Ontario Review Board
Re: Paul Arthur Hulbert
ORB File No: 7961
Hearing held on: Wednesday, November 26, 2025
Place of Hearing: Brockville Mental Health Centre
Pursuant to: Section 672.81(1) of the Criminal Code
Before:
Alternate Chairperson: Mr. P. Capelle
Members: Dr. P. Darby Dr. A. Gibas Ms. M. Chamberlain Ms. R. Chopra
Parties Appearing:
Accused: Paul Arthur Hulbert Counsel: Ms. K. Dossetor
The person in charge of hospital: Representative Dr. J. Gray
Attorney General of Ontario: Counsel: Mr. K. Schultz
REASONS FOR DISPOSITION
(Dated February 24, 2026)
Introduction
On October 27, 2021, Paul Hulbert was found not criminally responsible on account of mental disorder on a charge of first-degree murder, contrary to the Criminal Code of Canada. He is currently subject to a disposition dated December 18th, 2024, detaining him on the Secure Forensic Unit of the Brockville Mental Health Centre – Member of the Royal Ottawa Health Care Group (“the Hospital”). The disposition allows for privileges up to and including the ability to live in the community, within 250 km of Brockville, in 24 hour a day supervised accommodation approved by the person in charge.
On November 26th, 2025, the Board convened at the Brockville Mental Health Centre, to conduct Mr. Hulbert’s annual review hearing. Mr. Hulbert was present and represented by counsel, Ms. Kate Dossetor. The purpose of the hearing was to determine if Mr. Hulbert continues to represent a significant threat to the safety of the public, and if so, the necessary and appropriate disposition having regard to the criteria set out in s. 672.54 of the Criminal Code. The evidence at the hearing was comprised of the Hospital Report dated November 3rd, 2025, Exhibit 1, and the CPIC (Criminal Record), Exhibit 2.
Initial Position of the Parties
- At the outset of the hearing, the parties were canvassed as to their initial positions. Dr. Gray indicated that the Hospital’s position was that Mr. Hulbert continues to represent a significant threat to the safety of the public and that the current detention order should be continued without change. Mr. Schultz, on behalf of the Attorney General, and Ms. Dossetor, on behalf of Mr. Hulbert, joined in the Hospital position. All parties maintained their positions at the conclusion of the hearing.
Index Offence
- The circumstances giving rise to the index offence is set out in the Hospital Report and summarized as follows:
“On Monday April 13th, 2020, at approximately 10:24 p.m., John Hulbert was found dead inside his apartment at 929-1025 Grenon Avenue by family members. Members of the Ottawa Police Service responded and determined that John Hulbert had been murdered.
“On Tuesday April 14th, 2020, the Ottawa Police Service Homicide Unit took carriage of the investigation and in the early stages, identified John Hulbert’s son, Paul Hulbert, as a person of interest.
Paul Hulbert had been diagnosed with schizophrenia and lived in a supervised living facility. He was followed by Dr. Bali and the ACTT (Assertive Community Treatment Team), a program designed to facilitate community living for those who have serious illness and poor treatment compliance. Paul Hulbert was receiving injectable anti-psychotic medications every two weeks, and daily oral medications administered by his residence. His father, John Hulbert, had been designated as his substitute decision maker, as a result of Paul Hulbert’s lack of insight into his mental illness and history of non-compliance with his prescribed medication.
On April 14th, 2020, homicide investigators attended Paul Hulbert’s place of residence at 1735 Montreal Road and reviewed surveillance camera footage. On April 10th, 2020, Paul Hulbert was observed leaving his apartment at 8:15 a.m. and he didn’t return until 5:04 p.m.
After reviewing the surveillance footage, homicide investigators notified Paul Hulbert that his father was found deceased and his death was being investigated as a homicide. Paul Hulbert advised he hadn’t seen his father or attended his father’s residence in months.
Homicide investigators reviewed surveillance camera footage from 1025 Grenon Avenue. Paul Hulbert was captured on surveillance video arriving there on April 10th at approximately 11:57 a.m. Paul Hulbert appeared to take the elevator to the ninth floor. He was wearing dark clothing, a black toque, and carrying a black, backpack style bag.
