad has recently started smoking again.
In Dr. Naidoo’s opinion, had Mr. Haddad not been readmitted to the Hospital, his clozapine level would have dropped “precipitously”. In his view, the Hospital had no alternative but to readmit him at the time.
Dr. Naidoo confirmed, in response to a question from Mr. Haddad’s counsel, that Mr. Haddad returned to the Hospital voluntarily at the time of his readmission, and that he had demonstrated no aggression or violence. Mr. Haddad had acknowledged smoking some four to five cigarettes per day. He has been offered smoking cessation products but has thus far declined them.
Turning to the review of the Disposition, Dr. Naidoo testified that prior to Mr. Haddad’s discharge into the community, work was being done to improve his insight so that he would continue his treatment. Further improvement is needed, and Mr. Haddad’s insight is developing. The treatment team is also working on building more structure into Mr. Haddad’s weekly routine, as he currently has a great deal of unstructured time on his hands.
Asked what goals the treatment team would like to pursue in the coming year with Mr. Haddad, Dr. Naidoo listed the following areas:
- improved insight into and understanding of the need to maintain his treatment;
- cessation of his smoking (Mr. Haddad has verbalized a desire to stop but has recently resumed);
- maintaining abstinence from substances; and
- engagement with his personal goals of reducing his weight, improving his diet, pursuing employment opportunities, and strengthening his family relationships.
Dr. Naidoo confirmed, in response to a panel member’s question, that CBT-p (Cognitive Behavioural Therapy for psychosis) would be part of the plan for engaging Mr. Haddad to improve his understanding of his illness and need to continue his medication.
Dr. Naidoo also confirmed that Mr. Haddad’s sleep hygiene, noted as a concern in the Hospital Report for the current year, seems to have improved with clozapine.
Dr. Naidoo said that from a risk management standpoint, Mr. Haddad requires ongoing supports, along with regular “check-ins” with his care team. Currently, those supports include his case manager, Dr. Naidoo, and Mr. Haddad’s family, with whom he speaks regularly.
Dr. Naidoo considered Mr. Haddad’s symptoms to be currently managed and in early remission and confirmed that clozapine is his only antipsychotic medication. Dr. Naidoo said that smoking can result in Mr. Haddad’s mental state becoming unstable quickly, even while taking his clozapine. Noting Mr. Haddad’s reported desire to reduce and even discontinue taking his clozapine, counsel for the Attorney General asked about the speed with which any decompensation may occur. Dr. Naidoo replied that if Mr. Haddad were to become noncompliant, symptoms would appear within two to three days. Those symptoms would include paranoia concerning his family.
In response to a question from Mr. Haddad’s counsel about the potential for a recommendation for a Conditional Discharge at Mr. Haddad’s next review, Dr. Naidoo said that this could be a consideration but reminded the panel of Mr. Haddad’s history of non-compliance while subject to a series of Community Treatment Orders in the period prior to the index offence.
Dr. Naidoo confirmed, in response to a panel member’s question, that Mr. Haddad’s housing at First Place is long term (in other words, he is not required to transition to other housing within a specific timeframe).
No further evidence was led following Dr. Naidoo’s testimony.
Analysis and Conclusions
Significant Threat and Necessary and Appropriate Disposition
The panel accepted the parties’ joint position and found, independently, that Mr. Haddad represents a significant threat to the safety of the public. He suffers from a major mental illness, with treatment refractory symptoms, and his prior history of non-adherence to prescribed medication, even while subject to Community Treatment Orders, clearly demonstrates a need for oversight to maintain his compliance and to monitor for changes to his mental state. He also has a serious substance use disorder, particularly in relation to cannabis use, that has negatively impacted his mental health. His history includes instances of aggressive and violent behaviour, particularly directed toward family members. In addition, the index offence was quite serious and could well have resulted in catastrophic consequences. It was preceded, only weeks earlier, by a threat to kill his mother by burning her to death.
