Re: Vo Quang Thai, 2026 CanLII 23887

Re: Vo Quang Thai

ORB File No: 3341

Hearing held on: Monday, January 5, 2026

Place of hearing: Centre for Addiction and Mental Health

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

Before:

Alternate Chairperson: Dr. K. Connidis

Members: Hon. N. Kozloff Dr. K. Hand Dr. G. Kerry Mr. S. Duffy

Parties Appearing:

Accused: Vo Quang Thai Counsel: Ms. S. Feldman

The person in charge of hospital: Counsel: Mr. D. Blumenkrans

Attorney General of Ontario: Counsel: Mr. M. Feindel

REASONS FOR DISPOSITION

(Dated March 19, 2026)

Introduction

[1]. On April 4, 2001, Vo Quang Thai was found not criminally responsible on account of mental disorder (hereinafter also “NCR”) on two charges of assault, and one charge of failure to appear. Since the finding of NCR and the initial disposition, Mr. Thai has remained subject to Dispositions of the Ontario Review Board, most recently a Disposition dated January 8, 2025, detaining him on a general forensic unit at the Centre for Addiction and Mental Health (“CAMH” or “the Hospital”), with privileges extending to living in the community in supervised accommodation approved by the person in charge.

[2]. On January 5, 2026, a panel of the Review Board convened at CAMH to hold a hearing to review that Disposition. Mr. Thai initially appeared by Zoom from his residence and was assisted by a Vietnamese interpreter. Partway through the hearing, and as has been the case at prior hearings, Mr. Thai apparently decided that he no longer wished to attend and left the meeting. His counsel, Ms. Feldman, had instructions to continue in his absence, and Mr. Thai was permitted to be absent pursuant to section 672.5(10) (a) of the Criminal Code.

[3]. The issues to be decided at this hearing were whether Mr. Thai continues to pose a significant threat to the safety of the public and, if so, what is the necessary and appropriate disposition, considering the four factors in s. 672.54 of the Criminal Code.

[4]. There was no argument on the issue of significant threat. The position of the Hospital and the Crown at the outset of the hearing was that the necessary and appropriate Disposition is a continuation of the current Detention Disposition. On behalf of the accused, Ms. Feldman indicated that it was a joint submission albeit Mr. Thai “wishes to return to the hospital.”

[5]. Having heard and considered all of the evidence and the submissions of counsel, we find that the threshold test for significant threat continues to be met, and that the current Detention Disposition - with some tweaking of conditions 2(d) and 2(e) - remains necessary and appropriate in the circumstances. These are our reasons.

Background, Index Offences and Clinical Course

[6]. The following background information concerning Mr. Thai is reproduced from last year’s Reasons for Disposition with appropriate updates:

"Mr. Thai is 63 years of age, having been born in May 1962 in Vietnam, the third in a sibline of 10 children. He left Vietnam in early 1982 and reportedly spent several months in a refugee camp in Thailand before immigrating to Canada. Two of his brothers were already living in Canada at that time. For the past several years, however, Mr. Thai has not been in contact with any family members.

After immigrating to Canada, Mr. Thai worked in a variety of unskilled positions. His last confirmed period of employment was in 1994, and he has been receiving ODSP for many years.

Mr. Thai’s current diagnoses include schizophrenia and neurocognitive disorder of unknown cause. It appears that his symptom onset was in his late teens or early 20s. He has a lengthy psychiatric history in Canada beginning in 1982, shortly after his arrival in Canada, and including contacts with and admissions to several psychiatric facilities in the Toronto area, often as a result of his aggressive and/or bizarre behaviour in the community. He was consistently diagnosed with chronic schizophrenia and treated with a variety of antipsychotic medications with only marginal effect. He was followed for years by the Hong Fook Mental Health Services, albeit on a sporadic basis until his arrest on the index offences. Psychiatric treatment was offered to Mr. Thai through Hong Fook but he was only variably compliant. His psychiatric follow-up was interrupted by protracted periods when Mr. Thai was not in contact with his care providers, largely as a consequence of him being under arrest or detention or in hospital.

