Re Steven Sparling, 2026 CanLII 23899

Re: Steven Sparling

ORB File No: 7239

Hearing held on: Thursday, January 8, 2026

Place of hearing: Centre for Addiction and Mental Health

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

Before:

Alternate Chairperson: Mr. J. Weinstein

Members: Hon. N. Kozloff

Dr. K. Hand

Dr. G. Kerry

Mr. S. Duffy

Parties Appearing:

Accused: Steven Sparling

Counsel: Mr. B. Vincents

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

Attorney General of Ontario: Counsel: Ms. V. Culp

REASONS FOR DISPOSITION

(Dated March 19, 2026)

OVERVIEW

1. On October 6, 2017, Steven Sparling was found not criminally responsible on account of mental disorder on a charge of arson – reckless disregard for human life, contrary to the Criminal Code. (Note: Steven Sparling identifies as ‘non-binary’ and prefers they/them/their pronouns. They prefer to be referred to as Mx. Sparling.)

2. Mx. Sparling’s last annual review was conducted on January 6, 2025. They are currently subject to a disposition of the Ontario Review Board dated January 15, 2025, detaining them at the Centre for Addiction and Mental Health. The Disposition permits Mx. Sparling community living in the Greater Toronto Area in supervised accommodations, approved by the person in charge.

3. On January 8, 2026, the Board convened at CAMH for a mandatory review hearing of the Disposition further to s. 672.81(1) of the Criminal Code. Mx. Sparling was not in attendance. Their counsel confirmed that he had instructions to proceed, and an Order was made pursuant to s. 672.5(10) of the Criminal Code permitting them to be absent during the whole of the hearing.

4. The issues before the Board were to determine whether Mx. Sparling continues to pose a significant threat to the safety of the public and, if so, to determine the necessary and appropriate disposition for them consistent with the factors set out in s. 672.54 of the Criminal Code.

5. The Hospital asked the Board to conclude that Mx. Sparling continues to represent a significant threat to the safety of the public, and that a disposition detaining Mx. Sparling at the Forensic Service at CAMH with the provision for community living remains the necessary and appropriate, least onerous and least restrictive disposition to ensure the safety of the public (i.e. no change to the current disposition).

6. Counsel for the Attorney General agreed with the Hospital’s recommendation.

7. Counsel on behalf of Mx. Sparling requested an Absolute Discharge, arguing that they do not have a psychiatric illness nor do they require antipsychotic medication.

FINDINGS

8. After reviewing the evidence, the Board concluded that Mx. Sparling continues to represent a significant threat to the safety of the public. They have been assessed as a high-risk of committing grave harm to the public, and to themselves, and they continue to require the current level of supervision and treatment. There are serious concerns about the state of their recovery process and their level of understanding of and limited insight into their treatment resistant Schizophrenia. Their treatment plan includes the appropriate level of monitoring and supervision, which is still necessary at this time. For the reasons that follow in more detail below, the Board also concluded that the continuation of a Detention Order is both necessary and warranted at this time.

EVIDENCE AT THE HEARING

9. The Hospital Report dated December 9, 2025, was entered as Exhibit 1 at the hearing. One of the authors of that report, Dr. K. Valoo, also gave evidence at the hearing before this panel of the Board.

10. The relevant personal and psychiatric background information, including the events surrounding the 2015 index offence, is summarized in last year’s Reasons for Disposition and reproduced below (mutatis mutandis):

“PERSONAL BACKGROUND

On May 20, 2015, Collingwood emergency responders attended to a structure fire at a local group home, where Mx. Sparling lived on the second floor. Mx. Sparling had attempted suicide by cutting their wrists and, when that failed, they ignited the bed sheets despite knowing other residents were in the house. They had barricaded themselves in a room, preventing others from helping. Another resident suffered severe smoke inhalation, resulting in several months of hospitalization. The fire caused nearly $300,000 in property damage. Mx. Sparling sustained second- and third-degree burns requiring two and a half months in Sunnybrook Hospital's burn unit and a year at St. Joseph’s Rehabilitation Hospital, for multiple skin grafts.

