Re: Dale T. Bull
ORB File No: 8749
Hearing held on: Tuesday, December 9, 2025
Place of hearing: Thunder Bay Regional Sciences Health Centre
Pursuant to: Section 672.81(2.1) of the Criminal Code
Before:
Alternate Chairperson: Mr. J. Goldenberg Members: Dr. G. Chaimowitz Dr. G. Eayrs Hon. E. Kruzick Mr. S. Duffy
Parties Appearing:
Accused: Dale T. Bull Counsel: Mr. G. Iwasiw
The Person in charge of Hospital: Representative: Dr. E. Leinonen
Attorney General of Ontario: Counsel: Ms. R. Derouard
REASONS FOR DECISION
(Dated January 14, 2026)
Introduction
1Dale T. Bull was found not criminally responsible (“NCR”) of arson causing damage to property on July 24, 2024, contrary to the Criminal Code of Canada (“Criminal Code”). Pursuant to a Detention Disposition, dated August 5, 2025, Mr. Bull was detained at the Secure Forensic Unit of the Thunder Bay Regional Health Science Centre (“TBRHSC”) with the privilege to live in the community of Northwestern Ontario in accommodation approved by the person in charge. As a result, Mr. Bull has been living at the home of his parents at 118 Whitefish Bay, Lac Seul First Nation.
2By a letter dated October 8, 2025, the TBRHC notified the Board pursuant to s. 672.56(2)(b) of the Criminal Code of the restriction of liberty of Mr. Bull for a period exceeding seven days. On October 10, 2025, the Ontario Review Board (“ORB”) acknowledged the letter and proceed to schedule a Restriction of Liberty hearing on December 9, 2025, pursuant to s. 672.81(2.1) of the Criminal Code.
3Mr. Bull attended today’s hearing by teleconference from Lac Seul. He was represented by his counsel, Mr. G. Iwasiw, who attended the hearing by the Ontario Telemedicine Network (“OTN”) from Kenora.
Issues at the Hearing
4The issues to be decided are whether Mr. Bull’s liberty was restricted for a period exceeding seven days, and if so, whether the restriction was the least onerous and least restrictive in the circumstances.
Position of the Parties
5At the outset of the hearing, the Alt. Chair canvassed the parties with respect to their preliminary positions. On behalf of the hospital, Dr. Leinonen stated that Mr. Bull’s liberty was restricted for a period exceeding seven days, and that the restriction was the least onerous and least restrictive in the circumstances.
6On behalf of the Attorney General, Ms. Derouard indicated that she agreed with the position taken by the Hospital.
7Mr. Iwasiw, as counsel for Mr. Bull, took no issue with the position of the hospital. As a result, this was a joint submission.
Findings
8For the Reasons that follow, the panel found that Mr. Bull’s liberty was restricted on September 26, 2025, and that the restriction was the least onerous and least restrictive in the circumstances.
Index Offence
9The allegations giving rise to the index offence are set out in the Hospital Report as follows:
“June 30, 2023, at 9:00 pm The Lac Seul Police received information of possible House fire in Kejick Bay. Cst. Gordon in the community of Kejick Bay searched with negative results. PCC then advised Officers of several calls reporting a fire in Whitefish Bay at the John Bull Jr. residence.
At 9:22 pm, Cst Gordon arrived on scene at 5 John Bull Drive Whitefish Bay. Police observed a residence to be full engulphed in flames. Lac Seul First Nation fire crews were on scene attempting to extinguish the blaze. Cst Gordon spoke to witnesses on scene, they advised Dale Bull may possibly be inside the residence. A/Sgt Kejick arrived on scene shortly after and assisted with crowd control.
June 30, 2023, John Bull Jr was at his residence with his son Dale Bull. At approximately 7:30 p.m. he left the residence to visit with his other son Jonathan Bull at his residence down the road. At approximately 8: 00 pm John returned to his residence meeting with his son Dale Bull as he was exiting the residence. John attended his bedroom where he observed a small fire in his bedroom. John quickly filled up a bin with water and extinguished the fire in his bedroom. He then attended his son Dale’s bedroom where he observed a larger fire. John attempted to extinguish the blaze with negative results. He then ran to the nearby residence on Ian Trout to ask for assistance. The duo re-attended the scene of the fire and quickly learned the fire had gotten out of control and could not be put out. John ran across the street to the residence of community firefighter member Cory Smith to ask for assistance.
Cory then dispatched the rest of Lac Seul First Nations Fire team and all its available resources. Cst Gordon and A/sgt Kejick along with community members showered the community attempting to locate Dale Bull as the fire team battled the blaze.