Prior to the index offences, Mr. Thai had a criminal record commencing in 1982 and including convictions for aggravated assault (for which he received a sentence of two years less a day incarceration), assault with a weapon (arising out of an incident in which he stabbed a woman in the head with a screwdriver), criminal harassment and assault causing bodily harm. The circumstances of the index offences (which occurred in January 1999) involved Mr. Thai assaulting a 78-year-old man who was previously unknown to

him, and assaulting a second victim (also unknown to him) after that individual tried to intervene in his assault on the first victim.

Mr. Thai remained an inpatient at CAMH from January 1999 (when he was arrested in relation to the index offences) to March 2008, when he was discharged to live in a local boarding home. He lived at the home until August 2009 when he was readmitted to hospital after he failed to attend for follow up with his treatment team and to attend for medication. Although he was never charged, there was an allegation that shortly before his readmission Mr. Thai assaulted his roommate.

After many years as an inpatient, and following a period of relative stability, Mr. Thai’s off-ward passes were gradually increased to allow him greater liberty in the community. In September 2015, he began using extended community passes. Initially these passes occurred without incident, but in April, June and September 2016, he went AWOL after signing out on a pass. The treatment team believed that the AWOLs were the result of Mr. Thai’s level of disorganization and his cognitive deficits and a decision was made to proceed with discharge planning. At the time, Mr. Thai had available to him a 24-hour supportive and culturally appropriate placement that the team knew would be difficult to find in the future.

At the end of September 2016, on his second night in his new residence, Mr. Thai went AWOL. He remained at large for three days, then returned to the hospital on his own. While AWOL, he missed three doses of clozapine. In the months that followed, he evidenced a significant decline in his mental health and his functioning. His level of disorganization intensified and his hygiene worsened. He became more irritable and was involved in more conflicts with co-patients.

By mid-March 2017, Mr. Thai's mental state began to improve. He presented as more pleasant and cooperative with staff and he resumed some of the activities that he had previously enjoyed. However, his level of cognitive functioning did not return to his previous baseline and he was viewed as an AWOL risk due to his level of profound disorganization. Though he was permitted accompanied passes, Mr. Thai was deemed unsuitable for indirectly supervised privileges due to his risk of wandering, resulting in elopement, medication non-compliance, and deterioration in his mental state.

For several years after Mr. Thai’s readmission in 2016, his treatment team worked with a CAMH Long Term Care (LTC) Coordinator to find a suitable home for Mr. Thai. Eventually, in October 2021, Mr. Thai was discharged to Mon Sheong, a long-term care home that provides culturally specific programming and support. His treatment team viewed Mon Sheong as an ideal placement for Mr. Thai — it offered him greater access to cultural food and activities, as well as more residents and staff that could speak to him in Vietnamese and Cantonese, and Mr. Thai would reside on a secure 24-hour supervised unit which would help ameliorate his risk of absconding due to his disorganization.

In December 2021, Mr. Thai required readmission to hospital. He had refused his clozapine several times and was more irritable and disorganized, likely secondary to medication non-adherence. He was also experiencing painful dental issues but refused examination. The treatment team decided that these issues were more easily managed in an inpatient setting, and Mr. Thai was returned to CAMH. In hospital his dental issues were addressed and he was compliant with clozapine in liquid form. In late June 2022, he was discharged back to a secure unit at Mon Sheong. As described in the hospital report, he has continued to live in the same residence since that time, “with reasonable stability and within the scope of the LTC staff to cope, with FOPS support.”

Current Clinical Year

[7]. At the current hearing we received evidence in the form of a Hospital Report dated December 15, 2025 (Exhibit 1 in these proceedings), as well as the oral testimony of Dr. Simpson, Mr. Thai’s treating psychiatrist on the FOPS team. The following is excerpted from that hospital report:

"CAMH FOPS December 2024-November 2025

Mr. Thai continued to reside at nursing home locked unit of Mon Sheong Care home in Stouffville. This facility has a locked door, 24/7 support and culturally appropriate care. His usual level of nursing support is enhanced by the behavioural support team of Mon Sheong and case management and behavioural support from the FOPS team.

