Uchenna Onochie (Re), 2026 CanLII 18276

Ontario Review Board

Re: Uchenna Onochie

ORB File No: 6876

Hearing held on: Thursday, January 29, 2026

Place of hearing: St. Joseph’s Healthcare Hamilton West 5th Campus, 100 West 5th Street

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

Before:

Alternate Chairperson: Mr. J. Weinstein

Members: Dr. H. Bloom Dr. A. Kerry Hon. A. Sosna Mr. A. Mete

Parties Appearing:

Accused: Uchenna Onochie Counsel: Mr. A. Rai

The person in charge of hospital: Counsel: Mr. S. O'Brien

Attorney General of Ontario: Counsel: Mr. B. Adsett

REASONS FOR DISPOSITION

(Dated March 3, 2026)

Introduction:

1. On December 17, 2015, Mr. Uchenna Onochie was found not criminally responsible on account of mental disorder, on a charge of second-degree murder, contrary to the Criminal Code of Canada (“Criminal Code”).

2. Mr. Onochie is subject to a Disposition of the Ontario Review Board (the “Board”), dated January 30, 2025, which orders that he be detained at the Forensic Psychiatry Program of St. Joseph's Healthcare Hamilton - West 5th Campus (“St. Joseph's”).

3. On January 29, 2026, the Board convened a hearing at St. Joseph's to conduct the annual review of the current Disposition.

4. Mr. Onochie was present and was represented by his counsel, Mr. A. Rai.

5. A Hospital Report, dated January 12, 2026, (the "Hospital Report"), was entered as Exhibit 1.

6. The issues of the hearing were whether Mr. Onochie is a significant threat to public safety, as defined in s. 672.5401 of the Criminal Code, and, 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.

7. For the reasons set out below and based on the expert evidence and opinions before it, the Board concluded that Mr. Onochie continues to represent a significant threat to the safety of the public. The Board ordered that the necessary and appropriate Disposition in the circumstances is the continuation of the existing Detention Order.

8. The Board held a Restriction of Liberty (“ROL”) hearing, pursuant to section 672.561(2) of the Criminal Code, on September 23, 2025. The reasons for the ROL are set out in the Reasons for Decision, dated November 3, 2025:

"The ROL Report provides the rationale and Dr. Prat’s opinion for the original restriction of liberty and ongoing restriction, excerpted as follows:

“Mr. Onochie was readmitted on August 14, 2025, after he informed the team that he was not permitted to return to work due to a pending investigation. Mr. Onochie at that time had limited information and only knew that it was related to him touching a female co-worker’s head while being on break. While I was not present when the decision of admission took place, I have reviewed the reasons leading to this decision and feel that a careful and balanced approach was exercised, justifying the need for him to be monitored and assessed on the inpatient unit.”

9. The Reasons for Decision also contain the following relevant paragraphs:

"The ROL Report outlines that the treatment team felt that Mr. Onochie was not reporting all the information to the treatment team relating to the incident leading to the investigation by his employer, Amazon. This complicated their ability to perform an adequate assessment of risk to the community. Factors that were considered in readmitting Mr. Onochie to hospital included:

a) Mr. Onochie has engaged in past behaviours that crossed boundaries with female peers.

b) Despite having received one-on-one support, Mr. Onochie sometimes has difficulty identifying when and how he crosses the social boundaries with female peers and fails to identify red flags in his relationships with women.

c) Mr. Onochie initially identified that the female co-worker had been a friend of his for some time. He indicated he tried to establish a romantic relationship with her, but she declined. When Mr. Onochie reported the incident, he initially failed to disclose that he had asked her out again two weeks prior to the incident

d) Mr. Onochie was oblivious to the effect that his behaviour could have on his female peer. The treatment team had no information to confirm or refute his statement that there was no force or coercion involved. The team noted in the ROL Report that Mr. Onochie initially had not been forthcoming about particulars of the incident.

e) Mr. Onochie received a termination letter from his employer a few weeks after the incident after he was already admitted to the hospital. There were no details provided in the termination letter.

