Re William R. Medcof, 2026 CanLII 15128

Re: William R. Medcof

ORB File No: 3680

Hearing held on: Friday, January 23, 2026

Place of hearing: Centre for Addiction and Mental Health

Pursuant to: Section 672.81(1) of the Criminal Code

Before:

Alternate Chairperson: Mr. J. Goldenberg

Members: Dr. G. A. Chaimowitz Dr. L. Leong Hon. B. Durno Mr. S. Doherty

Parties Appearing:

Accused: William R. Medcof Counsel: Mr. K. Gray

The person in charge of hospital: Counsel: Ms. M. Warner

Attorney General of Ontario: Counsel: Ms. K. Kirec

REASONS FOR DISPOSITION

(Dated February 27, 2026)

1. After being found Not Criminally Responsible (“NCR”) on the following Criminal Code offences on November 29, 2002: aggravated assault, break and enter with intent (x2), uttering threats to cause death or bodily harm (x3), assault, criminal harassment (x3), failing to comply with probation, failing to comply with a recognizance (x2) and possessing a weapon for a purpose dangerous to the public peace, William Medcof remains subject to the jurisdiction of the Ontario Review Board (“ORB”).

2. Pursuant to an ORB Disposition dated November 6, 2024, he is subject to a Detention Order in the General Forensic Unit with conditions including living in the community in accommodation approved by the person in charge.

3. At Mr. Medcof’s annual ORB hearing held on January 23, 2026, pursuant to s. 672.81(1) of the Criminal Code, the issues for determination were whether Mr. Medcof remains a significant danger to the safety of the public and if so, what is the necessary and appropriate Disposition.

4. The Attorney General and the hospital submit Mr. Medcof remains a significant threat to the safety of the public. The necessary and appropriate order is for his detention on a General Forensic Unit with the same conditions as his last order except he should report weekly instead of every two weeks.

5. On behalf of Mr. Medcof his counsel, Mr. Gray submits the necessary and appropriate order is an Absolute Discharge as he no longer represents a threat to public safety. In the alternative, the order should be a Conditional Discharge with conditions including being permitted to live in the community in housing without the requirement that the residence be approved by CAMH.

6. The evidence on the hearing included the Hospital Report prepared by Dr. Owen O’Sullivan, the Hospital Restriction of Liberty Report, filed as Exhibits, and Dr. O’Sullivan’s and Mr. Medcof’s oral evidence.

7. For the following reasons, the Board unanimously concluded Mr. Medcof remains a significant threat to the safety of the public and the necessary and appropriate disposition is a Detention Order on the same conditions as were in the previous order except he is required to report not less than once per week, with the treatment team to determine if any telephone reports are permitted.

Background Information regarding William Medcof

8. Mr. Medcof is 58 years old. He is separated from his wife who had custody of their son when he left the marriage in July 1999. He is unemployed and supported by the Ontario Disability Support Program.

The Index Offences

1. On May 24, 2001, Mr. Medcof attacked his roommate causing a head injury that required stitches.

2. On May 25, 2001, Mr. Medcof unlawfully went into his parents’ home, struck his mother with a golf club, forced her into a vehicle and drove to Havelock. While driving, he told her that she, his father and sister were evil, and he intended to kill them. He stopped on the road and tied his mother’s hands and feet together.

3. He drove to the family cottage in Havelock, entered and threatened his father with the golf club before striking him in the neck area twice with his hand. His father was able to calm him down inside the cottage. Despite being bound, his mother called 911 with her cell phone from in the car. OPP officers attended and arrested Mr. Medcof. At the time of the offences, he was on a recognizance to remain away from his parent’s home and not to be in the front seat of a motor vehicle.

4. The Hospital Report notes Mr. Medcof minimizes the offences referring to it as a “minor index offence,” an “isolated incident,” and unrelated to mental illness. Further, “no one spent a night in hospital.”

5. Mr. Medcof told the Board during this hearing that he admitted to striking his roommate and mother and committing “most” of the other offences. He denied threatening anyone. He said he “just snapped.” At the time, he was under a great deal of stress, living in a boarding house while receiving $475 monthly with monthly rent of $450. He “lost contact with reality” and experienced a “brief psychosis.” Mr. Medcof added that no one was seriously injured.

Psychiatric Diagnoses

14. Mr. Medcof has consistently been diagnosed with Schizophrenia, with relapses and remissions over many years. He has a history of chronic cannabis and cocaine use, with ongoing use worsening his psychiatric symptoms. Further, Mr. Medcof presents with features of antisocial and narcissistic personality disorders.

