Ontario Review Board
Re: Curtis Hall
ORB File No: 8268
Hearing held on: Thursday, June 26, 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: Curtis Hall Counsel: Mr. H. Evans
The person in charge of hospital: Counsel: Mr. K. Dow
Attorney General of Ontario: Counsel: Mr. D. Brandes
REASONS FOR DISPOSITION
(Dated August 25, 2025)
Introduction
On March 31, 2023, Mr. Hall was found not criminally responsible on account of mental disorder on charges of assault, aggravated assault, and uttering a threat contrary to the Criminal Code of Canada (“Criminal Code”). Mr. Hall is currently subject to a Disposition of the Ontario Review Board dated August 16, 2024, which discharges him on certain terms and conditions.
On Thursday, June 26, 2025, the Ontario Review Board convened a hearing at the Centre for Addiction and Mental Health (“CAMH” or the “hospital”) to conduct Mr. Hall’s annual review hearing pursuant to section 672.81(1) of the Criminal Code. Mr. Hall attended his hearing and was represented by his counsel, Mr. H. Evans. Also in attendance were Mr. Hall’s parents. A Hospital Report, dated May 26, 2025, was entered as Exhibit No. 1.
The issue at this hearing is whether Mr. Hall continues to represent 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.
Positions of the Parties
At the outset of the hearing, the parties were canvassed for their initial recommendations to the Board. On behalf of the hospital, Mr. Dow submitted that the existing Conditional Discharge Disposition remains the necessary and appropriate Disposition. He also submitted that it is both necessary and appropriate to make amendments to remove the current residence specification, remove the requirement to leave his mother’s unit directly after visiting, remove the limitation on duration of travel, remove the prohibition on substance consumption, and change the reporting frequency.
For the purposes of the hearing, counsel for Mr. Hall conceded the issue of significant threat. Counsel for the Attorney General and for Mr. Hall supported the hospital’s recommendation, and therefore the panel was presented with a joint submission which was maintained at the conclusion of the hearing.
For the reasons set out below and based on the expert evidence and opinions before us, the Board agreed with the joint submission that Mr. Hall continues to present a significant threat to the safety of the public and that his risk can be properly managed with a continuation of the existing Conditional Discharge with the amendments recommended by the hospital and set out in our formal Disposition. The Board concluded that the above is the necessary, and appropriate, Disposition in the circumstances.
Index Offence
- The circumstances giving rise to the index offence are taken from last year’s Reasons for Disposition as follows:
“Mr. Hall and Mr. C. resided in an apartment building on Sheppard Avenue East, Toronto, and were only slightly known to each other. At about 2 a.m. on October 10, 2021, Mr. C. was outside by the back of the building, having a cigarette. Mr. Hall approached him and asked for a cigarette, which Mr. C. refused.
The two men got into a physical altercation. Mr. Hall smashed the back of Mr. C’s head with a coffee mug. At one point, Mr. C. was on the ground and Mr. Hall was continuing to stomp on him. Mr. C. was bleeding profusely from his head, and he lost consciousness momentarily.
After the altercation, both men left the area and came inside the building. Mr. Hall realized he had lost his key fob with his apartment key on it, and went looking for it throughout the building. A short time later, he and Mr. C. met again in the lobby of the building. Mr. Hall demanded his keys back. Mr. C. replied he did not have the keys. Mr. Hall then punched Mr. C. twice. Mr. Hall was armed with an unknown object at that time, and told Mr. C. he would kill him.
Police officers arrived, arrested Mr. Hall, and took him to the police station where he was reportedly held for a bail hearing and released the same day. Mr. C’s injuries included foot impressions or stomp marks on his abdomen and chest area, a black eye and cuts to an eyebrow, and a cut to the back of his head which required some stitches."
Diagnoses
- Schizoaffective Disorder, bipolar type
Cannabis Use Disorder in sustained remission within a controlled setting
Background
Mr. Hall’s background and course following the index offence are detailed in the Hospital Report in evidence and need not be repeated in detail, but the following points are noted.
Mr. Hall is 24 years of age and is single with no dependents. He is the fifth of seven siblings. After completing high school in Scarborough, Mr. Hall went to University in Tennessee, then left the program after two years. His employment history includes part-time work during high school and brief employment after returning from Tennessee.
Mr. Hall began smoking cannabis at age fourteen, and by the year preceding the index offence, he was smoking 5-10 grams per day. He believed that the effects were primarily positive, although it caused conflict with his parents. Prior to the index offence, Mr. Hall was not involved with police and has no criminal record.
His parents became concerned about his mental health during the summer of 2021. Mr. Hall was first hospitalized in November 2021 for three months and treated with Lithium. Mr. Hall reported that he was diagnosed with “psychosis, mania, and bipolar.” He was hospitalized again in the summer of 2022 on a Form 1 after discontinuing his medication. Upon admission, he appeared disheveled, was aggressive and confrontational, and was responding to internal stimuli.
From July 2022 to August 2023, Mr. Hall had a voluntary one-month hospitalization. Medication non-adherence and cannabis use disorder were noted to contribute to his episodic deteriorations. A Community Treatment Order was put in place. Mr. Hall was deemed capable to consent to treatment and the order was not renewed upon its expiry in December 2023.
Following Mr. Hall’s initial ORB Disposition, he received care through the Forensic Outpatient Service (FOPS) and resided independently in the community. In December 2024, his long-acting antipsychotic medication injection was switched from every four weeks to an equivalent dose administered every 12 weeks.