The surveillance footage from 1025 Grenon Avenue also captured Paul Hulbert leaving the building, through the main lobby doors, on April 10th, 2020, at approximately 12:46p.m. He was wearing the same clothing, this time with the hood of his jacket covering his head. He was carrying the same black backpack style bag. A black toque was found under the body of John Hulbert. The investigation revealed that Paul Hulbert used his Bank of Montreal debit card to purchase a large kitchen knife on April 8th, 2020. A large kitchen knife matching the description of the purchased knife was recovered from the dumpster at 1025 Grenon Avenue.
On April 15th, 2020, Paul Hulbert was arrested for murder. He was transported to 474 Elgin Street and had an opportunity to speak with legal counsel. Paul Hulbert was interviewed by Sergeant Brennan of the Ottawa Police Service and admitted that he killed his father by stabbing him. He provided details about the murder and discussed the reasons why he did it.”
Background Information
Mr. Hulbert’s personal and psychiatric background is set out in detail in the Hospital Report. It has been entered as an Exhibit and can be referred to for this purpose. The following details are highlighted.
Mr. Hulbert is presently 63 years of age. He was born in England, and he moved with his family, his parents and two brothers, to Deep River, Ontario, when he was five years of age. When he was 16 years of age he was hospitalized for some time due to a suicide attempt. This was his first of many such attempts.
Mr. Hulbert has a lengthy psychiatric history with admissions to a number of hospitals. These usually resulted from his aggressive behaviours wherein he was involuntarily admitted. For a long period of time, Mr. Hulbert was compliant with treatment for his mental illness and, as a result, was stable. During this period, he was married for ten years and employed as a truck driver until his early fifties.
Mr. Hulbert reported auditory hallucinations and expressed delusional ideas about his father over many years. He was subject to a Community Treatment Order with his father as Substitute Decision-Maker and was followed by the Assertive Community Treatment Team, ACTT. Unfortunately, even with close follow-up he continued to experience psychosis. He was preoccupied with delusions about climate change, global warming, and veganism. He experienced heightened auditory hallucinations as well as greater feelings of hostility, in particular towards his father. His psychosis worsened in the context of non-compliance with medication, and he was more aggressive.
Criminal History
Mr. Hulbert has a criminal record with two entries: 1999 conviction for sexual assault for which he received a 60-day intermittent sentence and probation for one year, and a 2021 conviction for assault in Ottawa for which he received one day.
Mr. Hulbert was also involved in a number of incidents of violence. In 2014, he damaged 31 cars by bending windshield wipers as a protest against global warming, but the criminal charges were withdrawn against him. In 2017, he attempted to stab his father in the abdomen with a plastic butter knife while he was hospitalized. In 2019, he attacked a roommate in a group home, breaking both of his hips, and also assaulted a woman by pushing her at the bus stop.
Psychiatric History
After being found NCR, Mr. Hulbert was admitted to the Royal Ottawa Mental Health Centre and subsequently transferred to Brockville Mental Health Centre on February 22, 2022. He was, at that time, receiving two injectable antipsychotic medications and an oral mood stabilizing medication but continued to display several psychotic symptoms including auditory hallucinations and responding to internal stimuli. He remained on the most secure unit at that time due to his clinical instability and unpredictable behaviour.
In 2022, Mr. Hulbert, under the care of Dr. Gray, had his medication changed with the consent of his brother, Michael, who is his Substitute Decision-Maker. He commenced Clozapine therapy and his symptoms greatly improved, although he continued to report auditory hallucinations. With the improvement, he was able to be moved to a less restrictive unit in the Hospital and began to be granted greater privileges.
In the following year, Mr. Hulbert experienced difficulties. He began cheeking his oral medications and eloped while on indirect Hospital ground privileges in February 2023. He was located in a hotel lobby in Brockville by police and returned to the Hospital. His presentation improved in the summer of 2023, but he again relapsed later in the fall when he became non-compliant with medication.
Current Diagnoses
Schizoaffective Disorder
Neurocognitive Disorder, mild
Evidence
The hospital’s evidence was presented through its Report as well as through the oral testimony of Dr. Jonathan Gray. This evidence is summarized below.
Dr. Gray informed the Board that Mr. Hulbert had a good year starting in March 2025. The current combination of medications appears to be serving Mr. Hulbert well. There have been no issues with elopement or his willingness to take his medication and there has been no aggression since March. The Hospital has managed the elopement issue by keeping staff with Mr. Hulbert.