15. While he can manage his property, he is incapable with regards to psychiatric treatment with the Public Guardian and Trustee as his Substitute Decision Maker.

16. Mr. Medcof denies he has schizophrenia, demonstrating limited insight into the nature of his symptoms, mental illness or his risk profile. In admitting continued cannabis use, he refers to a medical marijuana prescription he had in the past. He denies regular cocaine use, telling the Board his last use was in June 2025. He contends positive urine tests were fraudulently prepared by his treatment teams at CAMH.

Course since the NCR Finding

17. Being subject to the authority of the ORB for just over 23 years, Mr. Medcof has a lengthy history before the Board. He has been detained at CAMH and Ontario Shores at times, as well as living in the community in supervised and independent living at others. He was subject to a Conditional Discharge as recently as 2023 but has been on a Detention Order since his 2024 annual review.

18. The detailed background is set out in detail in the 71-page Hospital Report that was made an exhibit. Accordingly, a brief overview will be appropriate.

19. From the 2002 NCR finding through 2012, he was detained at Ontario Shores and CAMH. In 2012, he was discharged to supervised housing in the community. Between 2012 and 2016, he was hospitalized on multiple occasions because of substance use, breaches of his ORB conditions and non-compliance with medications. A 2019 Community Treatment Order (“CTO)” has since lapsed.

20. In 2022, he was charged with possessing a weapon for a purpose dangerous to the public peace, mischief to private property and failing to comply with a release order on an earlier theft under $5000 charge at a Rexall pharmacy. Following his release, he was admitted to hospital pursuant to the Mental Health Act, and then for a further 7 days when he became acutely hostile and intimidating during his initial visit with his new Forensic Outpatient psychiatrist, and a further 7 days when he refused his medication.

21. In July 2024, he was readmitted after missing a scheduled injection and subsequently was physically threatening and intimidating towards his psychiatrist, Dr. Meng. He argued with her about his last ORB annual review. When the doctor reminded him, the team had not recommended a Detention Order, he “suddenly got out of his chair and lunged at Dr. Meng, forcefully shoving his finger in her face while loudly shouting abuses, including calling her a “cunt.”

22. He had also verbally abused and physically intimidated his associate case manager outside the hospital by blocking her path with his bicycle, physically imposing on her personal space while continuing to shout verbal abuse and accusations. A passerby tried to intervene, but Mr. Medcof shouted at him to “fuck off” before the associate case manager went into a Shoppers Drug Mart where security were present.

23. In August 2024, he was arrested in Peterborough for suspicious activity referenced later, found to be in breach of his ORB disposition and returned to CAMH. In September 2024, he was transferred to the Extended Forensic Outpatient Services (“EFOPS”) as he required higher intensity care.

24. In November 2024, the ORB changed his conditional discharge to a Detention Order with conditions after an escalation in his challenging behaviour, which included acting aggressively towards his treating team, drug use, poor compliance, increased risk of homelessness and his concerning behaviour in the vicinity of his parent’s cottage in August 2024.

25. In December 2024, his care was transferred to Dr. Owen O’Sullivan. Mr. Medcof’s challenging behavior and hostile presentation continued. Further, he regularly tested positive for drugs.

26. In June 2025, during a review with Dr. O’Sullivan, he became overtly hostile, physically aggressive and intimidating, stood with his arms folded, refused to sit and shouted, “You are a fucking goof” and “You eat patients here.”

27. In September 2025, he was recalled to CAMH after various breaches of his ORB disposition for substance abuse as well as therapeutic and risk management challenges including hostility and medication refusals.

28. On November 9, 2025, he punched a co-patient. When staff arrived, Mr. Medcof was standing over the patient who was on the floor. They had to disengage the patients because Mr. Medcof was visibly angry. Mr. Medcof testified the co-patient insulted him, commenting on his hygiene, telling him to take a shower and calling him “Honey Boy.” Mr. Medcof told the Board he only punched the co-patient once, that his actions were justified but he “could have handled it better.”

29. The next day, Mr. Medcof’s annual ORB hearing was adjourned because his treatment team did not feel it was safe for him to attend because of an increased risk to others.

30. On November 17, 2025, he left a voice mail message for his EFOPS case manager in an angry tone stating that her and her colleagues were “steaming [their] way into [their] own private hell” and would be “reincarnated into an automobile in [their] next life.” When they were up on the mechanic’s hoist and he is wailing away on her with a 3.5 lb ball-peen hammer and an oxygen acetylene torch, “you’re going to be seeing fucking stars lady.”