Mx. Sparling is 59 years old, born in Collingwood, Ontario and is the second youngest of five children. Their youngest sister (their primary source of support) advised that their father and mother passed away in 2012 and 2016, respectively, and that Mx. Sparling struggled to cope with both deaths.

Mx. Sparling left high school in order to obtain employment. They had been a good student and eventually enrolled at the Collingwood Learning Centre where they successfully attained a high school diploma. They attended George Brown College, focusing on Culinary Arts. After the completion of an apprenticeship at the Westin Harbour Castle, Toronto, they earned their certification as a Red Seal Chef. Mx. Sparling worked at several different restaurants in Toronto and Collingwood but has long been unemployed due to their mental health difficulties.

Mx. Sparling had only been involved in two romantic relationships, with the last one being in their early twenties. Mx. Sparling has never been married, nor did they cohabitate with either of the girlfriends. Mx. Sparling had one serious romantic relationship that ended when the girlfriend went to university, and Mx. Sparling became ill. Records indicate that Mx. Sparling was confused about their sexuality as early as 1993.

Mx. Sparling does not have a criminal record and has never been charged with a criminal offence.

PSYCHIATRIC BACKGROUND

The psychiatric background information is contained in the Hospital Report. The following is a summary of the psychiatric hospital admissions before and after the court finding that Mx. Sparling was not criminally responsible of the index offence.

Mx. Sparling had multiple psychiatric admissions to hospital before the index offence. Records show that they were hospitalized in 1998 and 1999, receiving a diagnosis of psychosis, possibly due to Chronic Paranoid Schizophrenia or drug use, and traits of Dependency Inadequacy in the latter year at Penetanguishene.

There is a significant gap in the hospital records until 2009, during which time it appears they were receiving outpatient care. In 2010, they were admitted to Penetanguishene again and discharged with a diagnosis of Schizophrenia. In 2014, they visited an emergency room claiming they had suffered a sexual assault. They mentioned adhering to prescribed medications but had not seen a psychiatrist in four years and used marijuana daily, considering it their ‘medication.’

Following the injuries sustained in the fire related to the index offence, Mx. Sparling was treated in hospital. After discharge, they resumed consultations with a community psychiatrist but had multiple hospital admissions in 2016 due to psychiatric decompensations. 15. In 2017, Mx. Sparling was evaluated for criminal responsibility. After the finding of ‘not criminally responsible,’ they initially resided in the community subject to a Conditional Discharge disposition while followed by the Waypoint outpatient forensic team.

In May 2018, they began to exhibit breakthrough symptoms of psychosis, and their reporting condition increased to not less than every week. It was subsequently discovered that they had been non-compliant with their oral antipsychotic medication. On December 10, 2018, the Board convened an early hearing at the request of the outpatient team. They were issued a new Detention Order disposition, and police brought them to Waypoint for admission later in the day. They remained at Waypoint until their transfer to CAMH on July 13, 2021.

In 2023, Mx. Sparling’s clinical year was described as relatively stable, but stagnant. There were no significant rule violations or management concerns. They were abstinent from substances, and there were no absconding incidents. Mx. Sparling continued to exhibit treatment-resistant psychotic symptoms, with limited engagement, declining all efforts to engage in therapeutic programming or activities. When Dr. Meng was away from the hospital, they refused to meet with the replacement psychiatrist for a significant period. Mx. Sparling’s insight into their illness remains very poor.

Mx. Sparling’s current psychiatric diagnoses are Schizophrenia (with treatment refractory positive and negative symptoms), and Cannabis Use Disorder (in sustained remission, in a controlled environment). Mx. Sparling has been found not capable of making decisions about their medical treatment, but they are capable of managing their finances independently. Their substitute decision maker has been appointed by the Office of the Public Guardian and Trustee. They are financially supported by the Ontario Disability Support Program.