At approximately 9:52 pm A/Sgt Kejick located Dale Bull emitting from the wooded area adjacent to the residence. As Police approached the male he advised A/Sgt Kejick he started the fire to rid the house of evil spirits. A/Sgt Kejick advised Dale Bull he was under arrest contrary to Section 434 of the Criminal Code of Canada. He was read his Rights to council and Caution which he stated he understood and declined speaking to council. He was placed in the Police vehicle while officers assisted members on scene.
At 11:14 pm Dale was lodged at the Lac Seul Police detachment without incident.”
Background Information
10Mr. Bull is a 32-year-old Indigenous man born in Sioux Lookout, Ontario.
11Prior to his arrest on the index offence, Mr. Bull was living with his parents in Lac Seul, Whitefish Bay First Nation. He is single, not employed, and supported financially by Ontario Works.
12Mr. Bull was raised by his parents and is the youngest of four boys. His parents are Residential School survivors who have a history of alcoholism.
13Growing up, Mr. Bull met all his milestones and enjoyed a good relationship with his brothers. He succeeded academically with some learning difficulties.
14During his adolescence Mr. Bull had limited involvement with mental health services and had no history of psychiatric admissions. He experienced the death of a good friend which was very difficult for him to bear.
15At around the age of 17, he engaged in substance use, consuming marijuana, and alcohol. At age 18, while intoxicated, he attended the Sioux Lookout Emergency Department after a suicide attempt.
16During his high school years, Mr. Bull resided in a boarding home in Frenchman's Head, Ontario, a small community northwest of Sioux Lookout.
17In 2019/2020 there was a change in Mr. Bull’s mental health. He described feeling depressed which progressed to increased preoccupation of religious beliefs and symptoms of psychosis.
18In March 2022, Mr. Bull was employed in seasonal positions involving hands-on skills such as renovation, construction, and maintenance at a lodging camp. He last worked in March of 2022 in construction building power lines. He discontinued his employment because of his inability to manage anger, his conflicts with colleagues and his paranoid thoughts.
19Prior to the alleged offence, in June 2023, Mr. Bull mostly stayed at home with few outside interactions. As a result of Mr. Bull’s arrest on June 30, 2023, he was in custody at the Kenora District Jail. Following his release, Mr. Bull was residing at the home of his uncle Frederick as his surety. He was taking prescribed medication and not using substances.
20Mr. Bull has been residing with his parents in Lac Seul since his initial hearing held on June 25, 2025.
Psychiatric History
21Mr. Bull’s Current Diagnosis is set out in the Hospital Report as schizophrenia.
Evidence at the Hearing
22The Board admitted into evidence the Hospital Report dated November 21, 2025. The Hospital Report provides a great deal of information concerning Mr. Bull, his personal history, his mental health history, and details of the outstanding charge. In addition, the Board heard the viva voce evidence of Dr. E. Leinonen, a co-author of the Hospital Report. Dr. Leinonen adopted the contents of the report.
23Dr. Leinonen testified that the restriction of Mr. Bull’s liberties began on September 26, 2025, when Mr. Bull came to Thunder Bay with his family. As a result of being in Thunder Bay, an outpatient appointment was arranged at the hospital. Mr. Bull attended the appointment accompanied by his mother and brother.
24Mr. Bull was initially seen on his own. He told Dr. Leinonen that experienced “beings” which he described as “people going through time.” Mr. Bull also told Dr. Leinonen he was having command hallucinations to harm himself. When asked about any current plan or intention to self-harm, Dr. Leinonen stated Mr. Bull was vague and expressed, “I don’t think things are going to go very good for me.”
25When Dr. Leinonen asked Mr. Bull if he could speak to his family, Mr. Bull agreed. In meeting with Mr. Bull’s mother, Ruby, she expressed concern for Mr. Bull. She reported that Mr. Bull was not taking any of the anti-psychotic medication as prescribed. His mother stated that Mr. Bull became angry when reminded to take his medication which was concerning to the family.
26Based on Mr. Bull’s state of active psychosis and his non-adherence to antipsychotic treatment together with the family’s expressed concern, Dr. Leinonen testified that, on September 26, 2025, the treatment team decided to admit Mr. Bull to the Secure Forensic Unit.
27Dr. Leinonen reported that, at first, Mr. Bull was angry for being admitted. Even with his family’s assurance, Mr. Bull was argumentative, kicked Dr. Leinonen’s desk, and stated that he did not need the medication prescribed.
28Once on the unit, Dr. Leinonen testified that with medication Mr. Bull settled quickly. The hospital team observed some signs of ongoing psychosis. For example, Mr. Bull would inappropriately smile and laugh to himself. On October 9, 2025, Mr. Bull described an ongoing auditory hallucination in the form of voices and expressed peculiar thoughts about the universe.