From Mr. Haddad’s earlier history and his course since being found NCR, the panel finds, in accordance with the evidence from the 2024 psychological risk assessment, that his aggressive and violent behaviour and homicidal threats are related to the active symptoms of his mental illness, which have been at times exacerbated by substance use. In his favour, his mental illness has responded well to his current prescribed oral medication and Mr. Haddad has remained abstinent from the use of cannabis since coming under the Board’s authority. His medication is necessary to his stability and safe reintegration into the community. He is capable of consenting to his psychiatric treatment but has voiced a desire to discontinue it. It is clear from Dr. Naidoo’s testimony, which the panel accepts, that if Mr. Haddad were to discontinue his medication, his active psychotic symptoms would recur quickly, in just days, and his symptoms would include paranoid thoughts in relation to his family members, with whom he has just recently reconnected after a period of estrangement.
The panel is therefore satisfied that absent the oversight provided by the Board and the support of the Hospital’s forensic program, Mr. Haddad would very likely discontinue his antipsychotic medication, and his mental state would decompensate. The return of psychotic symptoms would be accompanied by the return of threatening, assaultive, and/or otherwise destructive criminal behaviour that could very easily result in serious physical and/or psychological harm to others, including but not limited to family members.
The panel agreed with the parties’ joint recommendation and found that the necessary and appropriate Disposition is a Detention Order containing the same terms as Mr. Haddad’s previous Disposition. The panel is satisfied that when Mr. Haddad is in the community, he requires close monitoring and a ready mechanism for returning him to the Hospital quickly in the event of any changes in his mental state, and to keep him in hospital for as long as necessary to ensure that his mental state is stabilized and his medication is optimized. The mechanism of a Detention Order is needed so that Mr. Haddad’s risk can be safely managed. His readmission from May 22 to June 10 of this year affords an example of the flexibility of a Detention Order as well as its necessity in Mr. Haddad’s case. These are quite early days in Mr. Haddad’s community reintegration and in the restoration of his familial relationships. As Dr. Naidoo reminded the parties and the panel, Mr. Haddad’s experience with a succession of CTOs reinforces the premature nature of a Conditional Discharge at this juncture.
The Increased Liberty Restriction
The panel found that Mr. Haddad’s readmission to the Hospital on May 22, 2025 was warranted, as was his continued admission until his discharge on June 10. Again, all parties were in agreement on this. Mr. Haddad’s sole antipsychotic medication was, and continues to be, clozapine, and Mr. Haddad was smoking some four to five cigarettes per day. As Dr. Naidoo testified, clozapine levels are vulnerable to becoming diminished by tobacco smoke, and Mr. Haddad had experienced a change from his base line mental state. This was observed by his case manager.
As the ROL Report stated, and as briefly explained by Dr. Naidoo in his testimony, Mr. Haddad’s mental condition, as observed in the Hospital, had worsened appreciably from his baseline. He was initially guarded during interactions, and his insight had deteriorated. He expressed mistrust for members of the treatment team. He was preoccupied with his physical health and had impaired insight into his relational instability with his family. He also believed his clozapine dosage was too high and that it had limited benefit for him. His clozapine level was noted to be lower than usual, supporting the hypothesis that his cigarette smoking lowered the level. Over the next week, his mental status normalized, and he agreed to an increase in the clozapine dosage to limit future fluctuation in his levels. Monitoring for side effects was necessary, revealing none. His clozapine level was rechecked and found to be in the therapeutic range. Psychoeducation was provided, and he met with his outpatient team, ensuring that the therapeutic relationship was back to baseline.
The panel is satisfied that the treatment team moved with dispatch to stabilize Mr. Haddad’s mental state and to minimize the risk that Mr. Haddad would lose his community accommodation, all while addressing his risk to public safety. Accordingly, the panel concluded that the significantly increased restrictions on Mr. Haddad’s liberty, flowing from his hospital readmission on May 22, 2025, and his ongoing detention in the Hospital to the date of his discharge, were on the evidence entirely warranted, representing the least onerous and least restrictive measures open to the Hospital for the management of his risk.
In approaching the matters before the Board in this case, the panel considered the evidence through the lens of the factors in s. 672.54 of the Criminal Code.
DATED this 22nd day of August 2025, at the City of Toronto, in the Toronto Region.
Eric Siebenmorgen Legal Member
Office of the Registrar Ontario Review Board