His treatment team saw Mr. Thai at least once a week at the nursing home. However, for the majority of the reporting year, he was seen twice a week due to his refusal of personal hygiene and behavioral concerns. He did not require hospital readmission.

Physical Health Needs:

Mr. Thai’s insight into his physical health needs remained limited and did not change during the reporting year. Mr. Thai’s medication compliance fluctuated throughout the reporting year. There were many incidents where he would refuse his physical health medication despite increased encouragement and several attempts by the nursing staff at Mon Sheong. He continued to require the use of the token economy to increase compliance with his clozapine bloodwork and physical health supports. He received both his flu and Covid vaccine in Oct 2025.

An important aspect to note was that Mr. Thai had several urinary tract infections throughout the reporting year. He never reported any signs of symptoms of UTI to the team. As previously noted, UTIs were associated with decline in behavioural adjustment.

Checking for a UTI was always performed if his behaviour deteriorated. Frequently a UTI was found and his behaviour improved with treatment of it. He was put on a cranberry pill supplement to help with lowering the risk of UTI.

Mental Health Needs:

Mr. Thai’s mental status fluctuated throughout the reporting year. At times, he was calm and cooperative. There were frequent incidents where he was verbally aggressive, threatening, and irritable. Some of these incidents were associated with a UTI. His speech was often mumbled which made it difficult to understand in either English or Mandarin. His thought process was illogical and incoherent. Mr. Thai intermittently talked about being “yelled at” by a man, however, there were no recorded of such incidents at the nursing home. This was likely Mr. Thai reporting auditory hallucinations. Mr. Thai often could not tolerate long conversation which made it difficult to gain details into these incidents. He reported mood as “ok” and affect was constricted. He had limited insight into his mental illness. He required close supervision of his medication compliance due to history of non-compliance.

There was a change in his clozapine dose from 550mg to 525mg in February 2025 due to elevated clozapine blood level of 4860 nmol. However, this minor decrease was followed by an increase in agitated behaviour so the dose increased back to 550mg in March 2025.

Self care and ADLs:

Mr. Thai required a lot of encouragement to maintain his ADLs and hygiene. His room continued to have uneaten food hidden in the cupboards, dirty dishes and many cups that he hoarded and collected from around the unit. His ADL schedule was Mondays for freshen up and Thursdays for shower. Due to the use of the token economy, Mr. Thai’s compliance in this aspect has been good. He has been more compliant with having staff go into his room to mop the floor and clean the bathroom though this could be a source of tension and challenging behaviour if not well managed.

Social and Family Support:

Mr. Thai did not receive any support from his family or friends. He does not have any contact with his family members or friends that he used to know. All of his supports are from Mon Sheong (nursing home) and his treatment team at CAMH. He does talk occasionally about wanting to return to CAMH as he has friends here.

Incidents and Challenging Behaviour:

In the past reporting year, Mr. Thai continued to exhibit concerning behaviours. On a weekly basis, Mr. Thai exhibited verbal aggression as well as threatening behaviour towards staff when his needs were not met immediately. Mr. Thai’s verbal and physical threatening behaviour included yelling at staff, showing fists in a punching motion, pushed care cart towards staff and charging at staff. These behaviours happened during ADL assists, when staff had to ask Mr. Thai to not take items from others, or when Mr. Thai was caught entering the nursing station.

There was one code white incident due to physical aggression towards a PSW where he grabbed the PSW’s arm and would not let go.

There was an incident where Mr. Thai threw a tape container towards nursing staff when he was caught taking it from the nursing station.

The frequency of such incidents has increased, occurring about once every one to two weeks across the reporting year. Whilst physical issues contribute to this, so also do staff changes, alteration to his care plan and to his token economy program.

