Ontario Review Board
Re: Richard Laurin
ORB File No: 4854
Hearing held on: Thursday, November 27, 2025
Place of Hearing: Brockville Mental Health Centre
Pursuant to: Section 672.81(2.1) 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: Richard Laurin Counsel: Mr. M. Bird
The person in charge of hospital: Representative: Dr. R. Linthorst
Attorney General of Ontario: Counsel: Mr. K. Schultz
REASONS FOR DECISION
(Dated February 24, 2026)
Introduction
On August 22, 2007, the accused, Richard Laurin, was found not criminally responsible on account of mental disorder (“NCR”) on two charges each of possession under, fail to comply with a probation order, possession of a credit card obtained by the commission of an indictable offense, one charge each of use of a credit card obtained by the commission of an indictable offense, fraud under, fail to comply with an undertaking, uttering threats to kill, and failing to comply with a recognizance, all contrary to the Criminal Code of Canada.
Mr. Laurin is currently subject to a disposition of the Ontario Review Board dated July 7th, 2025, which detains him at the Secure Forensic Unit of the Brockville Mental Health Centre (the “Hospital”) with privileges up to and including to live in the community in accommodation approved by the person in charge.
By letter dated October 23rd, 2025, the Brockville Mental Health Centre, Member of Royal Ottawa Mental Health Centre, advised the Ontario Review Board that Mr. Laurin was admitted to hospital for a period exceeding seven days thereby restricting his liberties.
On November 27th, 2025, the Ontario Review Board convened a hearing at the Brockville Mental Health Centre, to review the restriction of Mr. Laurin’s liberty by readmission to the Hospital pursuant to s. 672.81(2.1) of the Criminal Code. Mr. Laurin attended the hearing and was represented by his counsel, Mr. Michael Bird.
The issues before the Board are whether the Hospital’s decision to significantly increase the restriction of Mr. Laurin’s liberty by readmitting him to hospital October 16th, 2025, was reasonable and warranted and represented the least onerous and least restrictive course of action available to the hospital.
At the outset of the hearing the parties were canvassed as to their preliminary positions, and the Board was presented with a joint submission that the Hospital’s decision to significantly increase the restriction of Mr. Laurin’s liberty was necessary and appropriate and represented the least onerous and least restrictive decision to manage the heightened risk presented by Mr. Laurin. The Hospital and the Attorney General Crown stated that the restriction continued to be necessary at the time of the hearing. Counsel for Mr. Laurin questioned the length of the restriction and stated that his client was hoping to return to his apartment in the community. At the conclusion of the hearing the parties maintained their initial positions.
For the reasons set out below, the Board finds that the decision of the Hospital to admit Mr. Laurin to the Forensic Assessment Unit on October 16th, 2025, was reasonable and warranted and represented the least onerous and least restrictive course of action available. The Board also found that the restriction remained necessary and appropriate at the time of the hearing.
Index Offences
- A description of the index offences is taken from last year’s Reasons for Disposition as follows:
“The index offences occurred on three separate dates in the City of Ottawa. On April 13, 2006, Mr. Laurin was bound by probation order with a term to keep the peace and be of good behaviour. He tried to use a stolen credit card at the Bay store in downtown Ottawa. Security officers found him in possession of a wallet that had been reported stolen earlier that day from a nearby location. The wallet contained stolen identification and two stolen credit cards. The police released Mr. Laurin on an Undertaking to appear in court.
Later, on August 10, 2006, while still on probation and now bound by the Undertaking, Mr. Laurin was arrested at the Money Mart on Montreal Road in Vanier. He was in possession of a stolen cheque. He told the police officer that the officer was going to lose his job. He gave a story, claiming that the cheque had been given to him by a man as a deposit on a painting contract. In fact, there was no painting contract. The victim of the theft had earlier reported her purse stolen, with the cheque inside.
While subject to a recognizance of bail on November 26, 2006, Mr. Laurin was at the Shepherds of Good Hope kitchen on Murray Street in Ottawa. After breakfast, a volunteer staff member informed him that the kitchen was closing and that he would have to leave. He threatened her with words, “You better watch yourself or you’re going to get shot.” Despite being warned, he repeated the threat three more times. Fearing for her safety, the volunteer activated a panic alarm. Police attended and arrested Mr. Laurin.”
