Re: William R. Medcof
ORB File No: 3680
Hearing held on: Wednesday, November 26, 2025
Place of hearing: Centre for Addiction and Mental Health
Pursuant to: Section 672.81(2.1) of the Criminal Code
Before:
Alternate Chairperson: Ms. C. Finley
Members: Dr. Y. Alatishe Dr. L.O. Lightfoot Hon. B. Allen Mr. J. Cyr
Parties Appearing:
Accused: William R. Medcof Counsel: Mr. A. Rai
The person in charge of hospital: Counsel: Mr. D. Blumenkrans
Attorney General of Ontario: Counsel: Ms. V. Culp
REASONS FOR DECISION
(Dated January 8, 2026)
Introduction
On November 29, 2002, William Medcof was found not criminally responsible on account of mental disorder (“NCR”) on charges of aggravated assault, break and enter with intent to commit an indictable offence (x2), kidnapping, assault with a weapon (x3), uttering a threat to cause death or bodily harm (x3), assault, criminal harassment (x3), failing to comply with probation, failing to comply with a recognizance (x2), and being in possession of a weapon dangerous to the public, all contrary to the Criminal Code of Canada. He is currently subject to a disposition of the Ontario Review Board (“ORB” or “the Board”) detaining him on a General Forensic Unit at the Centre for Addiction and Mental Health, Toronto (“CAMH” or “the hospital”), with the ability to reside in the community in approved accommodations.
By letter dated November 19, 2025, the hospital advised the Board that on November 11, 2025, Mr. Medcof was transferred from the Psychosis Recovery and Treatment Unit (PRTU6), a non-forensic unit that is the equivalent in security to a general forensic unit, to the Forensic Assessment and Triage Unit (FATU), a secure forensic unit. As of the date of the letter, Mr. Medcof continued to be detained on the FATU. The result was that Mr. Medcof incurred an increase in the restriction of his liberties for a period exceeding seven days.
The Board convened a hearing on November 26, 2025, pursuant to s. 672.8(2.1), to review this restriction of liberty. Mr. Medcof was present and represented by his counsel, Mr. Rai.
All parties agreed that the only issues before the panel were whether the increase in the restriction of Mr. Medcof’s liberty was significant and necessary and appropriate and remained so at the time of the hearing. Mr. Blumenkrans, on behalf of the hospital, submitted that both the initial decision to move Mr. Medcof to FATU, a secure forensic unit, and his continued detention on that unit were necessary and appropriate and represented the least onerous and least restrictive measures available to manage Mr. Medcof’s risk to the safety of the public and continues to be so. Ms. Culp, on behalf of the Ministry of the Attorney General, concurred in the hospital’s positions.
Mr. Rai took no position with respect to the initial decision to transfer Mr. Medcof to FATU. However, in his submission, Mr. Medcof’s continued detention on FATU was no longer warranted and did not represent the least restrictive and least onerous measure to manage Mr. Medcof’s risk of violence.
Findings
- For the reasons that follow, the Board finds that the decision to transfer Mr. Medcof to a secure forensic unit was necessary and appropriate and his continuing detention on that unit as of the date of the hearing also is necessary and appropriate.
The Evidence
- The evidence at the hearing consisted of the letter from CAMH notifying of the restriction (ex. 1), the Restriction of Liberty Report, dated November 24, 2025, (ex. 2), and the viva voce evidence of Dr. O’Sullivan, Mr. Medcof’s previous Most Responsible Physician.
The Index Offences
On May 24, 2001, Mr. Medcof attacked his roommate. The victim sustained a head injury and was taken by ambulance to hospital where he received several stitches.
In the early morning of May 25, 2001, Mr. Medcof unlawfully entered his parents’ residence. He struck his mother with a golf club and forced her into his vehicle. As they drove toward their cottage, he told his mother that she, his father, and his sister were evil and that he intended to kill them. At one point, he pulled over on the side of the road and tied his mother’s hands and feet together. When he arrived at the family cottage, he unlawfully entered and threatened his father with a golf club. He struck his father with his hand in the neck area. His father was able to calm him down. Mr. Medcof’s mother, who had remained in the car, was able to call 911. OPP officers attended the scene. At the time of the events, Mr. Medcof was on a recognizance with conditions that he stay away from his parents’ home and that he not be in the front seat of a motor vehicle.