Mx Sparling’s course in hospital is detailed in the current Hospital Report of Dr. Valoo, who had replaced Mx. Sparling’s regular attending psychiatrist, Dr. Meng, in 2025 while she was on leave. Dr. Valoo also testified before this panel of the Board."

11. The following relevant portions of the most recent year’s course of treatment are reproduced from the Hospital Report:

“CAMH (LGUA) – January 2025 to December 2025

Mx. Sparling remained admitted to the FGUA over this reporting period. They had a challenging year characterized by an unauthorized leave of absence (ULOA), a changeover of psychiatrists, and discontinuation of all psychiatric treatment.

Mental Health and Treatment

Mx. Sparling continued to experience chronic paranoid and somatic delusional beliefs, including beliefs that they were pregnant and persecutory beliefs about their treatment in the hospital. These beliefs intermittently manifested in emotional lability and verbal agitation towards unit staff.

On April 30, 2025, Mx. Sparling signed out for an indirectly supervised pass to the community. They presented at their baseline mental status. However, they did not return to the unit at their expected time. The hospital’s ULOA protocol was initiated. That evening, Mx. Sparling was seen by their social worker near to the hospital. Simultaneously, security officers reported that Mx. Sparling had phoned police to say that they were not coming back to CAMH because they believed they had been sexually assaulted there. Police subsequently apprehended Ms. Sparling near CAMH and brought them back to the unit. The following day, Mx. Sparling declined to speak with their psychiatrist about the ULOA incident. On May 2, 2025, they did agree to speak with their psychiatrist, and said that they stayed out longer than their pass allowed in order to attract police attention on the persecution they experienced at CAMH. They opined that they had been successful in making a police report about their safety concerns through the ULOA. They were unremorseful about the ULOA, but said that they did not intend to do this again because they had achieved their goal.

A few days later, Mx. Sparling’s long-term psychiatrist, Dr. Meng, went on leave. Coverage was provided by Dr. Valoo. Mx. Sparling refused to engage in any form of assessment with Dr. Valoo for the near entirety of the remainder of the reporting period. They continued to experience prominent psychotic symptoms which intermittently manifested in verbal agitation towards staff. In June 2025, their unit social worker held a case conference with the Social Determinants of Health clinic to discuss Mx. Sparling’s suitability for a housing program. The social worker received feedback that Mx. Sparling’s options for community-based housing were extremely limited in the context of the nature of their index offence (arson) in combination with ongoing active psychotic symptoms.

Following this feedback, detailed discussions were had amongst the impatient team about options to optimize Mx. Sparling's antipsychotic treatment. It was determined that although a trial of clozapine would likely be helpful, this would not be feasible due to Mx. Sparling’s staunch refusal to accept oral antipsychotic medications, as well as the likelihood that they would not comply with mandatory monitoring requirements of a clozapine trial. Therefore, a trial of ECT was pursued instead. Mx. Sparling was highly resistant to engagement in any form of discussion about ECT.

On August 8, 2025, Mx. Sparling began declining injectable aripiprazole due to ongoing delusional beliefs that they were pregnant. They continued to decline injectable medication over the next several days, in spite of various attempts by the inpatient team to encourage compliance. They subsequently requested a Consent and Capacity Board (CCB) hearing to contest the findings of incapacity with regards to both antipsychotic medications and ECT.

Mx. Sparling engaged in a single discussion with Dr. Valoo on August 12, 2025. During this discussion they expressed a total lack of insight into their mental health condition and the likely outcomes of optimized antipsychotic treatment.

The CCB hearing was held on August 19, 2025, and both findings of incapacity were upheld by the Board. Mx. Sparling submitted an appeal of these findings. As a result, they remained untreated for the remainder of the reporting period. This appeal was scheduled to be heard in Court on January 26, 2026.