The token economy has a set of conditions where he would receive money for each of the tasks he completes such as showering, changing of clothes, returning cups and trays to the nurses, obtaining bloodwork and vital signs. He then can use the money that he earned towards purchases at the store, which had items that Mr. Thai prefers. This token economy had been very successful in managing Mr. Thai’s behaviour around refusal of hygiene care as well as some significance in managing his physical health.

MENTAL STATUS EXAMINATION (November 2025):

Mr. Thai generally presents as a thin man of Vietnamese descent. He is casually dressed and mildly dishevelled, and with frequent prompting, his basic hygiene was adequate. On a home visit his room was tidy but with some food items present (his room had been tidy the day before the visit). He keeps his curtains shut. He is generally cooperative with brief assessments, though rapidly loses interest in interviews and can only mange brief interactions. This has not changed this last reporting year.

His replies are limited, often with one-word (“yes” or “no”) responses. He routinely describes his mood as “good” and denies any affective concerns. His affect is restricted.

His thought form is grossly disorganized, both in English and Cantonese. Staff able to communicate in both languages report gross disorganisation in both languages.

He denies suicidal or homicidal ideation. He also denies hallucinations, though he occasionally mumbles to himself and appears internally preoccupied. He has reported being shouted at by a man, in what may be an hallucination. Thought content is limited to immediate concerns regarding his activities with no elaboration. He does not express paranoid ideation but appears hostile and suspicious.

He lacks judgment in the areas of maintaining cleanliness, hygiene practices, hoarding and physical health monitoring, though he exhibits fair judgment in his compliance with medication."

[8]. With regard to whether Mr. Thai continues to pose a significant threat to the safety of the public, the following is extracted from the current hospital report:

"RISK ASSESSMENT

Research has shown that actuarial methods of risk assessment are strong predictors of long-term violence risk across a range of populations and contexts. Actuarial methods provide probabilistic estimates of risk, based solely on empirically established relationships between a number of clinically relevant predictors and violent recidivism. Dynamic variables, as discussed below, are more associated with short to medium term risk and provide targets for appropriate and timely intervention strategies.

Structured clinical judgment is an approach to risk assessment that includes actuarial or historical risk factors as well as dynamic risk factors, and integrates both types of risk factors into a risk formulation or final risk judgement. This approach is employed in CAMH ORB reports. To guide this process, the HCR-20 Structured Guide for the Assessment of Violence Risk was scored. The HCR-20 is intended for use with civil psychiatric, forensic, and criminal justice populations. There are 10 historical (H) variables, 5 clinical (C) variables, and 5 risk management (R) factors. Each item is scored as 0 (not present), 1 (possibly present) or 2 (definitely present) to yield a score out of 40. It includes variables that capture relevant past, present, and future considerations. Specific subscale scores from the HCR-20 may have implications for clinical management of the patient’s risk. One historical item consists of the Psychopathy Checklist – Revised (PCL-R).

PCL-R score

Mr. Thai’s score on the PCL-R was 20, placing him at the 48th percentile among North American male forensic psychiatric patients.

VRAG

On the basis of his score on the VRAG, Mr. Thai’s category of risk for violent recidivism is in the 4th highest of 9 categories. Among mentally disordered offenders, approximately 31% in that category re-offend violently within an average of 10 years of opportunity.

HCR-20

In 2017, Mr. Thai scored 24 out of a possible 40 points on the HCR-20 Version 2. He scored 12/20 on the historical items, 6/10 on the clinical items and 6/10 on the risk management items when scored under a custodial disposition. Clinical items of particular concern include a lack of insight and active symptoms of psychosis. Risk management items of particular concern include a lack of personal support, and potential exposure to destabilizers.

From 2018 to 2024, the HCR-20 Version 3 has been used, and was rescored in November 2025 (results below). The score is essentially unchanged since 2023.

Historical Items:

Historical (H) items that were deemed present, and relevant, were history of problems with violence, relationship problems, employment problems, major mental disorder, traumatic experiences, violent attitudes and problems with treatment or supervision response.