Background Information
Given the focus of this review, and as the Board’s last disposition is maintained until the next review, there is no need to summarize in detail Mr. Medcof’s personal, criminal, and psychiatric history which are set out in the Hospital Report. The following background is provided for context for these Reasons.
Mr. Medcof is a 58-year-old man who was born in Toronto and adopted at the age of 3 months. His adoptive mother is an Anglican reverend and his adoptive father a retired teacher.
Mr. Medcof reported completing Grade 10 and later took a mechanics course at Centennial College and a course in paralegal and private investigation. The Hospital Report indicates that he had several jobs, none of which was longer than five months. He is currently supported by ODSP.
Mr. Medcof has a history of drug and alcohol abuse. While under the jurisdiction of the Board in 2015 and 2016, he consistently tested positive for cannabis in the weeks leading up to readmission to hospital. In 2017, Mr. Medcof reported suffering from chronic back pain and obtained a license for medical marijuana. He had not been seen by a pain specialist and had not expressed concerns about back pain to his treatment team. He refused to disclose the name of the prescribing physician or allow any contact to coordinate care. Since February 2017, Mr. Medcof has consistently tested positive for cannabis on urine drug screens. He also has been consistently testing positive for cocaine since 2019.
Mr. Medcof’s current diagnoses are Schizophrenia, Substance Use Disorder, Personality Disorder NOS (narcissistic and antisocial traits) and Exhibitionistic Paraphilic Disorder. He is incapable with respect to psychiatric treatment. The Public Guardian and Trustee (PG&T) serves as his Substitute Decision Maker (SDM).
Following the NCR finding in November 2002, Mr. Medcof was detained at Whitby Mental Health Centre (now Ontario Shores Centre for Mental Health Sciences). Mr. Medcof was discharged to reside in the community in 2005 but within 4 months, he was readmitted after testing positive for cannabis. There ensued hospital admissions over a number of years where Mr. Medcof was detained in the hospital. He would present as angry, sarcastic, aggressive, and hostile toward hospital staff.
Despite treatment, Mr. Medcof continued to suffer from symptoms of his major mental illness. He believed that the hospital, police, and courts were unnecessarily detaining him. He adamantly denied that he had a mental illness and was unwilling to form a therapeutic alliance with the clinical team. He refused to engage in the rehabilitation process and refused to participate in substance abuse programming.
Due to the antagonistic nature of the relationship between Mr. Medcof and the treatment team, in May 2008, Mr. Medcof was transferred to CAMH. He was insistent that he did not have a mental disorder and begrudgingly accepted intramuscular medication administered pursuant to the consent of his substitute decision maker. As in the past, he was not agreeable to working with the treatment team in any rehabilitation capacity as he felt he did not have any mental disorder. He continued to believe that the doctors and staff were telling lies.
Mr. Medcof ultimately was discharged to reside in the community. A pattern developed wherein Mr. Medcof would engage in regular problematic cannabis use, the treatment team would raise concerns, Mr. Medcof would exhibit increased paranoia and present with delusional ideation of a grandiose and persecutory nature, at times irritable and angry, and he would be readmitted to hospital. He typically would remain in hospital until his urine tests were negative and he had returned to his baseline, upon which he would be discharged back to his residence in the community.
Mr. Medcof also has had a number of confrontations with his treating psychiatrists. In 2019, he was very animated and angry during an appointment with Dr. Benassi, calling the doctor a liar and throwing a pad at the wall. In 2020, he was angry and aggressive with Dr. Pearce. This was in the context of Mr. Medcof requesting a “medication holiday.” He was then transferred to Dr. Eid. During their first meeting, he told her she was stupid and that she could “step in front of a GO train.”
