Re: Timothy Brown
ORB File No: 7971
Hearing held on: January 29, 2026
Place of hearing: St. Joseph’s Healthcare Hamilton, West 5th Campus
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: Timothy Brown Counsel: Mr. A. Rai
The Person in charge of Hospital: Counsel: Ms. L. Barney
Attorney General of Ontario: Counsel: Ms. K. Malkovich
REASONS FOR DISPOSITION
(Dated: March 17, 2026)
Introduction:
On November 12, 2021 Mr. Timothy Brown was found not criminally responsible (NCR) on account of a mental disorder, on a charge of second-degree murder, contrary to the Criminal Code of Canada (“Criminal Code”).
Mr. Brown is subject to a Disposition of the Ontario Review Board (the “Board”) dated January 29, 2025, which orders that he be detained at the Forensic Psychiatry Program of St. Joseph’s Healthcare Hamilton West 5th Campus (“St. Joseph’s”).
On January 29, 2006 the Board convened a hearing pursuant to s. 672.81 of the Criminal Code at St. Joseph’s to conduct the annual review of the current Disposition.
Mr. Brown was represented by his counsel Mr. A. Rai, who advised that his client did not wish to attend the hearing and that he had instructions to proceed in his absence. An order was made pursuant to s. 672.5 (10)(a), allowing Mr. Brown to be absent from the hearing.
A Hospital Report dated January 19, 2026 (the “Hospital Report”) was entered as an Exhibit 1. Dr. K. Shariati testified and adopted the contents of the Hospital Report.
Victim Impact Statements (“VIS”) were entered as Exhibit 2-7 They were read into the record by the authors. The victim’s two adult children, the victim’s niece, the victim’s son-in-law, and Michael Brown’s former wife recounted the hurt, depression, anguish and deep loss they continue to experience as a result of the senseless, callous, brutal death of an elderly victim in his own home.
The statements address the writers’ uncertainty and fears for their present safety, although Mr. Brown remains in detention, and thereafter, should he return to the community. In addition to the emotional toll that continues with no end, they collectively expressed one sentiment: Mr. Brown will never be forgiven for the unfathomable pain and loss they endure because of his senseless murder of their loved one.
The issue at this hearing is whether Mr. Brown is a significant threat to public safety, as defined in s. 72.540 of the Criminal Code. If so, the necessary and appropriate Disposition in the circumstances must be determined, bearing in mind the factors in s. 672.54 of the Criminal Code.
Position of the Parties:
Counsel for the Hospital, counsel for the Attorney General, and counsel for Mr. Brown agreed that Mr. Brown continues to represent a significant threat to the safety of the community.
Counsel for the Hospital submitted that a continuation of the present Detention Order with amended terms, including a term providing community living, is the appropriate Disposition. Counsel for Mr. Brown agreed with the Hospital’s position.
Counsel for the Attorney General submitted that Mr. Brown remains a significant threat to the safety of the public, and that the appropriate Disposition is a continuation of the terms and conditions in the present Detention Order with no amendments.
For the reasons set out below based on the evidence and opinions before it, the Board concluded that Mr. Brown continues to represent a significant threat to the safety of the public. The Board ordered that the necessary and appropriate Disposition in the present circumstances is the continuation of the existing Detention Order, with amendments to be detailed below.
Current Psychiatric Diagnosis:
- Psychotic Disorder due to another Medical Condition (Postictal Psychosis secondary to Temporal Lobe Epilepsy), in remission.
Other specified Personality Disorder, mixed personality features and prominent paranoid and borderline traits.
Index Offence:
- The circumstances giving rise to the Index Offence are summarized from last year’s Reasons for Disposition:
The victim [GH] and [DB] lived together. Tim Brown, [DB’s] adult son, lived with them in their home.
Mr. Brown had no previous history of physical violence.
On March 14, 2021 [GH] and Mr. Brown got into an argument when [GH] asked Mr. Brown to help him locate a disabled antique firearm believed to be in a closet of the home.
Mr. Brown became inexplicably enraged and started to punch [GH] about the head with repeated blows. He then used a glass object to strike [GH] on the side of the head.
[GH] was seriously injured and was transported to hospital. The police were called and attended the scene. Mr. Brown was arrested and charged with aggravated assault. [GH] later died from his injuries. Tim Brown was subsequently charged with second-degree murder.