f) It was felt by the treatment team that the decision to terminate Mr. Onochie could have been based on serious concerns of his employer, as they had previously known him as a dedicated worker. Mr. Onochie was informed by the team that understanding what led to his behaviour and addressing the issue effectively would help him maintain future employment long-term. However, Mr. Onochie did not understand that a similar situation could occur in the future.

g) After Mr. Onochie was suspended from work, he experienced a few episodes of acute auditory hallucinations that were extremely distressing to him.

h) For a short time, his mother was displeased with the situation and stopped talking to Mr. Onochie.

i) For some time, Mr. Onochie had been expressing a concern about his finances. He had been wanting to find a less expensive apartment or find a roommate. Before receiving the letter of termination, he decided that he would remain in hospital until he could find more affordable accommodations. Once he received the letter of termination, he had to vacate the apartment by the end of November 2025 when his lease would terminate. The treatment team suggested that he may be able to be discharged back to his apartment until the end of his lease in November. However, Mr. Onochie wished to remain in hospital and organize moving and selling his furniture as soon as possible.

j) Mr. Onochie’s mental status remains stable, despite the short-lived acute symptoms. He does not require an adjustment in his medication.”

10. For the reasons set in the Reasons for Decision, that Board found that the restriction of Mr. Onochie's liberty, from August 14, 2025, to the date of the hearing, was necessary and appropriate; it represented the least onerous and least restrictive measure at the time it was imposed and continued to do so.

Current Psychiatric Diagnoses:

11. Schizophrenia

Substance use Disorder, in remission.

Index Offence:

12. The circumstances giving rise to the Index Offence are extracted from last year's Board Reasons, as follows:

“On December 16, 2015, Uchenna Onochie came before this court for trial on a charge that, on the 17th of January 2015, he killed Aloy Onochie and thereby committed Second Degree Murder; contrary to S. 234(1) of the Criminal Code…

There is no dispute with respect to the facts surrounding the death of Aloy Onochie. At the time of his death, he was 60 years of age and was residing with the defendant, his 18-year-old son, in a condominium apartment near the intersection of Finch Avenue and Yonge Street in Toronto. Is it admitted that he died as a result of multiple stab wounds that were inflicted by the defendant late on the evening of Saturday, January 17. Immediately after the infliction of those injuries, the defendant fled from the apartment and ran to the Finch subway station in his bare feet, clad only in a t-shirt and pajama pants. He was covered in blood and he was brandishing a knife. When the police arrived, the defendant refused to drop the knife because, he said, ‘The devil is here.’ Eventually, the police were able to persuade him to drop the knife and he was taken into custody.

There is no suggestion that the defendant had any lawful justification or excuse for the assault on his father; nor is there any evidence of provocation. The joint position of the Crown and the defence, however; is that the defendant should not be found guilty of murder or of any other offence because he was not criminally responsible for his conduct.”

Course Since Last Disposition:

13. The following extracted paragraphs from the Hospital Report are relevant to this hearing:

"Mr. Onochie was transferred from Waterfall 3 to Mountain 2 on August 20, 2025. Mr. Onochie was admitted to the hospital as an inpatient after exhibiting inappropriate behavior at work, which involved “touching” a female colleague on the head. Initially, he told his outpatient case manager that he had shaken the co-worker’s head, but he later clarified that he had “touched” her on the back of the head.

Mr. Onochie endorses auditory hallucinations on a regular basis. He describes them as being derogatory in nature and he has been witnessed and overheard by staff to experience considerable distress and anxiety. At these times, Mr. Onochie requests “as needed” Loxapine and Lorazepam on a daily basis to counter the auditory hallucinations. Socializing, listening to music, watching TV and working are other coping strategies that are known to help him cope with the voices. He denies thoughts of suicide, self-harm or harm to others when asked.