In July 2021, Mr. Medcof discontinued treatment with antipsychotic medication against the recommendations of his FOPS team. On December 28, 2021, Mr. Medcof was charged with Theft Under for allegedly stealing a hammer and toaster from Canadian Tire. More concerning, on February 1, 2022, he was charged with possession of a weapon dangerous to the public peace, mischief interfere with property and failing to comply with his ORB disposition. It is alleged that during a dispute at a Rexall Store, he threatened to smash all the windows and produced a knife. Upon arrest, Mr. Medcof informed officers that he had left the stove on in his apartment. Housing staff were contacted and subsequently inspected the unit. They discovered that Mr. Medcof had left a large pot on the stove with the burner on high. It was also discovered that Mr. Medcof had dismantled his fire alarm and covered it up with tape. Upon his release on February 3, 2022, he was ordered to attend CAMH for psychiatric assessment as a condition of his bail. He was admitted to CAMH pursuant to the Mental Health Act until the expiry of his Form 4 on March 17, 2022, when he was discharged to live in the community. While in hospital, he was reinitiated on long-acting antipsychotic treatment with substitute consent.
From January 13 to January 19, 2023, he was admitted to hospital pursuant to a Form 1 after he became acutely hostile and intimidating during his initial meeting with his new Forensic Outpatient Service (FOPS) psychiatrist. He was readmitted briefly after he refused to accept his injection medication or cooperate with his outpatient team.
Mr. Medcof was readmitted to hospital from July 13 to July 17, 2024, after he missed his scheduled injection and was physically threatening and intimidating towards his psychiatrist. During the same period, he had engaged in verbal abuse and physical intimidation of his associate case manager after accosting his case manager outside of hospital. He was discharged from hospital as he no longer met the criteria for involuntary admission. On August 6, 2024, Mr. Medcof was detained by police in Peterborough for suspicious activity. Of note, this is close to the family cottage. He was found to be in breach of his ORB disposition (being absent from his residence for more than 24 hours without notifying the hospital). He was taken to the CAMH ED for assessment, and then released, as he did not meet criteria for certification under the Mental Health Act.
In November 2024, the ORB changed Mr. Medcof’s disposition to a detention order. This was preceded by an escalation in his challenging behaviour and risk over several months. This included aggressive behaviour toward his treating team, drug use, poor medication compliance, increased risk of homelessness, and concerning behaviour in the vicinity of his parents’ home area.
In December 2024, Mr. Medcof’s care was transferred to Dr. O’Sullivan. His challenging behaviour and hostile presentation continued with regular positive drug tests.
In June 2025, two separate Form 49s were issued. Mr. Medcof failed to attend the hospital to give urine samples, failed to abstain from substances and refused his long-acting injectable antipsychotic medication. During a review with Dr. O’Sullivan, he became overtly hostile and physically aggressive and intimidating. He was assessed by the EFOPS1 team and not admitted as his presentation was considered at his baseline.
On September 12, 2025, a Form 49 was issued, and he was brought to the hospital based on similar behaviour. He continued to use substances and was hostile towards his treatment team, creating a challenge for the team to manage his risk while in the community. He was subsequently admitted to CAMH.
The following is a summary of his behaviour leading up to this admission as found on page 6 of the Restriction of Liberty Report:
“Over the past 12-18 months there has been a clear and escalating pattern of challenging behaviour and hostility toward his supervising team. In the community, Mr. Medcof’s hostile and oppositional pattern of engaging, volatile presentation and consistent breaches of his disposition have posed increased risks of re-offending and disengagement from the service. This has been underscored by limited insight and a high degree of animosity toward his team, CAMH and the ORB. He resides independently and there have been limitations inherent to this with respect to his supervision. He continues to present as psychotic with limited insight.”
October 3, 2025 - November 11, 2025: PRTU6
Shortly after his admission to hospital, Mr. Medcof was transferred to PRTU6 pending a forensic bed becoming available. While on that unit, he accused his treating psychiatrist of being corrupt and taking bribes from pharmaceutical companies. He maintained staff lied about his history. As on previous occasions, the team found it challenging to build rapport or foster a therapeutic relationship with Mr. Medcof.
Mr. Medcof’s insight remained limited. He continued to assert he did not have a mental illness and described hospitalization as ‘political imprisonment.’ He refused a recommended trial of clozapine. He reiterated his request for a trial off medication.
On October 1, 2025, Mr. Medcof was approved to exercise level 1 passes (escorted on hospital grounds). He regularly visited the Therapeutic Neighborhood and had access to fresh air. These passes were held only briefly on October 28, as he was described as intimidating and threatening.