31. CAMH recalled Mr. Medcof and required him to remain in hospital, applying to the ORB for a Restrictions on Liberty hearing. On November 26, the Board ordered Mr. Medcof’s continued detention with conditions.

32. While Dr. Valoo became Mr. Medcof’s primary psychiatrist on January 5, 2026, Dr. O’Sullivan testified for the hospital. He had consulted with Dr. Eid who had been Mr. Medcof’s primary psychiatrist before Dr. O’Sullivan as well as his treatment team. Mr. Medcof was frequently hostile and verbally abusive to Dr. O’Sullivan while he was his primary psychiatrist. He remains intimidating and irritable and is highly disparaging of the team. He complains of the side effects from his anti-psychotic medications.

33. An Office of the Person in Charge (“OPIC”) Conference was held to review the condition permitting Mr. Medcof to live in independent living because of over 18 months of extremely challenging period while Mr. Medcof was in the community leading to concerns for risk management. The conduct included breaches of his ORB conditions, substance abuse, refusing to attend appointments and for his medication. He was reported to have been verbally abusive to the staff at his housing, tampered with the fire alarm, and was in arrears on his rent. Mr. Medcof denied substance abuse and refused to discuss substance issues. The conference concluded with independent living being withdrawn in favour of supervised living.

34. While he continues to show some positive signs of psychosis and remains intimidating toward staff, Mr. Medcof has shown some improvement because of his controlled abstinence. His treatment team has applied for level 2 passes that would permit Mr. Medcof to be accompanied on the hospital grounds. While in the community he attended weekly Buddhist group meetings and Narcotics Anonymous meetings. As of January 5, 2026, Mr. Medcof is no longer on a secure unit at CAMH.

35. While he is reported to have previously said if he received an Absolute Discharge, he would discontinue his medication, when asked what he would do at the hearing, Mr. Medcof said he did not know. He did not read that far into the future, reiterating that he was stable for seven years while taking one milligram of Risperidone.

36. As regards his future, Mr. Medcof wants to go to the United States to visit a woman he met on the internet to see if they have a future.

The Psychiatric Opinions

1. The authors of the Hospital Report concluded Mr. Medcof’s overall future risk of violence is high (including psychological harm), his risk of serious physical harm is high, and risk of imminent violence is medium. Without a detention order and under a conditional or absolute discharge, the risk of imminent violence would become high.

2. In reaching their conclusions, the doctors relied upon the history noted above as well as actuarial methods of risk assessment outlined at pages 62-71 of the report – the HCR-20 V3 Structured Guide for the Assessment of Violence Risk and the Structured Assessment of Protective Factors Risk Assessment Tool. His “present and highly relevant risk factors” included violence as an adult, other antisocial behaviour such as being abusive to staff, deceptiveness, thefts, the 2022 offences noted above, relationship problems including with his parents, substance abuse, having a major mental disorder, personality disorder, traumatic experiences (being sexually abused), violent attitudes and his poor treatment or supervision response including his refusal to abide by ORB conditions for years.

3. On the Structured Assessment of Protective Factors (“SAPROF”) risk assessment tool, Mr. Medcof’s overall level of protection was considered in the low range.

4. The doctors also relied upon Mr. Medcof’s use of cannabis and cocaine over the review period with associated mental instability. He has used alcohol and methamphetamine in the past but contends his treatment teams have falsified his positive test results.

5. The doctors concluded that any re-offending would likely occur in the context of escalating substance use and non-compliance with psychiatric treatment. This would likely lead to an increase in psychotic symptoms and his falling away from treatment services. He would be prone to behave in an agitated and impulsive manner because of his paranoia and delusions. Given his lack of insight and resistance to psychiatric services, it is unlikely he would seek assistance to prevent further decompensation of his mental disorder. He participates minimally in prosocial and structured programming or activities. Being socially isolated with limited, if any, community supports capable of recognizing his deterioration and the need for him to seek assistance.

6. Historically, his poor compliance has been associated with increased affective dysregulation and behavioural dyscontrol, likely to result in hospitalization and increased risk to himself and others, including re-offending as evidenced in late 2021 and early 2022 when a period of treatment non-adherence resulted in new criminal charges based on aggressive conduct for the first time in 20 years.