Thereafter, Mx. Sparling’s delusional beliefs and subsequent behavioral consequences gradually escalated. They maintained delusional beliefs that they were pregnant, and this resulted in various behaviors such as requesting massive quantities of food, repeatedly requesting hospitalist assessments, and exhibiting verbal agitation towards staff when they perceived that they were not getting adequate prenatal care. On September 1, 2025, while expressing beliefs that they were experiencing a miscarriage, they yelled at staff, threatened to “smack” a nurse, and shook the door of the nursing station. On October 7, 2025, they were subject to a code white (their first since their transfer to CAMH in 2021) for aggressive and dysregulated behavior, including screaming at and posturing to punch a nurse, triggered by perceptions that staff were not addressing their medical needs adequately. After the code white was called, they agreed to walk to the seclusion room without the need for mechanical or chemical restraints, and they were successfully trialled out of seclusion later that afternoon.

Passes and Programming

Mx. Sparling made use of level 7 passes for several years, until their ULOA in April 2025. Thereafter, they were reduced to level 0 passes (courtyard access) as per the CAMH pass ladder system. After four weeks they were approved for level 1 passes (escorted passes on hospital grounds), but did not use these. The OPIC eventually revoked their approval for off-unit passes (with an exception to attend medical appointments) due to Mx. Sparling's ongoing psychotic symptoms and inability for their psychiatrist to complete risk assessments due to a lack of engagement.

Mx. Sparling did not engage in any form of therapeutic or recreational programming over this reporting period. They spent the vast majority of time in their room, though did typically leave their room for meals and to make requests from staff.

Physical Health

Mx. Sparling continued to experience chronic health complications, including COPD and poorly controlled high blood pressure. Assessments of physical symptoms, as well as their willingness to comply with recommendations to manage their chronic health conditions, were complicated by their ongoing psychotic symptoms. For example, they frequently reported symptoms of pregnancy and/or menstruation, but declined investigations to determine the cause of these symptoms due to an inability to recognize that they were biologically incapable of being pregnant or menstruating. They also declined treatments that were unsafe in pregnancy, resulting in suboptimal control of their health conditions. In November 2025 Mx. Sparling had an appointment at the respirology service of St. Michael's Hospital for further assessment of their respiratory symptoms. However, on the day of the appointment they declined to attend, and were not willing to provide any explanation for this decision.

MEDICATIONS

At the time of this report, Mx. Sparling did not receive any psychiatric medications. They took various medications (acetaminophen, amlodipine, doxazosin, steroid inhalers, hydralazine, metformin, pantoprazole, perindopril, rosuvastatin) to manage their chronic physical health conditions.

MENTAL STATUS EXAMINATION (December 2025)

Mx. Sparling presented as a 59-year-old individual. They were consistently well groomed and appropriately dressed. They were generally calm during interactions with select staff members, but intermittently demonstrated irritability, suspiciousness, and demandingness. Their behavioural and affective control were generally good, but seemed to decline gradually over the reporting period. Their speech was spontaneous with generally good elaboration on responses. Their affect was usually euthymic, and could be quite bright during interactions with staff members that they liked. Their thought process was generally linear and organized, although there was evidence of underlying conceptual disorganization and a lack of internal coherence when discussing more delusional content. Their thought content became increasingly focussed on delusional content of a principally bizarre and somatic nature over the period. While they were guarded and hypervigilant at times, they did not appear distracted by internal stimuli. They showed poor insight into their illness, need for treatment, and risk factors for violent reoffending. Their judgment was fair despite these deficits. They were usually rule-abiding and cooperative with the conditions of their disposition with ongoing external oversight and support."

12. Dr. Valoo addresses the issue of risk (significant threat) at pp. 61 – 65 of the hospital report. The salient portions are reproduced below:

"RISK ASSESSMENT

Historical (H) risk items that are Present and Highly Relevant include a history of problems with Violence (in adulthood), Substance Use, Major Mental Disorder (schizophrenia), Traumatic Experiences, and Treatment/Supervision Response

Clinical (C) risk items that are Present and Highly Relevant are recent problems with Insight (illness, need for treatment, and violence risk), Symptoms of Major Mental Disorder (schizophrenia), Instability, and Treatment or Supervision Response. Recent problems with Violent Ideation or Intent are Possibly/Partially Present and Highly Relevant given a recent re-emergence of threatening behaviour towards hospital staff, in the context of medication non-compliance.