On November 9, 2025, Mr. Medcof’s behaviour triggered a Code White. In response to a co-patient commenting on Mr. Medcof’s hygiene, Mr. Medcof slapped a juice bottle from the co-patient’s hand and then punched him several times. One hit the co-patient’s head. Staff quickly separated the two men and Mr. Medcof was escorted to seclusion.
In discussing the incident, Mr. Medcof maintained he was provoked by this other patient commenting on his personal hygiene. He stated it was the hospital’s fault for not preventing the incident and that he had no alternative but to assault the co-patient. In the circumstances, he felt his actions were justified.
November 11, 2025 - November 26, 2025: FATU
At the time, Mr. Medcof remained irritable and continued to express justification for his actions. In addition, during his discussions with staff, Mr. Medcof identified two other patients on the unit who were a source of frustration for him. This was a source of further concern. Due to this increased risk to the safety of other patients and staff, on November 11, 2025, Mr. Medcof was transferred from seclusion on PRTU6 to seclusion in FATU, a secure forensic unit. He was successfully trialed out of seclusion within three hours of arriving on the unit, and the seclusion was discontinued.
During his initial review with Dr. Eid, the psychiatrist on FATU, Mr. Medcof reiterated that the incident that triggered the Code White was the hospital’s fault, and he had no alternative course of action. He did acknowledge, however: "I could have handled this better." He stated he hoped for an Absolute Discharge or a Conditional Discharge with "unrestricted travel."(His annual hearing was scheduled for the following day). He acknowledged that he might not get that given the circumstances. He asked Dr. Eid to discharge him that day to help his case at the ORB. He was unhappy that Dr. Eid did not discharge him. The following day, his treatment team determined that it was not safe for him to attend his annual ORB hearing in person due to increased risks to the safety of others. His annual review was therefore adjourned.
Since his transfer to the secure forensic unit, Mr. Medcof has remained guarded, dismissive, and irritable and accusatory of staff. They have described him as often presenting as calm but becoming easily angered. His affect varies between mild irritation to overt hostility. On November 17, 2025, Mr. Medcof left a voicemail on his case manager’s phone. He was angry and the language was considered threatening.
Dr. O’Sullivan testified before the panel. He referred to the escalating trajectory of Mr. Medcof’s behaviour over the past 12-18 months culminating in Mr. Medcof’s admission to hospital. The decision to transfer Mr. Medcof on November 11, 2025, was made because staff did not feel Mr. Medcof could safely exit seclusion and interact safely with other patients and staff on that non-forensic general unit.
Dr. O’Sullivan advised that FATU offers enhanced security in terms of its physical layout and procedures. Further, the staff-to-patient ratio is lower and the staff on that unit have expertise and skill working with patients who require more support and supervision with close monitoring. This secure forensic unit has separate seclusion suites available. Patients have yard access and can avail themselves of fresh air without needing to go on passes on the hospital grounds with the associated risks to abstention, or interactions with the public. In contrast, a general unit includes patients who have access to hospital grounds and the community. As a result, there is a higher risk for substances to be brought onto the unit. In Dr. O’Sullivan’s opinion, FATU is the most appropriate place for Mr. Medcof at this time.
In terms of therapeutic goals, while Mr. Medcof is on this unit, he will benefit from enforced abstinence. This has been an ongoing issue for Mr. Medcof. Over the time preceding his admission, he regularly tested positive for cannabis and less frequently, but still regularly, for cocaine. Abstinence is likely to improve his mental state and reduce his risk to others’ safety.
Dr. O’Sullivan testified that Mr. Medcof currently has a high degree of residual psychotic symptoms. In early October, his medication was increased, and he may have had some benefit from that. There is likely to be potential further benefits in the coming 2-4 weeks. Any steps to further optimize his treatment are best conducted on this unit where there will be close monitoring of his mental status.
His current treating psychiatrist, Dr. Eid, advised Dr. O’Sullivan that Mr. Medcof would benefit from a further period of stability before she would recommend a transfer to a less secure forensic unit. Ensuring abstinence and monitoring, any changes in medication are key factors in that decision. Staff have noted a modest improvement since his enforced abstinence. He has been less volatile in his interactions with staff.