Background Information Regarding the Accused:
Mr. Brown is 59 years old. He left high school in grade 10, and later obtained a welder’s certificate. He was gainfully employed in the steel industry for approximately 20 years prior to his arrest on the Index Offence in 2021. Mr. Brown married in 1994, and divorced in 2023. He has two sons, aged 31 and 28, from whom he is estranged. He has no criminal record. Mr. Brown is supported by WSIB benefits because of a workplace injury.
He has the support of his mother and sister who communicate and visit with him regularly.
Historical Psychiatric Profile:
Mr. Brown has history of regular substance use, including alcohol, cannabis, cocaine and occasional use of LSD and psilocybin.
He has a psychiatric history dating from 1993. He was admitted to hospital and received treatment, and outpatient follow-up. His family members, including his former wife, Leah Brown, and his two sons, described Mr. Brown as an individual who had been virtually angry all his life. It is reported that Mr. Brown has a deeply entrenched anger management problem, which started as early as kindergarten.
Mr. Brown’s sons related that their father was always mad about something. He would yell and became intimidating. His sons were careful as to what they said to avoid upsetting their father. Both sons slept with knives under their beds, fearful that Mr. Brown would kill their mother.
Medical in-patient and out-patient records confirmed the family reported episodes of Mr. Brown’s uncontrolled anger. Mr. Brown’s seizure disorder was not diagnosed until after the index offence.
Mr. Brown’s mother reported that in 2020 Mr. Brown called and advised her that he found himself on the ground with a lump on his head. A month later she and her daughter were visiting Mr. Brown at his home. While standing in the kitchen Mr. Brown fell to the floor and lost consciousness. A minute later he regained consciousness and was confused.
Around that time, Tim Brown phoned his wife in a distraught state advising her that strange things were happening to him, such as waking up covered in blood with no memory of what had occurred. He told her he was afraid he was losing his mind, and there was something wrong with his brain. He told her he would stop using cannabis because it led to memory loss.
Later in 2020 Mr. Brown sold his home and moved in with his mother and stepfather (GH, the victim of the homicide). While there, Mr. Brown’s mother noticed Mr. Brown was unresponsive during conversations, becoming silent or going blank. She thought he was exhibiting signs of amnesia. His mother became concerned about Mr. Brown’s medical wellbeing. She took steps to ensure that Mr. Brown was not alone in the event of a medical emergency.
Leah Brown reported that shortly before she and Mr. Brown separated in 2021, she brought Mr. Brown to see her family doctor due to her concerns about his depression and anger, which included an episode when Mr. Brown smashed his head through a wall in the family home. Mr. Brown was prescribed antidepressant and anti-anxiety medication. He was referred to a psychiatrist and admitted to hospital. According to Mr. Brown, the hospital stay was pointless, and he left with no diagnosis or treatment plan proposed.
The following is summarized from the Reasons for Disposition dated February 18, 2025:
In December 2024 Mr. Brown was transferred to another unit at St. Joseph’s because the staff needed a respite from his demanding, caustic and threatening behaviour.
Mr. Brown exhibited irritability and anger management issues on an ongoing basis. He easily lost his temper and became confrontational. He had trouble controlling his emotions when he perceived he was being treated unfairly. In two notable incidents involving confrontations with staff, Mr. Brown threatened to burn staff and their families, and threatened to put his fist through a staff member’s throat. Despite his threats, neither staff nor any family member were assaulted by Mr. Brown.
Mr. Brown exhibited limited insight that his behaviour was a major obstacle to his rehabilitation. He tended to downplay his behaviour, rationalizing that he was frustrated about his ongoing detention, and frustrated about the lack of appropriate mental health care he received prior to the Index Offence. He struggled to regulate his emotions and was unable to catch himself before he reacted. After the fact, Mr. Brown often apologized, recognizing his threats and behaviours were inappropriate.
The Hospital Report noted that Mr. Brown’s characterological issues were longstanding, and it would take a significant amount of time to deal with his personality disorder. Mr. Brown would continue to need long-term intervention to handle his anger management issues and emotional dysregulation.
Further, Mr. Brown had limited insight into the danger of returning to substance use. He did not fully appreciate how a return to substance use would not only affect his risk of seizures, but would also cause him to engage in disinhibiting and destabilizing behaviour that would put public safety at risk.
On the other hand, Mr. Brown was willing to engage in therapies recommended by the treatment team. He understood the necessity of adhering to his medication regimen, as prescribed by his neurologist.
