Re Christopher George, 2026 CanLII 34222

Ontario Review Board

Re: Christopher George

ORB File No: 5178/5244/5987

Hearing held on: Tuesday, March 24, 2026

Place of hearing: Southwest Centre for Forensic Mental Health Care 401 Sunset Drive, St. Thomas

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

Before: Alternate Chairperson: Ms. T. Mann Members: Dr. P.E. Cook Dr. P.N. Wright Ms. K. Tomaszewski Mr. S. Duffy

Parties Appearing:

Accused: Christopher George Counsel: Mr. S.F. Gehl

The person in charge of hospital: Counsel: Ms. J. Zamprogna

Attorney General of Ontario: Counsel: Ms. K. Dalrymple

REASONS FOR DISPOSITION

(Dated April 14, 2026)

Introduction:

1. On October 2, 2008, Mr. Christopher George was found not criminally responsible on account of mental disorder, on charges of break and enter, commit mischief over $5000, fail to comply with probation order (x2), theft under $5000, robbery, utter threat to cause death or bodily harm, and fail to comply with recognizance (x3), all contrary to the Criminal Code of Canada (“Criminal Code”). On December 2, 2008, Mr. George was found not criminally responsible on account of mental disorder on charges of robbery (x2) and wearing a disguise with intent (x2). In October 2011, Mr. George was found not criminally responsible on account of mental disorder on a charge of robbery.

2. Mr. George is subject to a Disposition of the Ontario Review Board (the “Board”) dated March 21, 2025, which orders that he be detained at the Southwest Centre for Forensic Mental Health Care, St. Joseph's Health Care London (the “Hospital” or “Southwest”).

3. On March 24, 2026, the Board convened a hearing at Southwest to conduct the annual review of the current Disposition.

4. Mr. George was present at the hearing and was represented by his counsel, Mr. Gehl.

5. A Hospital Report, dated January 27, 2026 (the "Hospital Report"), was entered as Exhibit 1.

6. The issue at this hearing is whether Mr. George is a significant threat to public safety, as defined in s. 672.5401 of the Criminal Code. If so, the necessary and appropriate Disposition in the circumstances must be determined, bearing in mind the factors enunciated in s. 672.54 of the Criminal Code.

7. For the reasons set out below and based on the expert evidence and opinions before it, the Board concluded that Mr. George continues to present a significant threat to the safety of the public. The Board ordered that the necessary and appropriate Disposition in the circumstances is a continuation of the existing Detention Order with the addition of the name of the Hospital to paragraphs 2(d) and (f) as proposed by the Hospital on page 220 of the Hospital Report.

Current Psychiatric Diagnoses:

8. Schizophrenia Substance Use Disorder (alcohol, cannabis, inhalants, methamphetamine; in sustained remission in a controlled environment) Antisocial Personality Disorder Attention Deficit Hyperactivity Disorder, by history

Index Offences:

9. The circumstances giving rise to the Index Offences are extracted from last year’s Board Reasons, as follows:

“On June 28, 2008, Mr. George used a brick to break a glass door into the lounge on the 20^th floor of a building in Sarnia. He took a television and dropped it in the garage of the building causing it to shatter. He was charged with break and enter, theft, and mischief. As a result of these offences, he was subject to a probation order. He was subsequently charged with failing to comply with the probation order, which required him to keep the peace and be of good behaviour. He was released on June 28, 2008.

On July 2, 2008, Mr. George stole a cell phone from the River City Men’s Shelter in Sarnia and fled on foot. A warrant was issued for him for theft under $5000.

On July 18, 2008, Mr. George entered a Bank of Montreal with a white grocery bag covering his head with eyes holes torn out. He was holding an Exacto knife and a black bag. He stated, “Just put all the money in the bag.” The teller removed cash from the cash drawer and put it in the bag. Mr. George left on foot and got into his waiting taxi.