Possible options for Mr. Medcof’s trajectory would be a move to another secure forensic unit that has enhanced programming or a move to a general forensic unit. The decision whether to recommend a transfer and to which unit is reviewed on a weekly basis. Once a patient is put on a transfer list, the wait time is generally a matter of weeks.
In response to questions from Mr. Rai, Dr. O’Sullivan confirmed that the last time Mr. Medcof testified positive for cannabis was in September 2025 and there has been no evidence of him consuming cannabis since that time. Since his move to the secure forensic unit, there have been no incidents of physical violence and no need for further seclusion. However, Dr. O’Sullivan referred to the threatening voice message left on the case manager’s phone and another incident where Mr. Medcof acted in a hostile manner towards staff.
Mr. Medcof remains compliant with his monthly injections of medication. He has participated in unit activities and regularly has availed himself of yard access.
Dr. O’Sullivan indicated that there were multiple factors contributing to Mr. Medcof’s behaviour on November 9, 2025. He was stressed about his upcoming ORB hearing for which he had prepared a speech to read, a co-patient called him a name that he felt was insulting, and a co-patient had commented on his hygiene. The doctor agreed that these factors were more related to Mr. Medcof’s personality profile than psychosis. It was quite a dramatic expression of physical violence, which was triggered by seemingly innocuous comments.
Mr. Medcof opted to read a statement to the panel. He expressed frustration that the hospital was violating his s. 7 rights under the Canadian Charter of Rights and Freedoms by restricting his liberty. He wished to be released on a conditional or absolute discharge. Mr. Medcof wishes to travel to the US to meet up with a woman whom he would like to marry and to pursue a career in comedy. He expressed animosity toward Dr. O’Sullivan and the staff at CAMH. He also repeated some of the comments that were included in the message left on his case manager’s phone that contained violent imagery.
All parties maintained their initial positions.
Analysis and Conclusion
The panel carefully considered the Hospital Report and the evidence of both Dr. O’Sullivan and Mr. Medcof and unanimously concludes that the decision to transfer Mr. Medcof to a secure forensic unit on November 11, 2025, and his continued detention on that unit, were necessary and appropriate and represented the least intrusive and least restrictive measures open to the hospital to manage his risk to other patients’ and staffs’ safety.
Over the last year, Mr. Medcof’s relationship with his various treatment teams has been increasingly oppositional and volatile, necessitating his admission to hospital in September 2025. While on the general forensic unit, Mr. Medcof’s behaviour continued to be challenging.
On November 9, 2025, Mr. Medcof’s attack on a co-patient triggered a Code White. He physically assaulted a co-patient who had commented on his hygiene. During subsequent discussions with the treatment team over the following days, Mr. Medcof identified two other patients who were causing him frustration. Staff were rightly concerned. At that point, it was necessary and appropriate that Mr. Medcof be moved to a more secure forensic unit in order to manage his risk for aggression and ensure the safety of other patients and staff on the unit. Staff could not ensure the safety of the other co-patients should Mr. Medcof be trialed out of seclusion and interact with them.
While on the secure forensic unit, Mr. Medcof has been abstaining from substances and his medication has been adjusted. Some small but notable changes have been observed. It is hoped that there may be further improvements and Dr. Eid plans to make further adjustments to his medication. Mr. Medcof is less volatile and generally less confrontational with staff. However, his affect can change quickly, as demonstrated by his voice mail message to his case manager and a hostile interaction with staff. The panel accepts Dr. O’Sullivan’s opinion that Mr. Medcof is currently well-placed on the secure forensic unit.
The panel also accepts Mr. Rai’s observations that since being on that unit, Mr. Medcof has not engaged in any physical violence and there has been no requirement for restraints or seclusion. The enhanced staff compliment, their expertise in managing patients who require extra support and close supervision, and the ability to limit substances from coming on the unit, are important. Given the possible optimization of Mr. Medcof’s treatment, the increased monitoring is critical. A longer period of stability is needed before consideration can be given to a transfer to a less secure forensic unit.
For these reasons, the panel finds that the significant increase in the restriction of Mr. Medcof’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 the hearing.
DATED this 8^th^ day of January, 2026, at the City of Toronto, in the Toronto Region.
Ms. C. Finley Alternate Chairperson
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Office of the Registrar Ontario Review Board