In summary, Mr. Brown’s presentation was mixed, with some progress but with continuing challenges over the past reporting year (February 2024-February 2025). The most notable change was that there has been no recurrence of any seizure activity since the summer of 2023.
Evidence at the Hearing:
General Overview:
The Hospital Report covers a period from December 16, 2024 to January 2026.
Dr. Shariati testified that for the majority of the year Mr. Brown’s presentation has remained relatively stable with minimal psychotic symptoms presented, no major safety concerns raised, and no behavioural incidents requiring seclusion or restraint. Mr. Brown continues to demonstrate underlying irritability directed at the hospital, the forensic psychiatric system and staff members. His irritability is typically situational and verbal in nature, absent physical aggression. For the most part, the incidents are brief, and Mr. Brown is generally receptive to redirection and support once provided reassurance.
At pg. 73 the Hospital Report notes that, “Mr. Brown exhibits limited insight into his mental illness and continues to maintain he does not require hospitalization.” Dr. Shariati explained the context of that statement. He testified the statement is not conclusionary, but a product of Mr. Brown’s frustration with the hospital, the forensics system, and finding himself embedded in that system. It is a statement momentarily made, reflective of his personality disorder when frustrated. However, Mr. Brown’s mood is generally stable, his affect congruent, though he becomes easily irritable when his requests or expectations are not met.
Mr. Brown continues to reflect on the index offence and the events leading to it. The index offence and its consequences continue to weigh heavily on him. He has expressed remorse and grief for both the victim’s family and his family. He has expressed remorse for the loss of his stepfather. Mr. Brown is diligent in taking anticonvulsant medication and attending appointments. His greatest fear is a recurrence of the index offence. Mr. Brown has remained sober since being involved with the Forensic team.
Additionally, at page 40, the Hospital Report observes:
There is also a notable trauma component shaping Mr. Brown’s emotional reactivity: He continues to struggle with pervasive guilt, shame, and self-blame about the index offence. These feelings become more pronounced when he perceives scrutiny or misinterpretation. Given his history of seeking services multiple times prior to the offence, a systems-blame lens has become deeply embedded in his narrative. Irritability and verbal frustration are more accurately understood as trauma-related defensiveness and mistrust rather than an indication of dangerousness.
No issues arose when Mr. Brown, indirectly supervised by mother and sister, used passes on hospital grounds and in the community. He has been in the community with Social Work and has been engaging, polite to members of the public, and able to handle stress and commotion that may arise in the public sphere. Dr. Shariati testified that at this point Mr. Brown has achieved the ceiling of his privileges. Mr. Brown is encouraged to use his community passes more extensively to minimize and counteract the frustration he experiences while in the present hospital environment.
Mr. Brown is primarily supported by his mother and his sister. They visit him a few times a month to accompany him into the community. They have almost daily phone contact with him. They have a good understanding of Mr. Brown’s current situation and will contact Social Work with any questions or concerns. They will seek support when needed.
In summary, the Hospital Report finds that Mr. Brown has taken progressive steps this reporting year, including compliance with anticonvulsant medications, successful use of hospital grounds and community passes, and has been attending recommended groups and individual therapy to promote his recovery. Despite the positive steps, Mr. Brown continues to have great difficulty using coping and stress management skills when feeling distressed. Social Work will continue assistance in providing Mr. Brown with the necessary tools to address that issue.
Recent Seizure Episodes:
The Hospital Report notes that Mr. Brown’s psychotic symptoms are secondary to his medical seizure disorder, which was first identified after the commission of the index offence. It is the seizure disorder, then unknown and untreated, and Mr. Brown’s history of psychiatric instability, that led to the violent beating and subsequent death of the victim. Throughout ORB detention Mr. Brown’s presentation was carefully monitored. In the 2025 Reasons for Disposition at page 8, the following is chronicled: “Mr. Brown’s presentation has been relatively stable over the past recording year. The most notable change was that there has been no recurrence of any seizure activity since the summer of 2023.”
Dr. Shariati testified that between July and October 2025, Mr. Brown may have experienced one to three mild seizures. The seizures were not witnessed nor confirmed with follow-up medical investigation.
One seizure was believed to have occurred because staff observed some blood on a pillow in Mr. Brown’s room. The blood was postulated to be the result of Mr. Brown biting his tongue during a seizure.
A second seizure was referenced at page 74 of the Hospital Report. While discussing the index offence Mr. Brown appeared tearful and remorseful. He exhibited a short period of confusion, and disorientation features commonly experienced by patients post seizure (the post ictal phase). Following the incident Mr. Brown quickly stabilized and returned to his baseline functioning.