7. His medication is central to sustaining his recovery and mitigating risk. While Mr. Medcof has a longstanding history of non-compliance with medication, with sustained compliance he is likely to continue to benefit and improve relapse prevention having shown improvement in his mental condition, potentially meaningfully mitigating the public safety risk. He has been seen responding to absent stimuli, suggestive of hallucinations, although this has been observed less frequently.

8. As regards future risk management, Mr. Medcof continues to be administered long-acting injectable antipsychotic medication. While not achieving full remission of his chronic delusional beliefs, it attenuates the degree of paranoid and persecutory ideation as well as a relative reduction in levels of affective dysregulation and associated episodes of behavioural dyscontrol. His hostility and antagonism towards his clinical team remains as he maintains an oppositional stance toward his treating team making it highly challenging to form a meaningful therapeutic relationship.

9. In response to a Board member’s question, Dr. O’Sullivan said it was the unanimous view of the clinical team and the hospital that Mr. Medcof remains a significant threat to public safety and the appropriate disposition is a Detention Order on a General Forensic Unit with the current terms except that he should report weekly instead of every two weeks.

10. A Board member asked Dr. O’Sullivan:

“… Given his current mental status and his behaviours on the unit, even if he were to take medications in the community, would that be a manageable risk? In other words, there were also behaviours described on the unit as threatening and, et cetera. If you placed him in the community and kept him on medication would that be an assumable risk in the community?”

4. Dr. O’Sullivan said:

“Since September, there’s just been one serious incident of physical violence. At times, he kept a low profile. I do envisage that there’s a reasonable prospect of him being successful if he can get, if we discharged and we identify, the team identifies suitable support placements, I think, I think it’s possible.”

Criminal Record

1. Mr. Medcof has two dated entries before the index offences, attempted fraud under $5,000 and failing to comply with a recognizance in 2000. Given the dates, they are not relevant to the Board’s determination. He has one entry after the index offences, escaping lawful custody in 2008, receiving a suspended sentence and 12 months probation on his guilty plea.

Other Incidents

1. On December 28, 2021, he was arrested and charged with theft under $5000 when he left a Canadian Tire store without paying for a toaster and a hammer. In December 2023, Mr. Medcof told his psychiatrist, Dr. Meng that the incident was “irrelevant” because the charges were withdrawn. He explained he stole the toaster because he wanted a toaster. He made no reference to the hammer.

2. On February 1, 2022, he was arrested and charged with possessing a weapon for a purpose dangerous to the public, mischief interfering with private property and failing to comply with an ORB condition. He was in a Rexall Pharmacy and became engaged in a verbal altercation with a clerk while seeking a refund. When told he could not get the refund, he became aggressive, told the clerk they were going to give him the money, or he would smash all the windows. As the argument continued, Mr. Medcof produced a knife he was carrying and cut open a meat stick.

3. In December 2023, Mr. Medcof told Dr. Meng the Rexall incident was not concerning because the store was empty and the staff were hiding in a “shelter area” when he brandished the knife. Further, his behaviour was justified because the store stole $200 from him.

4. On August 6, 2024, staff at a Peterborough hotel contacted the OPP regarding suspicious activity as Mr. Medcof was in the parking lot looking into cars. When the officers arrived, they determined he had been in Peterborough for two days in breach of his ORB condition to notify the hospital if he was absent from his residence for more than 24 hours.

5. Mr. Medcof’s father and sister had called the police with concerns for their safety after he called them on August 4, 2024, and said he was going to make an uninvited visit to the family cottage. When arrested, he was carrying a bag that contained a recently purchased axe.

6. Mr. Medcof was arrested and returned to CAMH by the police. There is no indication that charges were laid and if they were, their disposition.

7. While Mr. Medcof did not address this incident in his evidence, nor his counsel’s submissions, he spoke to his treatment team when he was returned to CAMH. He told them he took a cab to Peterborough to get out of the city, do some fishing and look for accommodations. He acknowledged he had not done any of those things and had not brought any fishing equipment. He said the trip for leisure, without any intention of visiting his family. Had his father been receptive to a visit, Mr. Medcof would have given his father a hug. Mr. Medcof denied knowing his disposition prohibited him from leaving his residence for more than 24 hours without notice. He denied looking into cars in the hotel. He was only there because he had nothing else to do and was waiting for someone although he would not elaborate further. Further, he was dismissive of his family’s concerns about his unsolicited communication.¹

8. Turning next to the issues the Board must determine.

Does Mr. Medcof continue to represent a significant threat to the safety of the public?