August 13^th and 14^th, 2025: At approximately 10:30 a.m. on August Mr. Onochie contacted his case manager stating that he was “not having a good day” after being indefinitely suspended from his position at Amazon with pay. He reported that the suspension followed an incident involving a female co-worker, during which he approached her from behind while she was seated outside and “shook her head”. He stated that the co-worker asked him not to repeat the behaviour, and he apologized at the time. He later learned that she reported the incident to Human Resources. Mr. Onochie expressed significant anxiety and fear of termination, noting that Amazon had instructed him not to contact the company or attend the premises, and that police would be notified if he did so.

This event appeared to represent a significant stressor for Mr. Onochie, especially given his documented history of sexually inappropriate behaviour and limited insight into boundaries.

Given the uncertainty surrounding the circumstances of his suspension, the nature of his physical contact with the woman, and the potential for symptom escalation due to stress, along with the current instability in both his employment and housing, the treatment team prioritized close monitoring. Mr. Onochie was readmitted to the inpatient forensic unit at St Joseph’s Healthcare Hamilton, Waterfall 3."

Mr. Onochie had been residing in a market rent apartment in Hamilton since November 2023. He had been followed by the Forensic Psychiatry Outpatient team until his readmission in August 2025. Upon his readmission and termination of employment, Mr. Onochie was not able to afford the rent for his apartment. He gave notice and vacated his apartment by September 30, 2025."

Position of the Parties:

14. Counsel for the hospital, the Attorney General, and Mr. Onochie advised that this was a joint submission: all were adopting the hospital’s recommendation of a continuation of the existing Detention Order.

15. Counsel for Mr. Onochie advised that he would not be disputing the issue of significant threat for the purposes of this hearing

Evidence at the Hearing:

16. The Board had available to it the evidence, documents forming the Record, the Exhibits, and oral evidence from Dr. Prat. Dr. Prat co-authored the Hospital Report and testified as follows:

a) He has been Mr. Onochie’s attending psychiatrist, and the most responsible physician, for four years. He has reviewed the Hospital Report and adopts its contents.

b) Mr. Onochie is currently an inpatient in Mountain 2.

c) Mr. Onochie was readmitted to the hospital in August 2025.

d) Mr. Onochie has not posed any management issues and has been working on interpersonal relationship skills and coping strategies for anxiety. He sometimes struggles with feedback, often seeking approval and perceiving constructive criticism as dislike. This difficulty accepting feedback is a longstanding issue.

e) Mr. Onochie has used his passes to spend time with friends, without incidents.

f) Mr. Onochie has actively sought information from Amazon, his former employer, about his termination, and he has visited a legal clinic for advice.

g) The treatment team initially paused Mr. Onochie's job search to seek clarification about why Mr. Onochie's employment was terminated by Amazon. Mr. Onochie is now updating his CV and seeking employment.

h) Mr. Onochie, to his credit, declined an opportunity for independent housing two months ago, because of financial uncertainty.

i) Mr. Onochie provided Dr. Prat with the termination letter that he indicated he received from Amazon. This letter was highly unusual, as it had no letterhead and was unsigned.

j) The treatment team has not received any information from Amazon about why Mr. Onochie was terminated, despite making multiple requests.

k) Mr. Onochie has worked one on one with the occupational therapists to identify difficulties and learn to receive feedback. Mr. Onochie is to start a healthy relationship group in February, which may help him learn how to understand social boundaries, from others’ experiences.

l) Mr. Onochie continues to display "all or nothing thinking and rigidity." For example, he often seeks consent at every stage of a relationship, and does not understand the flexibility and nuances of relationships.

m) When Mr. Onochie experiences stress, he has increased difficulty accepting feedback, as it impacts his self-esteem.

n) The team has received feedback from his friends, with Mr. Onochie's consent; they raised no concerns regarding boundaries, nor any other issues.

o) Mr. Onochie's rigidity and approval seeking may be attributed to low self-esteem and lifetime dynamics, rather than to any mental health issues.

p) Mr. Onochie may have some cognitive impairment, but it does not affect his independence or his social functioning.

q) The treatment team is working on discharge planning, but any discharge is dependent on several factors: Mr. Onochie gaining full employment; Mr. Onochie financial situation; and the availability of housing. Mr. Onochie does desire independent living and is mindful of his financial constraints.

r) The current Disposition is considered necessary and appropriate for the safety of the public.

s) Mr. Onochie remains compliant with his medication regimen, and he has had no instances of aggression, violence, or substance use. He has also attended a group delivered by the Canadian Mental Health Association (CMHA).