On July 20, 2008, the victim used an ATM in the entrance of a Toronto-Dominion Bank (“TD”). When the victim left the bank, Mr. George approached the victim brandishing a screwdriver. Mr. George shouted, “I’ll kill you if you don’t give me that money!” The victim handed the money over to Mr. George. Mr. George ran away while shouting, “If you call the police I’ll kill you.” Mr. George was charged with the robbery offence, and uttering death threats. At that time, he was advised of the warrant from the July 2, 2008 incident and was held pending a bail hearing. Upon arrest for this incident Mr. George provided a false address to the police, and he was then considered of no fixed address. He smelled of alcohol and advised the police he had consumed two beers prior to the robbery, and he had ingested 80 units of methamphetamine during the daytime hours; both in contravention of his condition to abstain. As a result, Mr. George was charged with three counts of breaching his Undertaking. Subsequent investigation revealed the Mr. George continued to be subject to a probation order of November 16, 2006, which had a two-year duration and required him to keep the peace and be of good behaviour. He had contravened this probation order when he was involved in the robbery outside of the TD bank. As a result, Mr. George was further charged with one count of breaching his probation.

June 22, 2011: Mr. George took a taxi to a Bank of Montreal in London, ON. He told the teller “This is a holdup, I have a knife, I have a knife.” The supervisor told him that they don’t keep cash at the wickets. Mr. George turned and walked out. He took the taxi back to his starting location and then fled without paying the cab driver. The police found him at a motel and arrested him for robbery. In his pocket was a note, “THIS IS A ROBBIE.” While being transported to cells, Mr. George admitted to committing the robbery.”

Background Information:

10. Mr. George’s background is outlined in the Hospital Report, and it is accurately summarized in last year’s Reasons:

“Mr. George was born in Sarnia. Both his parents died young in tragic circumstances. His drug use started at an extremely young age. He sold drugs extensively. As an adult he was often of no fixed address and resided in shelters and hostels. His criminal history is very lengthy. There were several hospital admissions before the index offences. He has been plagued with mental illness, physical health issues and addiction issues over a long time. His strengths are his pleasant personality. He does well when occupied with activities in a structured manner.

It is noteworthy that he has absconded from hospitals multiple times, most recently from September 20 to 27, 2023. At that time, he relapsed with substances and was ultimately readmitted back to the Hospital on the A1 unit.

Mr. George is a registered Native Canadian of the Oneida Band.”

Position of the Parties:

11. Counsel for the hospital and for the Attorney General requested no change to the current Detention Order Disposition, except to add the Hospital’s name to paragraphs 2(d) and (f). Counsel for Mr. George conceded that significant threat was not at issue for the purposes of this hearing, and he agreed that a Detention Order as proposed by the Hospital is the necessary and appropriate Disposition in the circumstances.

12. Accordingly, there was a joint submission before the Board.

Course Since Last Disposition:

13. Mr. George’s course since his last Disposition is set out in detail in the Hospital Report. The following extracted paragraphs are relevant to this hearing:

“Throughout the reporting year, Mr. George experienced some psychotic symptoms, including daily audio hallucinations. He continued to suffer from his delusional belief systems. … Despite numerous treatments and medications (e.g., electro convulsive therapy, lithium and other mood stabilizers), the chronic nature of his symptoms persists. With that said, his symptoms do not diminish his ability to perform independent activities of daily living.”

“He also re-took his final exam for his Ontario Secondary School Diploma (OSSD) in April 2025 and passed, noting improvements throughout the year with attention and focus. Overall, however, he continued to demonstrate cognitive difficulties. For instance, he wrote lengthy letters to his treatment team asking for increased privileges which had already been approved. He also asked for passes to the YMCA, to which he was already attending.”

“Mr. George’s main sources of stress centered around complex structural processes (e.g., housing eligibility criteria) that have delayed his community reintegration. For instance, his application with Community Homes for Opportunity (CHO) housing was initially denied this year due to previous abscondment incidents. As a coping strategy, he remained engaged in structured and non-structured activities that he enjoyed. For the most part, he maintained his volunteer position at a local thrift store, attending three times weekly. However, near the end of the reporting period he impulsively quit this job and required prompting and support to continue, demonstrating low problem-solving abilities. He regularly attended an Indigenous healing circle at the Southwest Ontario Aboriginal Health Access Centre (SOAHAC) in London, an addictions support program, engaged in physical exercise at the YMCA and participated in other community outings.”

“…Mr. George requires a higher level of on-site support and supervision to which very minimal community housing programs in the area offer. Due to his abscondment history, referring Mr. George to a supervised accommodation in proximity to the hospital is recommended.”