Dr. Gray stated that if Mr. Hulbert continued in his current trajectory, the Hospital would look at discharging him into the community. He noted that Mr. Hulbert would require a placement with 24-hour supervision which would be able to manage his risk of elopement. Dr. Gray said that the Hospital was just starting to look for community placements and noted that this could take awhile. The Hospital will involve Mr. Hulbert’s Substitute Decision Maker (“SDM”) in choosing a placement. As previously noted, Mr. Hulbert’s SDM is now his brother, who is very supportive and involved in his treatment.
Dr. Gray told the Board that Mr. Hulbert participates in groups and activities at the Hospital and is engaging well with staff. Mr. Hulbert appears happy with his current privileges and enjoys leaving he Hospital with staff supervision.
The doctor opined that absent Board oversight, Mr. Hulbert would likely not take his medication and would become unwell. Dr. Gray noted Mr. Hulbert’s history of aggression while in the Hospital, although less egregious than the index offence, which necessitated a cautious approach.
Mr. Shultz asked the doctor about Mr. Hulbert’s request to come off his Clozapine as outlined in the Hospital Report. Dr. Gray informed the Board that Mr. Hulbert felt that he experienced side effects from the medication, but these had not been observed by the Hospital staff. He is very sensitive to the effects of his medication, so the treatment team has worked to have the maximum dosage possible while managing Mr. Hulbert’s side effects. Dr. Gray stated that Mr. Hulbert had been more at peace with his medication recently.
Dr. Gray was asked if Mr. Hulbert could develop more insight into his mental illness. The doctor noted that while Mr. Hulbert has always struggled with mental illness and has had little insight, there had been some minor improvements in this area recently. Mr. Hulbert had requested half an hour of indirectly supervised privileges on Hospital grounds. The doctor said that the treatment team did not agree with this as they would be worried that he might elope. Mr. Hulbert agreed that it might be better to be supervised as someone could hurt him or he could fall.
The Hospital is resistant to allowing any unsupervised privileges to Mr. Hulbert due to the concern of elopement. Mr. Hulbert is stable at this time, and the treatment team does not want to risk this progress. The Hospital wants Mr. Hulbert to continue to do well and if he were to elope, it would mean that he would loss any progress made.
Analysis and Conclusion
- The Board unanimously finds that Mr. Hulbert continues to pose a significant threat to the safety of the public. In arriving at this determination, the Board considered the joint position of the parties and accepted the uncontroverted evidence of Dr. Gray. The Board also relies on the Hospital Report, which notes the following:
“… Mr. Hulbert continues to pose a significant risk to the safety of the public. Although he has not had an incident of violence this year, nor an attempted elopement, if he was not under the structure and restrictions of an Ontario Review Board disposition, Mr. Hulbert would most likely attempt an elopement from whatever facility in which he was residing. He would not take medications if he had any control over the issue and this would worsen his mental state. When more ill, he becomes more agitated and has in the fairly recent past, struck out at staff without much provocation. Given also the severity of his index offences, committed while very unwell, one needs to be cautious regarding a risk of relapse in an uncontrolled environment in the future.”
The Board, therefore, is satisfied that absent an ORB Disposition, it is likely that Mr. Hulbert would become unwell and cause physical or psychological harm to members of the public. The Board unanimously determines that the necessary and appropriate Disposition required to manage the threat Mr. Hulbert poses to the safety of the public while still meeting his needs, is a continuation of the existing Detention Disposition.
In making this Disposition, the Board carefully considered the positions and submissions of the parties and the evidence of Dr. Gray and is satisfied that this determination is both necessary and appropriate. The Board reviewed the provisions of s. 672.54 of the Criminal Code and carefully considered the need to protect the public from dangerous persons, Mr. Hulbert’s mental condition, his reintegration into society and his other needs.
The Board commends Mr. Hulbert on his good year. It is very positive that he is more readily taking his medications, is participating in groups and structuring his time well. The Board is hopeful that in the coming year, Mr. Hulbert can continue on his current trajectory and move towards an appropriate, supervised community placement.
DATED this 24th day of February, 2026, at the City of Toronto, in the Toronto Region.
Ms. M. Chamberlain Legal Member
Office of the Registrar Ontario Review Board