17. In response to questions from counsel for the Attorney General, Dr. Prat testified:

a) Mr. Onochie is seeking employment similar to his previous warehouse employment. He was employed by Amazon for a number of years.

b) Despite years of treatment, Mr. Onochie continues to experience daily hallucinations and regularly hears voices. Mr. Onochie is optimally treated. The intensity of his symptoms fluctuates, often driven by anxiety.

c) Mr. Onochie sometimes overstates the degree of his anxiety and requires encouragement to use coping strategies, such as walking on hospital grounds.

d) When Mr. Onochie spent time with a friend over Christmas, he did not use any PRN medication. This experience validated Mr. Onochie’s belief that the hospital environment causes his anxiety. Dr. Prat does not share this viewpoint.

18. In response to questions from counsel for Mr. Onochie, Dr. Prat testified:

a) Mr. Onochie has met with the occupational therapist and completed the Java club; however, it should be noted that it is a low-barrier program, and its completion would be expected, given Mr. Onochie's cognitive functioning.

b) Mr. Onochie attends the CMHA group regularly and benefits from strong support from friends and family.

c) Mr. Onochie's auditory hallucinations are bothersome, but never commanding in nature.

d) Regarding the alleged incident that led to Mr. Onochie's termination from Amazon, the team have not observed any similar inappropriate behaviour during treatment.

19. In response to questions from the panel, Dr. Prat testified:

a) The panel raised concerns about the authenticity of the Amazon termination letter. He explained that the letter was provided by Mr. Onochie; it was sent from an email address that, according to his personal research, appeared consistent with Amazon's format. He did not feel that Mr. Onochie had the skills to fabricate such an email address.

b) Mr. Onochie's involvement with the legal aid clinic is very recent, and Dr. Prat has no further information.

c) Mr. Onochie's priority in pursuing this lawsuit is not financial compensation, but proof for the clinical team, and the Board, that he had not engaged in inappropriate behaviour.

d) Mr. Onochie's approval seeking behaviour can be attributed to life experience dynamics, including early experiences, the impact of not completing his studies, and substance use. This behaviour has been a long-standing issue, and therapy has focused on helping Mr. Onochie internalize self worth, rather than seeking external validation. Mr. Onochie has made some progress in reducing this approval seeking behaviour, but it remains a challenge, especially when he is under stress.

e) While the Hospital Report notes that Mr. Onochie has sometimes been evasive or guarded about interpersonal relationships and financial matters, this guardedness was more about difficulty facing criticism and a desire to prove independence, rather than intentional deceit.

f) The treatment team's focus remains on development of coping skills and psychotherapy, rather than any medication optimization, such as Amisulpride as an adjunctive to his current antipsychotic medication.

g) Mr. Onochie tends to use PRN medication pre-emptively, because of anxiety, and the treatment team is working to reduce this reliance.

h) Mr. Onochie had completed cognitive behavioural therapy (CBT) for psychosis, gaining skills in recognizing early warning signs and the importance of treatment, but he still struggles to apply coping strategies independently. It would be useful to have a formal cognitive assessment, to help inform the team about appropriate employment and accommodations that could be needed. Mr. Onochie is on a wait list for sexual behaviour assessment, which is important for the team's understanding of how to best treat him. Nevertheless, Dr. Prat feels that the treatment team is clinically equipped to manage Mr. Onochie's current risks without this assessment.

i) Mr. Onochie's limited ability to handle stress, and its resulting anxiety, are risk factors. The Mental Health Act would not be sufficient to respond to stress or anxiety which is one of the reasons that a Detention Order is necessary and appropriate. The treatment team also needs to retain the ability to approve Mr. Onochie’s housing, as he still makes impulsive financial decisions, which cause him stress. In the past, Mr. Onochie wanted to have subletters or roommates, which would have been additional stressors and would have increased his risk to public safety.