Clinical Items:

The primary clinical (C) items that were deemed present, and relevant, were problems with insight into his mental disorder, symptoms of his mental disorder, instability and treatment responsiveness and compliance. Items that were possibly present and relevant included recent problems with violent ideation and instability. His hoarding behaviour and opportunistic taking of hazardous items is an ongoing risk.

Risk Management Items:

The Risk Management (R) factors that were deemed present, and relevant should Mr. Thai remain under the jurisdiction of the ORB under a detention order were future problems with treatment or supervision response, and management of stress and coping.

The Risk Management (R) factors that were deemed present, and relevant should Mr. Thai be granted a conditional discharge and released into the community without significant mandated structure and psychiatric support, were future problems with professional services and plans, living situation, personal support, treatment or supervision response, and management of stress and coping skills.

Overall, he was assessed as being at high risk of violence under the current recommendation of a detention order with community living in approved supervised accommodation.

SAPROF

The Structured Assessment of Protective Factors (SAPROF) was developed for the assessment of protective factors for adult offenders. It was intended to be used in addition to risk focused structured professional judgment tools, such as the HCR-20. The SAPROF contains 17 protective factors organized into three scales. 15 of the factors are dynamic, making them valuable treatment targets and treatment evaluation measures.

On the SAPROF, Mr. Thai’s notable protective factors include mainly external elements such as professional care, living circumstance and external controls in place. However, Mr. Thai has also demonstrated medication compliance within a supervised setting with encouragement, positive attitudes towards his care team has gradually developed at Mon Sheong, and select leisure activities. He approaches staff and engages appropriately for the most part, with some ongoing areas of frustration. Within a supervised setting, his level of protective factors is deemed to be low-moderate, and his risk of violence, high-moderate.

Clinical Risk Factors/Re-offence Scenario

Criminogenic risk factors include Mr. Thai’s psychotic illness (schizophrenia with severe disorganization), history of violence, history of non-adherence with medication and treatment supervision, lack of insight, cognitive impairment, poor frustration tolerance, limited structure and vocational skills, and social isolation.

If Mr. Thai is to reoffend, this will likely transpire in the following way:

Mr. Thai suffers from schizophrenia with significant residual psychosis. He has no appreciable awareness of his illness or need for medications. As such, he is not motivated to maintain adherence when unprompted and supervised. When not treated or under-treated, his psychosis intensifies, and he will likely exhibit violent behaviour towards others. This pattern of non-adherence with medications outside of external obligations and supervision, and resultant decompensation and aggression has been documented on numerous occasions both in the hospital and while in the community. Mr. Thai has demonstrated a history of rapid decompensation when non-adherent with clozapine, even with short periods of missed does. From a risk management perspective, the clinical team requires an equally rapid ability to intervene in the relapse scenario, prior to the emergence of florid psychosis and violence. He has an ongoing risk of conflict arising from his poor insight, resistive to housing rules and challenging behaviour. We have seen evidence of low severity violent behaviour in response to day-to-day frustration in the last reporting year, compounding his hoarding.

3. Diagnosis

Schizophrenia

Mr. Thai has shown prominent thought disorder and hallucinations, and significant elements of disorganized behaviour and negative symptoms. His symptom onset was in his late teens/early 20s. As a result of his psychosis, Mr. Thai has shown significant disturbance in his ability to work, maintain his basic activities of daily living, or engage in interpersonal relationships, each markedly below his premorbid level of functioning. Mr. Thai’s psychotic episodes are not related to substance use or to a general medical condition. He continues to show markedly disorganized thought and, in the past, persecutory delusions involving the belief he is the victim of theft that has contributed to his violent acts. His psychosis has, to date, only responded marginally to antipsychotic treatment and is treatment resistant/refractory. He has shown progressive cognitive decline over recent years as a result of marked disorganisation.