“Mr. George had full hospital and grounds privileges…. He had community passes for the purpose of attending his volunteer job [a thrift store] weekly. During the week he was also able to attend the Canadian Mental Health Association (CMHA)-led programs for up to two hours. He had the choice of attending the library or the YMCA for up to two hours weekly. In addition, he was also able to go shopping at clothing stores once every two weeks. He also attended day passes with his approved person, Crystal George, where they spent time having dinner at her home and shopping. There have been no concerns reported while utilizing his community passes.”

“Mr. George had a long history of both alcohol and substance use. In the previous reporting year, he successfully completed a four-week substance use treatment program at Rainbow Lodge. He attended the same program in June 2025. Throughout the year, he continued attending the Southwest Ontario Aboriginal Health Access Centre (SOAHAC) in London, for their weekly addictions healing circle which he initiated in October 2024. He also continued attending Celebrate Recovery meetings facilitated in the community on Sunday evenings.”

Evidence at the Hearing:

14. The Board had available to it the evidence and documents forming the Record, the Exhibits, and oral evidence from Dr. D. Curry, a psychiatry resident supervised by Dr. Quinn, Mr. George’s treating psychiatrist. Dr. Quinn co-authored the Hospital Report, and attended the hearing. Dr. Curry provided the following summary of Mr. George’s progress over the review period:

a) He has been involved with Mr. George’s care for approximately two months under the supervision of Dr. Quinn, Mr. George’s treating psychiatrist. Dr. Curry adopted the Hospital Report.

b) Mr. George had a relatively stable year.

c) Mt. George volunteers at the thrift store almost daily, and is a valued member of the thrift store team.

d) Mr. George remains connected to his aboriginal heritage through his cousin who is an approved person, and through various programs and activities.

e) Mr. George is mostly gregarious and out-going. He has the ability to quickly build rapport with people including clinicians, which is a major strength for him.

f) Mr. George continues to experience residual symptoms of schizophrenia, including daily auditory hallucinations; grandiose delusions particularly about his healing powers and extreme knowledge; tangential thinking; and mood fluctuations, with a mostly elevated mood. There is no concern with violent ideation or self-harm.

g) Many treatments have been trialed in the past with limited success. When the treatment team in the past used a stimulant medication, it immediately caused Mr. George to become floridly manic. Mr. George’s illness is treatment refractory. Mr. George is currently treated with clozapine. The dose of clozapine was increased last fall. His treatment is currently optimized, meaning that a balance has been struck between side effects and symptom management.

h) Mr. George is adherent to treatment but requires supervision and assistance to remain adherent. Although he is considered to be capable of consenting to treatment for schizophrenia, Mr. George has partial insight into schizophrenia and its symptoms. He knows he has been diagnosed with schizophrenia but does not recognize his delusions as symptoms of schizophrenia.

i) Mr. George becomes more disorganized and impulsive when he is stressed, and this disorganization and impulsiveness has a negative impact on his ability to adhere to his treatment regime without supervision and assistance.

j) To Mr. George’s credit, although he has had opportunities to use substances, he has remained abstinent from substances since his readmission to the Hospital, in 2023.

k) When he does use substances, Mr. George declines rapidly and becomes more disorganized and more psychotic, which worsens his mental status.

l) To maintain his sobriety, Mr. George has continued to be involved with indigenous healing and support through SOAHAC, and to attend Celebrate Recovery.

m) Mr. George’s motivation to attend residential treatment programs appears to be mixed, including the desire to leave the Hospital to meet social needs and relieve boredom. The Stonehenge residential treatment program will be considered in the future, depending on Mr. George’s housing stability.

n) Mr. George has a significant history of abscondment from the Hospital and from supervised residences in the community. His history includes abscondments in the early 2000’s, 2017, 2019 (x3), and 2023 (x2, both from CHO housing).

o) Mr. George may experience different triggers to abscond, including substance use, boredom, command auditory hallucinations, and personality structure. Sometimes the abscondments have been planned, and other times they have been impulsive. Mr. George has not absconded since 2023 because of the structures in place to meet his needs. Nevertheless, the underlying risk factors continue to be present, making continued structure and supervision essential to a successful community placement.