Dr. Shariati testified that the severity of the suspected seizures is unknown. He described the seizures to be distinctive, very minor and brief. However, if any seizures did occur, Mr. Brown did not exhibit any psychotic symptoms. The Hospital Report at pg. 85 similarly states the same with additional commentary:
Despite increased seizure activity over the summer, he [Mr. Brown] did not experience a psychotic relapse nor a resurgence of physical aggression. His insight into the relevance of temporal lobe epilepsy and the link to psychosis, and subsequent violence risk, is adequate. He shared that his greatest concern would be a recurrence of psychosis.
Dr. Shariati agreed that it was likely that Mr. Brown suffered additional subclinical seizures, not detected or clinically apparent, may have occurred. Their number and severity were not further explored.
Mr. Brown has no memory or knowledge of the seizures. During a Risk Assessment interview Mr. Brown expressed concern over the reported seizures describing them as triggering a familiar, unsettling feeling. He indicated he does not remember the seizures, but believes they occurred based on staff reports. He recalled feeling anxiety and guilt, thinking, “I did something. I hurt someone.” He denied any recurrence of psychosis.
Analysis and Conclusions:
Mr. Brown has been diagnosed with Psychotic Disorder due to Another Medical Condition in remission, postictal psychosis from temporal-lobe epilepsy, and longstanding personality traits with paranoid and borderline personality features.
Having heard and considered the entirety of the evidence, as well as the submissions of all parties, the panel unanimously agrees with the joint submission that Mr. Brown remains a significant threat to the safety of the public.
The panel further finds on all the evidence, that the necessary and appropriate Disposition in the circumstances is a continuation of the present Detention Order with the inclusion of community living.
Applicable Law:
- Simonic (Re), 2024 ONCA 573, 2024ONCA 573 holds that if the evidence establishes that including community living term in a disposition will either:
(a) serve as a therapeutic purpose or motivate an accused’s progress and/or;
(b) have a practical benefit, such as placement on housing waitlists, then the necessary and appropriate disposition may include community living. What motivates an accused is a matter of “clinical expertise” and must be supported by the evidence. (Simonic).
Mr. Simonic was found NCR in 2022 of sexual assault, forceable confinement, and breach of probation. Following his initial ORB hearing, he was ordered detained on a secure forensic unit with privileges including entering the community indirectly supervised.
At Simonic’s 2023 annual review, CAMH recommended, amongst other changes, the added privilege of living in the community. Simonic sought a conditional discharge with a term requiring he live with his parents.
The Board found that Simonic remained a significant threat to the safety of the public and a conditional discharge would not be sufficient to manage his risk. While in secure detention Simonic committed 49 breaches, including 22 incidents in respect of which he required seclusion, one abscondment, and one incident in which he fractured a bone in his hand from punching another patient. He also refused to take his medication on 13 occasions.
The Board rejected CAMH’s recommendation that the detention order be amended to include community living, and imposed the same terms and conditions as the existing detention order. Its reason for doing so was that there was no realistic prospect of Simonic qualifying for community living in the coming year, and it did not accept that a community living clause would have any therapeutic benefit.
Simonic appealed to the Court of Appeal and requested that community living term be added to his detention order. The Court concluded that the Board erred in failing to find that the addition of a community living term to the existing disposition was the least onerous and restrictive disposition. The Court held that even without any reasonable prospect of qualifying for community living in the coming year, a community living term can be included in his disposition to provide an incentive to improve behaviour and motivate the accused. Further, a community living clause in a disposition may also facilitate the accused’s placement on housing waitlists and reduce the duration of their stay in hospital when they are ready for discharge.
At para. 15 the Court commented on possible waitlist prejudice:
Given that at least some providers of community living will not place a patient on a waitlist until they are granted community living privileges, the denial of a community living clause could mean that a patient would face the prospect of remaining in an inappropriately restrictive environment for an excessive length of time while waiting for the disposition to be revisited at the next annual review. This court explained that refusal to provide a community living clause in such circumstances - where the treatment accepts it would be therapeutically beneficial and practically necessary - would be “to subject the appellant to more severe restraint than is warranted by his condition”. Kelly (Re), 2014 ONCA 269 at para 11.