Final Risk Judgment

Taken together, when weighing Mx. Sparling’s pertinent risk and protective factors, their risk of any future violence would be Moderate in the context of a continuation of the current Detention Order.

In contrast, under a Conditional Discharge, their risk of future violence would increase to High.

Clinical Risk Factors/Re-offence Scenario

Criminogenic risk factors important to understanding Mx. Sparling’s re-offending risk are their history of violence, major mental illness (treatment-resistant schizophrenia), poor insight, medication non-compliance, history of substance use (cannabis), and poor therapeutic engagement.

Mx. Sparling’s history of violence with resulting serious physical harm to others primarily centered around the May 2015 index offence. Their conduct at the time had flowed from an acutely psychotic mental state. They had been extremely fearful that males had been sexually assaulting them and that they would be further sexually assaulted. They cut their wrists and set a fire in their rooming house that led to serious injury to both themselves and another resident, and caused extensive property destruction. Prior to that, during a first psychiatric admission in 1993 they expressed paranoia with thoughts of hurting their niece. During their admission to Waypoint, they made verbal threats towards staff. In 2025, since discontinuing all antipsychotic treatment, they exhibited two instances of threatening behaviour towards hospital staff (including posturing to punch a nurse, resulting in their first code white since the admission to CAMH). This history demonstrates a clear link between their mental illness and violent/threatening behaviour towards others.

Mx. Sparling has a longstanding history of schizophrenia since the 1990’s. They have a history of irregular compliance with medication and psychiatric follow-up. Even when adherent with treatment, Mx. Sparling has exhibited ongoing treatment-resistant psychosis. They were reportedly taking medication prior to the May 2015 index offence, yet was markedly psychotic at the material time, leading to serious harm to others. The exact etiology of their psychotic decompensation was unclear, though they had shown a significant escalation in cannabis use over the preceding period. In 2018, they covertly discontinued oral medication with significant exacerbation of psychotic symptoms. They required police intervention to bring them to hospital and needed placement in seclusion due to agitated, intimidating, and uncooperative behaviour. Their mental state, in the context of psychotic exacerbation, was notably characterized by the same persecutory delusional beliefs that had motivated the index offence. Since their readmission in 2018, they have adamantly refused all oral psychiatric medication and on several occasions, physical intervention from multiple clinical staff was required to facilitate their injection administrations. Despite treatment, they continued to operate under a significant psychotic symptom burden, and it was only since 2021 that their more overt persecutory delusions have shown attenuation. This progress was reversed in 2025, when they discontinued their antipsychotic treatment and launched an appeal of a finding of incapacity with respect to psychiatric treatment, leading to gradual escalations of their paranoid and persecutory beliefs and ensuing behavioural dysregulation. Their insight into their ongoing symptom burden is absent, and this has impeded their engagement in therapeutic interventions intended to address their dynamic risk factors and mitigate their risk to public safety absent the present detention order.

Mx. Sparling’s most likely reoffence scenario would be in the context of an acute psychotic relapse in an uncontrolled/non-clinical environment, precipitated by antipsychotic medication non-compliance, the destabilizing effects of substance use, and/or exposure to stressors. In light of their poor insight, pattern of medication non-adherence when not subject to external enforcement, poor therapeutic engagement, and strong interpersonal distrust, it is anticipated that absent the external controls and oversight afforded by their detention order disposition, they would fall away from care, discontinue treatment, and likely re-engage in the use of cannabis. As their mental state deteriorates, they would experience a re-emergence of the same intense persecutory and paranoid delusions that had preoccupied their thinking at the time of the index offence. They would likely withdraw further and refuse contact with potential supports. Their living situation would likely become unstable as they attempted to escape from persecution. As their level of distress intensified, they would be susceptible to engage in the same type of high-lethality remedy that had characterized the index offence, placing both themself and those in their environment at risk of serious physical harm.