4. Composite Assessment of Risk

Mr. Thai has a significant history of violence and aggression, continues to experience an abnormal psychotic mental state, and has limited insight into his mental health problems, risks, and ongoing needs. He has a history of non-adherence with prescribed medication and disengaging from mental health care, including history of absconding from care. He also shows evidence of severely impaired cognitive function and frailty. Based on the clinical and actuarial risk issues noted above, the clinical team opines that Mr. Thai continues to pose a significant threat to the safety of the public as defined by section 672.5401 of the Criminal Code.

5. Risk Management

a. Schizophrenia

Our principal risk management interventions for this criminogenic variable are the continued administration of the antipsychotic medication, clozapine, currently at 550 mg daily and high-level support for the housing provider and the MacKenzie Service behavioural support specialist and through FOPS and our behavioural support team.

Of note, Mr. Thai is acutely sensitive to overstimulation and changes of care setting, which has been associated with an exacerbation of his disorganized behaviour and thought processes. Increased disorganization has likely fuelled previous instances of absconding and non-compliance with medications. His hoarding behaviour and intrusiveness in the care of others creates points of challenge and conflict with staff where he continues to respond to with physical threats and challenges. While residing in the community, he requires a closely monitored and supported environment in a locked facility with 24-hour on-site supervision (i.e. long-term care).

b. Non-compliance with psychiatric treatment/limited insight.

Our principal risk management strategy has been ongoing monitoring, supervision, behavioural support and psycho-education. Mr. Thai is assessed regularly with mental status examinations, with frank and open discussions regarding his illness and the need for medications, respect for Mon Sheong staff and rules and psychiatric follow-up. It is not clear how much of this information he understands. As such, it is critical that his medications are dispensed under supervision.

c. Social isolation/low educational attainment/poor vocational skills.

Our principal risk management strategy encourages Mr. Thai to engage in various programming activities that enhance his quality of life and skill development in his long-term care facility. The structure and support provided by these activities may have a stabilizing effect on his mental state. Prior to COVID, he regularly attended culturally-based programming in a community health Association. While at his housing placement at Mon Sheong Long-Term Care Centre, the clinical team continue to encourage greater participation in culturally based programs and services to enhance Mr. Thai’s social engagement and quality of life.”

[9]. At the conclusion of the Hospital Report the opinion and recommendation of Mr. Thai’s treatment team are set out as follows:

"The clinical team is of the opinion that Mr. Thai still presents as a significant threat to the safety of the public, given his ongoing symptoms, previous repeated supervision failures with associated aggression and difficulty in consistent engagement with counselling about risk identification and management. His residual psychotic symptoms and thought disorganization have rendered efforts for skill learning and development of strategies to mitigate re-offence challenging.

The clinical team is unanimous in recommending no change in his current Disposition Order, as he continues to manifest challenging behaviour with low severity violence in the last reporting year. We need to be able to rapidly readmit him to hospital to support his long-term care facility and make his ongoing community residence feasible. The Mental Health Act is deemed insufficient to manage his risk to the public.

In someone with such marked dependency needs and cognitive impairment, guardianship legislation may in time be sufficient to ensure that he remains in long-term secure, supported accommodation that he is likely to need indefinitely. Currently, however, the magnitude of his challenging behaviour is such that the care facility requires a very high level of assistance from FOPS to maintain his residence, including the option to readmit to the forensic program. This level of risk argues for maintenance of the Detention Order."

[10]. In response to questions from hospital counsel, Dr. Simpson stated that the team views Mon Sheong as the best place for Mr. Thai. He receives excellent, culturally appropriate care in a long-term care facility with security appropriate to the risks he poses."

[11]. In response to questions from Ms. Feldman, Dr. Simpson confirmed that it was Mon Sheong’s policy that “in his case” Mr. Thai was only to be escorted out of the residence and into the community by CAMH FOPS staff as there were no family members or volunteers available for that purpose. He acknowledged that the frequency of these outings was once or twice weekly, which was less frequent than would be the case at CAMH. Dr. Simpson agreed that Mr. Thai enjoyed being escorted to the local Tim Hortons – a distance of 400 to 500 meters - but added that Mr. Thai’s physical capacity had declined, that he had collapsed on those outings in the past, and that he currently would not accept a wheelchair as an alternative to walking. Dr. Simpson also agreed that Mr. Thai missed his CAMH friends and that he was bored; he added that going forward the treatment team would try to identify things that improved his quality of life and decreased his frustration.