Assessment and Findings:
Dr Shariati testified that under the current Disposition Order Mr. Brown is at the ceiling of his privileges. He testified that he has encouraged Mr. Brown to use his privileges to their fullest extent, such as increasing the supervised visits in the community. He testified Mr. Brown remained frustrated.
Mr. Brown will not qualify for community living in the coming year, as all parties agree that Mr. Brown continues to pose a risk to the safety of the public, and a continuing Detention Order is necessary. The panel agrees.
Crown counsel submits that a community living clause will have no therapeutic benefit and would be unlikely to provide an incentive and motivate Mr. Brown to improve his behaviour, given his deeply entrenched and intractable psychological profile of challenge, confrontation and lack of insight into the gravity of his mental illness.
The panel finds despite some setbacks in this year’s reporting period, Mr. Brown’s attitude, deportment and conduct although difficult, caustic and challenging has significantly improved. This is borne out in part in Mr. Brown’s recent Risk Assessment set at pages 83-85 in the Hospital Report, and in the evidence provided by Dr. Shariati:
Mr. Brown has achieved some progress since his last comprehensive risk assessment (2020) on a number of clinical risk factors. Although he experienced two seizure episodes in late summer 2025, followed by a period of confusion and memory loss, he did not experience a resurgence of psychotic symptoms or violent behaviour. His insight into the relevance of temporal lobe epilepsy and the link to psychosis, and subsequent violence risk, is adequate. He shared that his greatest concern would be a recurrence of psychosis….
A number of incidents have been recorded where Mr. Brown lashes out verbally at staff. However, when asked to debrief about the same, he denies any intent to harm others, and often expresses regret. Mr. Brown has not gone further than verbal sparring matches with staff…
…Mr. Brown attends appointments punctually and has accessed the Hamilton community numerous times in the past year without issue (i.e. returns on time, does not seek out conflict, can way find, prioritizes time with his sister and mother). Further, he has made progress in terms of coping - he has been able to walk away from difficult conversations, ask for time, and has returned to his room to recompose and try again. He has been targeted by co-patients who have been acutely unwell and has consistently approached staff to let them know without acting out. [to be reviewed below]
There have been no concerns in the past year regarding symptoms of major mental disorder…
Regarding future risk factors, Mr. Brown remains medication adherent and is largely compliant with care…Insight into mental health and related violence risk is adequate and is expected to remain stable. There is no indication that Mr. Brown, absent psychosis, would be intent on or experience urges to physically hurt others. …Mr. Brown’s anticonvulsant medication was increased after the seizure activity this summer and that he is followed regularly by Neurology. As such, there is little concern with seizure activity leading to a psychotic episode in the coming year.
Considering his clinical presentation and all factors identified…Mr. Brown’s risk for physical violence falls on the low-to-moderate range with the protection afforded by a Detention Order disposition….
.. many of Mr. Brown’s risk factors remain active because of frequent episodes of irritability and disgruntlement and his verbally reactive comments towards staff. These behaviours appear consistent with his longstanding temperament and are unlikely to result in escalation of acute risk for physical aggression.
When questioning Dr Shariati, Crown counsel directed him to pg. 75 of the Hospital Report which reported an incident in July 2025, where Mr. Brown engaged in a verbal altercation with a co-patient, later punching a hole in the wall and implying further violence, stated, “Next time I’ll go for the real thing”. Crown counsel suggested that Mr. Brown, in addition to historically expressing frustration and annoyance with staff, also had conflicts with co-patients during which he not only verbally threatens, but also expresses his anger with violence.
Dr. Shariati responded by providing some historical context to the incident. He testified the other party, his patient, was psychiatrically unwell, psychotic and paranoid. Dr. Shariati was aware the patient had been targeting Mr. Brown for weeks. He agree it was concerning that Mr. Brown punched a hole in the wall, but the other patient was the instigator and very much the problem. He testified that although Mr. Brown has a low tolerance level, he showed a lot of restraint.
The panel finds, that given Mr. Brown’s progress and the insight he has gained in the last year, adding a community living term to the present Disposition Order, as held in Simonic, will serve a therapeutic purpose or motivator for Mr. Brown’s [continuing] progress moving forward.
There is no dispute that the waiting lists for community living are lengthy and in high demand. The reality is that until a community living term is included in a Disposition Order, Mr. Brown cannot be put on a waiting list for future placement in the community and would be “subject…to more severe restraint than is warranted by his condition”. The panel thus finds the addition of a community living term not only serves as extra motivation for Mr. Brown to continue his progress, but also ensures that with a community living term, he experiences no prejudice by being “subject to more severe restraint than is warranted by his condition.” Kelly (Re), 2014 ONCA 269 at para 11.