Diagnosis

Schizophrenia (with treatment refractory positive and negative symptoms)

Cannabis Use Disorder (in sustained remission in a controlled environment)

Composite Assessment of Risk

Based on the above noted dynamic and static risk factors, the clinical team is unanimous in the opinion that Mx. Sparling continues to represent a significant threat to public safety, as defined in Section 672.5401 of the Criminal Code."

13. The Hospital Report concludes with the recommendation of the treatment team:

"The treatment team is unanimous that a disposition detaining Mx. Sparling at the Forensic Service at CAMH with the provision for community living in approved accommodations remains the necessary and appropriate, least onerous and least restrictive, disposition to ensure the safety of the public.

A conditional discharge is not appropriate at this juncture, given that Mx. Sparling remains untreated from a psychiatric perspective and has no available community-based accommodation. If Mx. Sparling does transition to community living over the upcoming year, the team must be able to act quickly and efficiently prior to Mx. Sparling becoming certifiable under the Mental Health Act in order to manage their risk to the public. Additionally, it remains necessary to approve their accommodation for risk management purposes."

Vive Voce Evidence of Dr. Valoo

14. In her testimony before this panel of the Board, Dr. Valoo underlined that over the past year there has been a decline in Mx. Sparling’s mental health with increasing psychosis. She advised that their schizophrenia is treatment-resistant and does not respond to at least two different types of antipsychotic medication. She opined that ECT (Electroconvulsive therapy) in combination with clozapine might be an effective treatment option for Mx. Sparling but haven’t as yet been tried in combination. Mx. Sparling remains untreated while awaiting a decision of the Court of Appeal on their appeal of a decision of the Consent and Capacity Board that upheld a finding that they are incapable of making treatment decisions regarding their mental disorder.

15. Asked about an Absolute Discharge, Dr. Valoo responded that the likelihood of them taking their antipsychotic medication is nil. She expressed the following concerns about an absolute discharge at this time:

a. they are not receiving treatment / medication currently

b. they are evidently psychotic and getting worse

c. they would lose their professional, social, and community supports

In the result they would be at increased risk for a recurrence of violence as in the past.

16. Dr. Valoo summarized their risk on the basis of what disposition is ordered by the Board at this time:

a. Detention Order: moderate

b. Conditional Discharge: high

c. Absolute Discharge: unmanageable

Dr. Valoo thought it very likely that Mx Sparling would discharge themself from hospital and wondered where they would go, how they would support themself and care for themself.

17. Mx. Sparling has been unmedicated since August 2025. As at the time of the hearing, they had not seen Dr. Meng, who recently returned from leave. The treatment plan going forward is dependent on the outcome of Mx. Sparling’s CCB appeal. If the CCB upholds the hospital position, treatment with antipsychotic medication will resume.

Final Submissions

18. Counsel for the hospital stated that their position remains unchanged: Mx. Sparling remains a significant threat to the safety of the public and a detention order is the necessary and appropriate, least onerous and least restrictive disposition.

19. Counsel for the Attorney General posited that Mx. Sparling is “worse” than they were in 2025, and accordingly there should be no change to the current Disposition, a Detention Order at CAMH.

20. Counsel for Mx. Sparling reiterated the request for an Absolute Discharge, arguing that they do not have a psychiatric illness nor do they require antipsychotic medication.

ANALYSIS AND CONCLUSION

(a) Significant Threat

21. Where there is a risk of serious physical or psychological harm to members of the public resulting from conduct that is criminal in nature but not necessarily violent, the Board must find that the threshold for ‘significant threat’ has been met.

22. The issue of whether Mx. Sparling continues to pose a significant threat to the safety of the public was contested at the hearing, and accordingly we have carefully considered the issue.