29Dr. Leinonen testified that with some adjustment to Mr. Bull’s medication, by mid-October, Mr. Bull’s psychotic symptoms were beginning to remit. By late October, Mr. Bull appeared to be quite stable. Mr. Bull’s family remained in touch with Mr. Bull and the hospital team while he was in the hospital. In consultation with Mr. Bull’s parents on October 21, 2025, they expressed that they were comfortable with Mr. Bull’s discharge and return to their home pursuant to the Detention Disposition.
30Mr. Bull was much improved and was discharged on October 25, 2025.
31In response to a question from Mr. Bull’s counsel, Dr. Leinonen stated that the Mr. Bull’s geographic location in Northwestern Ontario poses some challenges. As an example, as his treating psychiatrist, Dr. Leinonen, met with Mr. Bull in person for the first time on September 26, 2025. He indicated that the hospital will endeavour to explore ways of dealing with the difficult geographic issues.
32In his testimony, Dr. Leinonen opined that the restriction of Mr. Bull’s liberty was, in the circumstances, warranted for the safety of the public, supported by Mr. Bull’s family, and was the least onerous and least restrictive way to manage Mr. Bull’s risk.
33In response to questions from the Board and Mr. Bull’s counsel, Dr. Leinonen addressed some of the geographic challenges that living in Lac Seul First Nation presents in managing Mr. Bull’s mental health. As an example, the pharmacy that supplies Mr. Bull’s medication is about 1 ½ hours’ drive from Mr. Bull’s residence. Mr. Bull’s case manager is located in Kenora, Ontario, and Mr. Bull consults with Dr. Leinonen and the hospital team are conducted virtually. Dr. Leinonen expressed a desire to ameliorate the challenges if possible.
34No further evidence was called.
Submissions of Counsel
35Dr. Leinonen acknowledged that Mr. Bull’s liberty was restricted by his admission into the hospital on September 26, 2025. It was submitted that the restriction of Mr. Bull’s liberty was in the circumstances warranted for the safety of the public, supported by Mr. Bull’s family, and was the least onerous and least restrictive way to manage Mr. Bull’s risk.
36On behalf of the Attorney General, Ms. Derouard agreed with the submissions of the hospital.
37Mr. Iwasiw, as counsel for Mr. Bull, stated that he agreed with the hospital’s position. Mr. Iwasiw expressed that Mr. Bull has the support of his family who want the best for him.
Analysis and Conclusion
38The Board carefully reviewed the evidence at this hearing and unanimously concluded that the hospital’s notice of the increased restriction of Mr. Bull’s liberty was appropriately made. On the testimony of Dr. Leinonen, the panel finds that Mr. Bull’s admission to the Forensic Unit of the TBRHSC was in the circumstances warranted given Mr. Bull’s decompensation.
39In coming to our conclusion, the Board accepts Dr. Leinonen’s evidence that Mr. Bull suffers from a major mental disorder, namely schizophrenia. The panel accepts Dr. Leinonen’s evidence that in his assessment of Mr. Bull on September 26, 2025, Mr. Bull was clearly decompensating and needed to be admitted to the hospital for health and risk reasons. The Board relies on the expert evidence that Mr. Bull is likely to re-offend in the context of a decompensation because of his psychosis.
40We find that the restriction of Mr. Bull’s liberty was warranted in light of the twin goals of public safety and to ensure that the conditions the hospital imposed met the least onerous and least restive standard as set out in Chaudry (Re), 2015 ONCA 317.
41We accept the evidence that Mr. Bull’s conduct was a concern to his family with whom he lives. Mr. Bull decompensated when he refused to abide by the medication regime put in place to manage his serious mental disorder. The evidence of Dr. Leinonen, which we accept, is that Mr. Bull’s family was concerned about the risk Mr. Bull posed if he returned to the community. Mr. Bull has returned to residing in the family home. His mental deterioration could entail a recurrence of the psychotic belief that the family home needs to be purged of evil spirits.
42The Board has a duty to treat vulnerable NCR patients with the utmost of dignity: Winko v. British Columbia (Forensic Psychiatric Institute), 1999 CanLII 694 (SCC), 1999 2 S.C.R. 625. The hospital team took immediate steps to treat Mr. Bull and to promote his return into the community. We encourage the hospital to continue in that pursuit and to deal with the challenges that a patient living in Lac Seul First Nation presents for the treatment team.
43In considering the evidence, the panel unanimously finds that given Mr. Bull’s serious mental illness, the decision to impose more restrictive measures was necessary to manage the risk Mr. Bull posed to others and himself. We are satisfied that the restriction of liberty in the circumstances of this case was the least onerous and restrictive measure.
DATED this 14th day of January 2026, at the City of Toronto, in the Toronto Region.
Mr. E. Kruzick Legal Member
__________________ Office of the Registrar Ontario Review Board