[12]. Dr. Simpson opined that a conditional discharge would be inappropriate for Mr. Thai because the hospital required the authority to direct his place of accommodation and to rapidly re-hospitalise him if necessary.

[13]. In response to questions from panel members, Dr. Simpson opined that Mon Sheong was “very committed” to Mr. Thai’s care, albeit there were no trips or outings with Mr. Thai escorted by Mon Sheong staff. Asked if that was due to Mr. Thai’s behaviour, he replied that he was not sure specifically about the number and competency of Mon Sheong staff available for that purpose but that the current disposition did not prevent same.

[14]. In final submissions counsel for the hospital reiterated the recommendation that there be no change to the current disposition except that paragraphs 2(d) and 2(e) be amended by replacing “Toronto” with “Greater Toronto Area”. (The specific Mon Sheong LTC facility where Mr. Thai resides is located in Stouffville).

[15]. On behalf of Mr. Thai his counsel submitted that Mr. Thai’s disposition should provide “as much liberty as his condition allows.”

Analysis and Conclusions

[16]. As outlined above, none of the parties contested a finding of significant threat, and we find that the threshold test for significant threat continues to be met. Mr. Thai has a lengthy history of experiencing the symptoms of a major mental illness, diagnosed as schizophrenia. Historically he was noncompliant with treatment absent sufficient supervision and monitoring of his medication. When unmedicated or undermedicated, Mr. Thai decompensated rapidly and became acutely psychotic and violent. He continues to believe that he does not need medication and requires supervision when swallowing medication. He has also shown progressive cognitive decline over recent years, with marked disorganization. We accept that based on this history, his ongoing lack of insight and his level of disorganization, were Mr. Thai to no longer be subject to a Review Board disposition, this same pattern of noncompliance and resulting decompensation leading to violence is likely to be repeated.

[17]. We also agree that in order to address the risk that Mr. Thai poses to public safety, a detention disposition remains necessary and appropriate. The evidence is clear that the treatment team requires the authority to approve any housing in which Mr. Thai is placed while residing in the community. Given his very significant cognitive disorganization and behavioural challenges, Mr. Thai requires a high support, locked facility with 24-hour on-site supervision.

[18]. The treatment team continues to view Mon Sheong as a very good placement for Mr. Thai, and therefore much of the focus of the CAMH team’s work is to maintain him in that facility. That work involves making sure that the LTC staff at Mon Sheong feel well supported by the treatment team, including helping the staff to manage Mr. Thai’s challenging behaviour and ensuring that Mr. Thai can be readmitted quickly (and directly) to a forensic unit at CAMH, even at a time when he does not meet criteria for involuntary status under the MHA. This can only occur under a detention disposition.

[19]. Accordingly, considering public safety (which is paramount), as well as Mr. Thai’s mental condition, his community reintegration and his other needs, we find that the necessary and appropriate disposition, which is also the least onerous and least restrictive in the circumstances, is one continuing to detain Mr. Thai on a general forensic unit at CAMH, with privileges and prohibitions as set out in the current disposition.

[20]. As a final point, it occurs to the panel that it may be the specific wording of paragraphs 2(d) and 2(e) of the current disposition - which stipulate “to enter the community of Toronto” rather than “to enter the community of the Greater Toronto Area” - that is informing Mon Sheong’s “policy” and preventing their staff from escorting Mr. Thai on trips and outings, even to the local Tim Hortons. Therefore, the Disposition will be amended accordingly. In any event we encourage the CAMH team to work with the Mon Sheong staff in order to maximize his opportunities to enter the community.

DATED this 19^th^ day of March, 2026, at the City of Toronto, in the Toronto Region.

Hon. N. Kozloff Legal Member

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Office of the Registrar Ontario Review Board