23. Based on the testimony of Dr. Valoo and the relevant contents of the current Hospital Report, Mx. Sparling remains a significant threat to the safety of the public.

24. Several factors convince us that the threshold for ‘significant threat’ has been met. Mx. Sparling has a complex psychiatric profile where their primary diagnosis of Schizophrenia appears to be treatment resistant. Recent risk assessments also point out that Mx. Sparling’s risk for violent recidivism remains in the relatively high range.

25. In the result, we find on the evidence that Mx. Sparling remains a significant threat to the safety of the public.

(b) Necessary and Appropriate

26. Having found that Mx. Sparling remains a significant threat to the safety of the public it follows that they are not entitled to be discharged absolutely. In any event, an Absolute Discharge has absolutely no air of reality at this time because of the lengthy history of mental illness and the severity of their substance use, the serious nature of the index offence, and the significant recent fall back from limited recovery progress they had made over the years, notwithstanding the length of time they have been in the psychiatric system. If granted an Absolute Discharge at this time and without the oversight of the Ontario Review Board, they would leave hospital, continue their non-adherence with antipsychotic medication, disengage from their treatment providers, decompensate and pose a significant threat to the safety of the public because of their psychosis driven behaviors.

27. We note that Mx. Sparling has been assessed as having a treatment resistant (refractory) mental disorder, marked by psychotic and mood symptoms, including a salient paranoid belief system. They have a history of past and current non-adherence to medication and disengagement with treatment providers, with subsequent significant mental and functioning deterioration.

28. From the evidence of Dr. Valoo it is clear to us that this was a very difficult year for Mx. Sparling. They went absent without leave, refused to engage with their assigned attending psychiatrist, and became non-adherent with their anti-psychotic medication. In the result, their mental health has significantly declined.

29. This is particularly concerning considering the violent nature of the index offence driven by untreated psychotic episodes combined with a disregard for the safety of the other residents of the group home and their own life. There is still a high probability that they will become violent again, especially if their positive and negative psychotic symptoms worsen. Their entrenched delusional system remains a real concern, especially given their current non-adherence.

30. It is readily apparent to us that because of Mx. Sparling’s non-adherence to medication and non-engagement with their treating psychiatrist for over 6 months, these serious ongoing concerns about their mental illness are significantly heightened.

31. We find that continued oversight under the Board will be vital to Mx. Sparling’s overall recovery process, especially in light of the recent events that have caused a resurgence of their psychotic symptoms with increased paranoid and persecutory intensity, which in turn only heightens their need for continued close monitoring and supervision to ensure both their safety and that of the public.

32. The current Disposition appropriately addresses their current level of threat to the safety of others and to themselves, given that they are subject to the level of supervision provided by their treatment team and the forensic psychiatry services at CAMH. Their psychiatric treatment and care involve the necessary level of supervision, evaluation, and adjustment to manage their risk level. Without the forensic treatment team, and their interventions and support, Mx. Sparling’s recovery path would most certainly decline.

33. Indeed, they have been assessed as a high risk of committing grave harm to the public should they be discharged conditionally, and they continue to require the necessary level of supervision and treatment provided by a Detention Order.

34. Mx. Sparling’s treatment plan is in place because of their numerous readmissions to hospital and their ongoing psychotic symptoms, which are intensified by a concrete paranoid belief system. It is apparent to us that they present a significant treatment challenge at this point in time.

35. The forensic treatment team is key in helping Mx. Sparling achieve mental stability, and we find given all the circumstances, that they could not be managed without the current level of assistance and supervision. It remains to be seen if they are able to make more progress moving forward and achieve more stability with the medication and treatment plan in the upcoming year(s).

36. Accordingly, we conclude on the evidence before us that the necessary and appropriate, least onerous and least restrictive disposition for Mx. Sparling is to continue their recovery process under the supervision and authority of the Ontario Review Board, in accordance with their current Detention Order.

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

Hon. N. Kozloff

Legal Member

__________________ Office of the Registrar

Ontario Review Board