Background
Mr. Laurin’s background history is sparse, mainly because he is an unreliable historian. It seems that he drank excessively as a teenager and engaged in street drugs.
Mr. Laurin has had a number of encounters with the criminal justice system and police commencing in 1984, details of which are outlined in the Hospital Report filed as an Exhibit at this hearing. His current diagnoses are:
- Schizophrenia, continuous
- History of Alcohol and Stimulant Use Disorder (Cocaine)
- History of Adult Antisocial Behaviour
- Chronic Obstructive Pulmonary Disease
- Hypercholesterolemia
- Since Mr. Laurin’s hospitalization following the index offences and his NCR finding, he has consistently suffered from delusions of grandiosity, claiming that he is King Richard and that normal rules do not apply to him. Although he has been compliant with medication, he does not know why he is taking medication and denies having an illness and that he does not need to be in Hospital.
Restriction of Liberty
- The Hospital Report outlines the restriction to Mr. Laurin’s liberty that occurred in mid-October 2025:
“…the outpatient team reported that Mr. Laurin had missed two consecutive appointments. This exceeded the timeframe allowed under his disposition. When staff attended his residence for follow-up, he refused them entry and yelled through the door that he had called police. He accused the team of being criminals.
The team determined that they could no longer safely assess him in the community. His psychiatrist, Dr. Linthorst, confirmed that Mr. Laurin was in breach of his disposition and represented a potential and ongoing risk to public safety. A Form 49 (Warrant of Committal) was therefore completed, and police were notified to return Mr. Laurin to hospital.
He was brought up and admitted to hospital on October 16. Mr. Laurin presented as guarded, angry and disorganized. He stated that he was ‘King Richard,’ that Dr. Alabi was a criminal,’ and that he was not a forensic patient. He referred to ‘Black Law’ and claimed that based on this law there was going to be a lawsuit against the hospital. He thought that he was legally protected from detention because of his royal status.”
…. “Since receiving his injection, he appears to have become less agitated and somewhat less disorganized, though remains irritable with numerous ongoing delusions. Some of his delusions are about being royalty, that all medical and legal staff in his care are involved a conspiracy to make money from his involvement in the forensic system, and that he is empowered by something called ‘Black Law’ that will protect him. These delusions have all remained consistent in intensity since treatment with medication.”
Evidence
The hospital’s evidence was presented through its Report dated November 7th, 2025 (Exhibit No. 1), as well as through the oral testimony of Dr. R. Linthorst.
Dr. Linthorst informed the Board that since his last annual review, Mr. Laurin had lived in the community. Initially, he attended appointments and accepted his medication as prescribed. Over time, however, he became less willing to accept the medication. In August, He accepted his injection but said that it was illegal and told the staff to get out of his apartment. Later he questioned his involvement with the ORB. Ultimately, Mr. Lauren refused to engage with the treatment team by not permitting them in his apartment and was readmitted to the Hospital.
Dr. Linthorst explained that the restriction remained necessary as Mr. Laurin’s functioning continued to be problematic and the Hospital felt that there was currently no safe placement available for him in the community. Mr. Laurin’s capacity was challenged, and he was recently found incapable of making his own treatment decisions or of managing his property.
Currently Mr. Laurin’s financial management is being transferred to the Public Guardian and Trustee. He cannot resume living in his apartment until this process is complete because of a delusional belief that he owns the entire building and therefore does not need to pay rent. He is therefore at risk of eviction from this housing.
The Hospital’s treatment plan for Mr. Laurin is to focus on his long-acting injectable medication and maintain a strict schedule that can be monitored by hospital staff.
In response to questioning by the Crown, Dr. Linthorst agreed with the following:
a. If Mr. Laurin were to be released from the Hospital, he would continue to resist working with the outpatient treatment team; he would be unlikely to pay rent and would most likely be evicted.
b. A release from the Hospital would precipitate afunctional decline for Mr. Laurin. He would act on his delusions and engage in conflictual behavior.
c. Mr. Laurin would be unlikely to be able to meet his own basic needs.
d. Mr. Laurin was experiencing positive symptoms while in the Hospital. He believed that the Hospital was making money by keeping him there. He also believed in “Black Law” and that the Hospital was going against this law by keeping him there.
e. The FIT team continued to be uncomfortable working with Mr. Laurin because of the manner he presented at the time of the hearing. Mr. Laurin would not voluntarily engage with the FIT team if he were living in the community.
f. Mr. Laurin was currently on the most restrictive unit in the Hospital. He was on the waitlist to transfer to the second most restrictive unit.
g. Mr. Laurin’s current medications are considered the most effective and so the treatment team is not thinking of other options. Mr. Laurin will not agree to the bloodwork required if he were to take Clozapine, so this medication is not available to him.