20. No other evidence was called.

Analysis and Conclusion:

21. Having heard and considered the entirety of the evidence as well as the submissions from the parties, the Board agrees with the joint submission: Mr. Onochie remains a significant threat to the safety of the public.

22. In Winko, the Supreme Court outlined that, in coming to the conclusion on the issue of significant risk, a Review 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. Prat, in addition to the documentary evidence before us.

23. While Mr. Onochie has made progress in areas such as interpersonal relationships and boundaries, his ongoing challenges with psychotic symptoms, stress management, and decision making, combined with the absence of stable protective factors, indicate that he remains a significant threat to public safety.

24. Mr. Onochie struggles with managing stress and anxiety, which exacerbates his psychotic symptoms. His reliance on PRN medications and staff reassurance further indicate limited coping strategies.

25. Mr. Onochie exhibits rigid thinking. This all-or-nothing mindset limits his ability to evaluate alternative solutions, and it contributes to impulsive decision making and anxiety.

26. Mr. Onochie currently lacks stable housing, employment, and a consistent routine, which are critical protective factors for his recovery and stability.

27. In particular, the Board relies on the following extracted paragraphs from the Hospital Report:

"The majority of Mr. Onochie’s relevant risk factors on his last completed HARM (November 18, 2025) are considered to need continued monitoring at this time (i.e., his experience of psychotic symptoms, insight into his illness, ability to maintain a positive, cooperative attitude, to follow rules, to control his impulses, to participate meaningfully in therapeutic, educational, and employment activities, and to maintain supportive relationships with prosocial family and peers). His use of substances also continues to be monitored as a condition of his disposition. The lone risk factor considered managed at this time is his adherence to prescribed medications.

Taking into account the results of his most recent psychological risk assessment, monthly HARM reviews, and progress during the reporting period, Mr. Onochie’s integrated risk for violent reoffending remains low on a Detention Order disposition. As the clinical team is not recommending any significant changes to his disposition, a comprehensive re-assessment of risk is not warranted at this time.

That being said, Mr. Onochie’s history of personal boundary violations with females remains a concern, particularly given the recent termination of his employment.

One remaining concern is his ability to manage anxiety related to residual symptoms of psychosis. Over the past six months, he has relied extensively on PRN medication and staff support. Only in the past month and a half has he become more engaged in alternative coping strategies, such as walking or attending additional programs.

He continues to experience certain risk factors, including residual psychotic symptoms that fluctuate with his anxiety level, recent but still-stabilizing improvements in interpersonal relationships and boundaries, and ongoing rigidity in his thinking, which limits his ability to identify optimal solutions and contributes to his anxiety. His protective factors remain limited due to the absence of a consistent routine, employment, and stable housing; however, he demonstrates internal motivation to regain independence. Based on all of the above, he continues to meet the threshold for significant threat to public safety. His care requires management under a Detention Order with community living provisions. Although he has shown the ability to overcome difficulties, this progress required time, and he was not initially receptive to our feedback or to the need for a gradual and safe process before returning to work. Therefore, if he were placed on a Conditional Discharge."

28. In light of the Board's finding of significant threat, it is charged with shaping a disposition for the coming year. It is clear from Dr. Prat's evidence that the Mental Health Act would not be sufficient to protect the safety of the public, as Mr. Onochie's risk factors, stress and anxiety, would not be sufficient to engage the provisions of the act. Dr. Prat also indicated that the hospital needs to retain the ability to approve Mr. Onochie's accommodations, in order to make sure that he does not act impulsively, nor choose to sublet or live with others, as he has done in the past.

29. In consideration of all the evidence, submissions of the parties and criteria set forth in s. 672.54, the paramount consideration being the safety of the public, in addition to the mental condition of Mr. Onochie, his reintegration into society and his other needs, the necessary and appropriate Disposition is the continuation of the existing Detention Order.

DATED this 3^rd day of March 2026, at the City of Toronto, in the Region of Toronto.

Mr. J. Weinstein Alternate Chairperson Office of the Registrar Ontario Review Board