57. The first issue for determination is whether Mr. Medcof continues to represent a significant risk to the safety of the public. If he does not, the ORB has no further jurisdiction, and he must be discharged absolutely. If it is determined that he is a significant threat, then the Board must craft a Disposition which considers the provisions of s. 672.54 of the Criminal Code.

58. As noted above, the Attorney General and hospital submit Mr. Medcof remains a significant threat to the safety of the public. Mr. Medcof submits he does not, and an Absolute Discharge should issue.

The Law

1. A significant threat to the safety of the public means a risk of serious physical or psychological harm to members of the public – including any victim of or witness to the offence, or any person under the age of 18 years – resulting from conduct that is criminal in nature but not necessarily violent: Criminal Code, s. 672.5401.

2. That threshold to invoke the Board’s continued authority is a relatively high one, conjuring “a threat to public safety of sufficient importance to justify depriving a person of their liberty: Winko v. British Columbia (Forensic Psychiatric Institute), 1999 CanLII 694 (SCC), [1999] 2 SCR 625, at para. 68. The threat must be of a serious criminal offence. It must be more than speculative, a mere possibility of future harm is insufficient: R. v. Ferguson, 2010 ONCA 810, at para. 8.

3. The Board is required to impose the least onerous and least restrictive disposition compatible with public safety: Criminal Code, s. 672.54 and Re: Ramos, 2025 ONCA 820, at para. 17.

Analysis

62. For the following reasons, the Board unanimously concluded Mr. Medcof remains a significant threat to public safety.

63. First, the Board relies on the circumstances of the index offences. While the index offences are quite dated, they are very serious. Further, it is most concerning that he breached an ORB condition by travelling to Peterborough which is close to Havelock where the family cottage is located and had bought an axe. While the Hospital Report noted that shortly after that incident, he was able to moderate his behaviour during assessment and “provided a plausible account of his recent actions,” it was prefaced that the team had serious concerns about his behaviour and pattern of repeated disregard for supervision.

64. Having carefully considered all the evidence, including relating to the August 2024 incident, if the Hospital Report inferred Mr. Medcof’s explanation was reasonable or probable as opposed to persuasive but deceptive, the Board rejects that conclusion. Considering he had no fishing equipment for a fishing trip, an implausible explanation for being in the parking lot, no proffered explanation for having the axe, and not elaborating on who he was waiting for Mr. Medcof’s account is neither reasonable nor probable. Further, as noted in the ORB judgment on the hospital’s Restriction of Liberty application in November 2024, Dr. Meng said the team had concerns about his version of events because it made no sense in the face of the facts.

65. Second, the recommendations provided by experts who examined the NCR accused are the most important in the suggested list of areas to be considered by the Supreme Court of Canada in Winko, at para. 61. However, the Board must exercise its own independent judgment when reviewing professional opinions (Re: Ramos, at para. 18, #5).

66. The Board has carefully considered the record upon which the opinions were based and without reservation accepts the doctors’ opinions on risk to public safety as well as the bases upon which the opinions were based. Mr. Medcof has shown an escalating pattern of conduct over the past two years, including non-compliance with medication and reporting and one incident of assaultive behaviour. He continues to be antagonistic and confrontational with his treatment team even though he has not struck any member. His lack of insight into his mental disorder and the risk of violence contributes to the concerns. In particular, the Board accepts that his medication is central to sustaining his recovery and mitigating risk.

What is the Appropriate Disposition?

67. As noted above, the hospital and Attorney General submit the necessary and appropriate order is a Detention Order.

68. While at the outset of the hearing, Mr. Gray submitted there should be a conditional discharge with approved community living, the Alternate Chair noted that condition could only be imposed with a Detention Order, referencing Brockville Psychiatric Hospital v. Mc Gillis, (1996), 1996 CanLII 1828 (ON CA), 2 C.R.(5th) 242 (ONCA).

69. Mr. Gray then submitted that on a Conditional Discharge, Mr. Medcof should be permitted to live in Toronto but without any travel restrictions. While it was beyond the authority of the ORB, he would also enter a CTO.

70. In final submissions, Mr. Gray submitted the following agreeable terms were all available with a conditional discharge in addition to those noted above: reporting weekly with a provision for telephone reporting at the discretion of the treatment team, not to use illegal substances, possess a weapon nor contact with named persons.

71. In seeking a Conditional Discharge, Mr. Gray submitted that Dr. O’Sullivan’s evidence (see below) that there was a reasonable prospect of success that he would succeed were Mr. Medcof living in the community results in a conditional discharge being the necessary and appropriate order.