- Dr. Linthorst was asked what needed to happen before Mr. Laurin could return to community living. He stated that:
a. The Public Guardian and Trustee would have to take over control of Mr. Laurin’s finances. The service team has reported that this process has started, and it could take several months for them to set up financial control.
b. Mr. Laurin would have to demonstrate that he was willing to work with the FIT team in the community. Mr. Laurin could demonstrate his ability to do this by working with the Hospital social worker.
c. The treatment team would also want to see Mr. Laurin having insight into being in the forensic system.
Dr. Linthorst informed the Board that currently Mr. Laurin was not able to leave the Hospital without permission. He is not allowed any passes on his current unit. Once he transfers to the next unit Mr. Laurin would be able to have privileges, the highest of which would be indirectly supervised community time. The Hospital is concerned that Mr. Laurin would attempt to elope so it may be some time before he is granted any community privileges. The treatment team has attempted to explain to Mr. Laurin that he is subject to a detention order and is required to follow certain conditions, including meeting with the treatment team when he is in the community. Mr. Laurin simply does not believe this to be true.
In response to questions from the Board, Dr. Linthorst stated that if Mr. Laurin were to return to the community at this time he would refuse to work with the FIT team. He would likely engage in conflictual behavior and may become verbally abusive. He may not be physically violent to the public, but he would be at risk to himself.
A member of the Board noted that Mr. Laurin responded best to first generation antipsychotic medications but that he was not taking them. The Board member questioned if Mr. Laurin was under treated and wondered if a medication review would be helpful. Dr. Linthorst informed the Board that the pharmacy had completed a medication review but agreed that perhaps a deeper chart review would be helpful.
The Law
The analytical framework established by Campbell (Re), 2018 ONCA requires the Board to consider the liberty norm and the liberty status of an accused on a restriction. The liberty norm and liberty status for each restriction must be examined to determine the significance of the increase (if any) on the restriction of an accused’s liberty caused by the restriction. In determining the liberty norm of an accused at the outset of each period of restriction, the Board must “take a contextual approach, one that considers the individual’s pattern of liberty in the recent past.” ((Re) Campbell, para. 66). The liberty she/he was actually experiencing (rather than what she/he was entitled to) at the time of the increase is what the Board is to consider, and that “liberty must be of sufficient duration to have become, objectively speaking, the NCR accused’s norm” ((Re) Campbell, para. 65).
The test to be applied to significant increases in the restriction of liberty is the same as is required for dispositions- whether the significant increase is necessary and appropriate to protect the safety of the public.
Conclusion and Disposition
Prior to his seclusion, Mr. Laurin had been residing in the community, in his own apartment with regular check-ins. He was seen by the outpatient treatment team at least once every two weeks. For this reason, the Board finds that at the time of his re-admission to Hospital. Mr. Laurin’s liberty norm was community living in accommodation approved by the person in charge. In the Hospital, Mr. Laurin did not have the ability to leave without staff accompanying him and even then, only did so on rare occasions. The Board finds that the return to the Hospital represents a significant increase in the restrictions on Mr. Laurin’s liberty.
The Board further finds that Mr. Laurin’s reluctance and then refusal to take his prescribed medication and meet with the outpatient team was serious and it was necessaary to have him return to the Hospital to ensure the safety of the public. For these reasons, the Board finds that the significant restriction on Mr. Laurin’s liberty was necessary and appropriate at the time it was imposed.
The ROL Report indicates that since returning to the Hospital, Mr. Laurin continues to have delusions and is unwilling to work with his treatment team. The Board therefore finds that the significant restriction on Mr. Laurins’s liberty continued to be necessary and appropriate at the time of his hearing.
For these reasons, the Board finds that the significant increase in the restriction of Mr. Laurin’s liberty was necessary and appropriate and the least onerous and least restrictive at the time it was imposed and continued to be so at the time of his hearing.
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