The panel’s unanimous findings were made with caution and careful consideration. That exercise included the views of two members who voiced uncertainty about some of the evidence. Those views are set out below:
“The clinical dimensions and legal dimensions of a given case can be dyssynchronous. This can occur when there are gaps and/or conflictual elements in the evidence. Mr. Brown’s case is one such instance. Two panel members had greater concerns in respect of some uncertainty about the containment of Mr. Brown’s seizure disorder, and about how his behaviour might impact supervisory staff at any 24/7 supervised facility he could come to reside in once community living was actualized.
Although we conclude, on the evidence, that including a community living in 24/7 supervised accommodation provision is the required legal outcome, the decision was not made lightly, arrived at with some divergence of perspectives, and accompanied by some pause.
We learned through questioning of Dr. Shariati that Mr. Brown’s surliness, vitriol, and proneness to impulsive verbal aggression, which has hitherto been directly mostly at staff, could transfer toward supervisory staff in any home he resides in at some later point, when he is living in the community. Mr. Brown’s anger towards the health care system at large for failing to diagnose his seizure disorder earlier, which, if that happened, would have prevented him from committing the index offence (his perspective), is a function of his proneness to project blame onto others. We hope that staff supervising him in whatever residence he is housed, when that eventuality is appropriate, are as resilient as hospital staff have needed to be tolerating his outbursts to date.
His clinical – neurological - course over the last year is also a concern. The panel heard that after an 18-month abatement of seizure activity, Mr. Brown has had up to three seizures this year while fully medicated against them. None were witnessed. One was inferred from blood on his pillow in the morning, suggesting that he bit his tongue. Two potential other seizures (Sept. 15th and Oct. 12th, 2025) were inferred from the suggestion of a confusional state. None were associated with psychosis or untoward behaviour.
If Mr. Brown had up to three seizures, they occurred within a fairly narrow timeframe…over September and October of 2025, and they are unexplained. One seizure - which Dr. Shariati conveyed had the greatest evidence in support of it being a seizure (the biting of the tongue and blood on the pillow) - stemmed from a nocturnal seizure, which Mr. Brown hadn’t seemingly had in the past. Dr. Shariati agreed that Mr. Brown may have also suffered some subclinical seizure activity no one is aware of. Given that his greatest risk for violence stems from his seizure disorder, the mysterious occurrence of these seizures is unsettling.
As regards clinical concerns that have generated some doubt for a minority of panelists regarding Mr. Brown’s readiness for community living, we recognize and accept that these concerns should not bar Mr. Brown from the next logical step in risk management, namely preparing him for community living. We understand that this process can take a long time, but that nothing happens unless the privilege is granted so that Mr. Brown’s name can be added to an already lengthy waiting list. We also recognize that the hospital will pay scrupulous attention to Mr. Brown’s clinical course and mental state before allowing a move into the community.
We have confidence that in the interim, the hospital will continue to diligently manage Mr. Brown’s risk factors, and as we heard from Dr. Shariati through questioning by the panel, this would include applying a sharper lens to mapping the dimensions of Mr. Brown’s seizure disorder. Dr. Shariati agreed that it could be beneficial to approach his neurological colleagues to as whether EEG telemetry is available and an appropriate resource to investigate the scope of Mr. Brown’s seizure disorder, and we support that step being taken.”
Conclusion:
For the aforementioned reasons the panel finds that the necessary and appropriate Disposition, which is also the least onerous, is a continuation of the current Disposition Order, with a term granting community living.
The following additions to the current Disposition are further ordered:
To enter the community [of with] within the catchment area of St. Joseph’s Healthcare Hamilton, West 5th Campus, indirectly supervised;
Passes for up to 7 days, to enter the community within the catchment area of St. Joseph’s Healthcare Hamilton, West 5th Campus, for the purpose of discharge planning, indirectly supervised;
To live in the community within [the community within] the catchment area of St. Joseph’s Healthcare Hamilton, West 5th Campus, in supervised accommodation approved by the person in charge;
While living in the community report to the person in charge of St. Joseph’s Healthcare Hamilton, West 5th Campus, or his or her designate, not less than once per week.
DATED this 17th day of March 2026, at the City of Toronto, in the Toronto Region.
Alexander Sosna Legal Member
Office of the Registrar Ontario Review Board