The Law

72. Where even some risk exists, the Criminal Code at s. 672.54 directs the least restrictive and least onerous disposition compatible with public safety must be imposed. Any restrictions must be based on evidence and responsive to the person’s liberty interest, mental condition, reintegration needs and broader circumstances: Ramos, at para. 17. In that context, the terms must be the least onerous and least restrictive.

73. In making their determination, the Board’s responsibilities must be carried out with full awareness of the need to protect the public, particularly where the case involves serious or violent conduct: Ramos, at para. 18.

Analysis

74. For the following reasons, the Board has unanimously determined that the appropriate and necessary disposition is a Detention Order.

75. First, with regards to Dr. O’Sullivan’s “reasonable prospect of success” answer, the Board does not regard his answer reflects a reasonable prospect of success were Mr. Medcof to live other than in approved housing. The doctor noted “if the team identifies suitable support placements.” The answer supports a Detention Order.

76. If the Board is wrong in that assessment of the answer, the Court of Appeal has directed that the opinions of psychiatrists and treatment teams must be assessed carefully. The conclusion must be rooted on concrete facts, not replacing the Board’s responsibility to apply the legal standard. Ramos, at para. 25. Having assessed all the evidence on this issue, including Dr. O’Sullivan’s testimony that both the clinical team and hospital were of the unanimous view that a Detention Order was the appropriate order and Mr. Medcof’s troubling history with treatment and compliance, the Board rejects the submission of there being a reasonable prospect of success if Mr. Medcof was living unsupervised in non-approved housing.

77. Second, an important basis for the doctors’ opinion was Mr. Medcof’s history of non-compliance with his medications and reporting. In those circumstances, the need for any living accommodation to be approved by the hospital is essential for public safety. That objective mandates that trained personnel be on site to monitor any deterioration in his mental state. With Mr. Medcof not accepting he has a mental illness other than PTSD, the prospects of him complying with conditions and medications without trained staff are poor. The risk that he would likely decompensate rather quickly and more rapidly if he were to use substances was found by the doctors to be realistic. The Board accepts that conclusion.

78. The Board also takes into consideration, Mr. Medcof’s history and attitude towards his treatment teams. While he does not like Dr. O’Sullivan, the Hospital Record reflects a series of primary psychiatrists and treatment teams that have received a similar lack of cooperation, at times hostility and antagonism.

79. This combination of factors creates the absolute need for approved accommodation with supervision to protect the public.

80. Turning next to the conditions, the hospital and Attorney General submit the current conditions should remain except there should be weekly reporting. While submitting the conditions should apply to a Conditional Discharge, Mr. Medcof submits the terms proposed above should apply. He does not oppose a weekly reporting condition with a provision for permission to report by phone.

81. The conditions on the current Detention Order include that the person in charge may permit Mr. Medcof to live in the community of the Greater Toronto Area in accommodation approved by the person in charge, prohibit him from using alcohol or non-medically prescribed drugs, refrain from communication with James Medcof or Cathi Porcielo, not to be within 1 km. of a Toronto and Havelock address and direct that while living in the community he must report not less than once every two weeks.

82. Based on the evidentiary record noted earlier, the Board directs that the current conditions remain except weekly reporting is now required.

83. Given Mr. Medcof’s history of non-compliance with conditions, including reporting and non-compliance with medications, as well as his escalating pattern of concerning behaviour, the Board finds weekly reporting with a provision for the treatment team to approve telephone reporting is necessary and appropriate.

84. Finally, while the geographical restrictions regarding a Toronto residence and Havelock cottage were not addressed on behalf of Mr. Medcof, given the 2024 incident, those terms are necessary and appropriate.

Conclusion

85. After taking into consideration public safety, Mr. Medcof’s mental condition and other needs, as well as his re-integration into society, the Board unanimously finds Mr. Medcof remains a significant risk to public safety and that the necessary and appropriate order is for Detention in a General Forensic Unit and the current conditions, except reporting shall be weekly and not every two weeks.

DATED this 27th day of February, 2026, at the City of Toronto, in the Toronto Region.

Hon. B. Durno

Legal Member

__________________

Office of the Registrar

Ontario Review Board

Footnotes

1. 1While the December 2021, February 2022 and August 2024 incident did not result in convictions or findings of guilt, they are properly considered by the Board pursuant to the Court of Appeal judgement in Ontario (Review Board) v. Ranieri, 2015 ONCA 444 at paras. 13-18 applying the considerations noted by the Court.