Mr. Hall began a full-time college Electrical Engineering Technician program in in September 2023 but transferred to the HVAC program. After his first year in the program, he worked as a casual labourer on construction sites and did not return to school. Most recently, he was accepted to the George Brown College Construction Craft Worker Foundations Program which he began on May 5, 2025.
During the reporting year, Mr. Hall travelled to Jamaica with his parents. His mother oversaw Mr. Hall’s oral mood stabilizing medication. Also, during the reporting year, Mr. Hall became engaged. He intends to get married between December 2025 and January 2026 in Jamaica.
Evidence at the Hearing
- Dr. Jaiswal has been Mr. Hall’s attending outpatient psychiatrist since August 2023. He is the author of the Hospital Report in evidence and adopted its contents. He testified that:
Mr. Hall will complete his college program at the end of August, then move into the practical component of the program
Mr. Hall is on the waitlist for a community psychiatrist and has been referred to the Scarborough Health Network for psychiatric care
Mr. Hall continues to reside in the same apartment, which is subsidized by CMHA. He has no plans to leave his apartment, and it is unlikely that he would choose to move into insufficient housing
Mr. Hall attends his mother's apartment to use her internet to do his college program online. Dr. Jaiswal is unsure if the victim of the index offence still resides in the same building as Mr. Hall's mother, but there have been no concerns with attempts to contact the victim
Mr. Hall uses alcohol responsibly, there is no issue with alcohol use, and no decompensation has been noticed
urine drug screens have not shown evidence of substance use, Mr. Hall wants to abstain from use of substances, and removing the condition in his Disposition requiring him to abstain from substances will allow him to demonstrate that he has the ability to abstain from substance due to intrinsic motivation. The hospital will continue to test for substances
last year, Mr. Hall went to Jamaica and there was no issue with this travel
the hospital is recommending removing the limitation on duration of Mr. Hall’s travel, as he has indicated that he wishes to go to Jamaica to get married. The hospital will ensure that there is a safety plan and monitoring of medication
the hospital recommends a reduction in the frequency of reporting because Mr. Hall has demonstrated stability in his mental state throughout the reporting year. Dr. Jaiswal believes it is unlikely that there will be decompensation or a return of active symptoms
Mr. Hall would come to the hospital on request if he were to experience symptoms. Reducing the frequency of reporting will allow the treatment team to assess this
in order to be ready for an Absolute Discharge, Mr. Hall will need to demonstrate intrinsic motivation to abstain from use of substances, stability in his mental status over the coming reporting year with decreased reporting, and a successful transition to a community-based treatment team. Ideally, Mr. Hall would have stable employment
Mr. Hall's family is a strong support for him and historically has brought him to hospital when he was unwell. The hospital communicates regularly with Mr. Hall's mother.
Counsel for the Attorney General and counsel for Mr. Hall had no questions for Dr. Jaiswal.
In response to questions from the panel, Dr. Jaiswal testified that:
Mr. Hall's insight into his illness, need for medication, and substance use is good and robust. Mr. Hall does not want to be unwell
he recognizes symptoms of his mental illness, and recognizes that use of cannabis can lead to decompensation in his mental state
Mr. Hall has continued to take medication despite experiencing side effects. Because his mental state is stable, he does not want to change the medications
Mr. Hall recognizes that he was unwell at the time of the index offence and does not want to go back to that state. He feels genuine remorse about the index offence
Mr. Hall has never had a diagnosis of alcohol use disorder
the consent to treatment clause is not required at this time, and again, its removal will provide Mr. Hall with an opportunity to show intrinsic motivation to continue treatment
Mr. Hall will continue to receive support from CMHA housing and a caseworker
Mr. Hall has extensive family who provide him with good support
- No further evidence was called.
Analysis and Conclusion
Having heard and considered the entirety of the evidence, as well as the submissions from the parties, the Board finds that Mr. Hall remains a significant threat to the safety of the public.
In Winko, the Supreme Court outlined that, in coming to the conclusion on the issue of significant risk, the 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. Jaiswal, in addition to the documentary evidence before us.
The Board recognizes that Mr. Hall has had a very successful reporting year and agrees with the hospital that the lessening of conditions in his Disposition for the coming year will assist the treatment team in evaluating Mr. Hall’s ability to abstain from cannabis use and remain adherent to his medication. The condition requiring Urine Drug Screens remains in place to ensure that if Mr. Hall relapses to cannabis use and experiences decompensation in his mental state, the hospital will be aware of the cause of any decompensation.
Mr. Hall is well-supported in his current housing, and the treatment team is confident that he does not plan to leave, which is important as insufficient housing is a risk factor for Mr. Hall. Stable housing will be important as Mr. Hall transitions to community-based care over the year.
Mr. Hall uses his mother’s internet for his online courses and has not interacted with the victim of the index offences. It is unknown if the victim still resides in the building, and in the treatment team’s opinion, the condition requiring Mr. Hall to leave the building immediately after visiting his mother is unnecessary.
Mr. Hall travelled successfully to Jamaica during the reporting year and has plan to travel to Jamaica for over 25 days in order to get married. The treatment team is confident that with an approved itinerary and safety plan, it is no longer necessary to limit the duration of travel.
In consideration of all the evidence, submissions of the parties, and the criteria set forth in s. 672.54, the paramount consideration being the safety of the public, in addition to the mental condition of Mr. Hall, his reintegration into society and his other needs, the necessary, and appropriate, Disposition is a continuation of the existing Conditional Discharge with the amendments as noted in our formal Disposition.
DATED this 25th day of August, 2025, at the City of Toronto, in the Region of Toronto.
Ms. M. den Haan Legal Member
__________________ Office of the Registrar Ontario Review Board