p) Mr. George requires a level of supervision sufficient to prevent him from becoming a risk to public safety. The treatment team needs timely notification if he absconds, or uses substances, so that he can be returned to the Hospital as quickly as possible before he can cause harm to the public.

q) CHO (Community Homes for Opportunity) provides supportive, affordable housing to those who are living with a serious mental illness, and is the only type of housing available near the Hospital which can meet Mr. George’s needs.

r) Because of his history of absconding from CHO residences (twice in 2023), CHO rejected Mr. George’s applications over the past two years. During the reporting period, the outreach team focused on advocating with CHO to obtain a placement for Mr. George.

s) This advocacy was successful, and Mr. George obtained a placement in a CHO home in St. Thomas, in close proximity to the Hospital, with an anticipated LOA to this residence starting on April 1, 2026.

t) This home will provide 24/7 supports for medications and monitoring of mental health status. The outreach team has a close relationship with the staff of this home, which will allow for quick sharing of information about Mr. George with the outreach team.

u) Mr. George decompensates rapidly, with an almost immediate increase in symptoms. In the past, the Hospital has been able to use a warrant of committal to bring Mr. George back to the Hospital. The ability to apprehend Mr. George quickly if necessary is a very important tool in maintaining Mr. George’s stability and ensuring the safety of the public to the extent possible.

v) Mr. George is entering a potentially destabilizing period as he again transitions to living in the community. A detention order is essential.

w) Mr. George’s abstinence will be further supported by a referral to Thames Valley addiction counselling services, a withdrawal management program, and AA.

x) Mr. George will be able to continue be able to structure his days with the community activities he is currently involved with, and the Hospital will provide transportation for these activities.

y) Mr. George continues to be supported by his cousin, who is now an approved person.

z) Mr. George will be able to connect with an aboriginal healer when he is ready for this.

Analysis and Conclusions:

15. Having heard and considered the entirety of the evidence as well as the submissions from the parties, the Board agrees with the joint submission: Mr. George remains a significant threat to the safety of the public.

16. In Winko, the Supreme Court outlined that, in coming to the conclusion on the issue of significant risk, a Review Board should closely examine a range of evidence, including: the circumstances of the original offence; the past and expected course of the accused’s treatment; the present state of the NCR accused’s medical condition; the NCR accused’s own plans for the future; the support existing for the NCR accused in the community; and most importantly, the recommendations provided by experts who examined the NCR accused. In coming to our conclusion in this matter, the Board relies on the uncontroverted evidence of Dr. Curry, in addition to the documentary evidence before us.

17. Mr. George cannot be managed in a less restrictive Disposition because he requires the high level of supervision offered by a Detention Order, including approving his housing, and the ability to bring Mr. George to the Hospital expeditiously if his mental status deteriorates.

18. Mr. George has a significant history of repeated abscondments. In the past, Mr. George has acted impulsively, leading to absconding and relapsing into substance use. Substance use has an immediate effect on exacerbating Mr. George’s psychotic symptoms, and increasing his disorganization and impulsivity. In this state, he will be unlikely and potentially unable, to remain medication adherent, which will further exacerbate his symptoms, causing him to become a significant threat to public safety.

19. Based on his history, the potential that Mr. George will abscond again is real, and not speculative.

20. Mr. George is entering a crucial and potentially destabilizing period of transition to community living. A detention order is necessary to provide the Hospital with the ability to return Mr. George to the Hospital expeditiously if he relapses into substance use or absconds, both to protect the public and to stabilize Mr. George as quickly as possible.

21. In particular, the Board relies on the Re-Offence Scenario and the Overall Clinical Assessment of Risk, as set out in the Hospital Report:

“Re-Offence Scenario (at page 218):

Absent forensic supervision and support, Mr. George would likely be without shelter and unable to cope with this contextual circumstance and engage in substance use behaviours. Coincidingly, he would not be able to obtain a psychiatric or adequate mental health support in a timely manner, causing him to discontinue his medication regime. The combination of substance use, medication nonadherence, and stress would further compromise his mental state, including increased delusions and hallucinations. Within this disinhibited context, he would respond with violence to psychotically-perceived aggressors in the community as well as to fuel his addiction habit.

Overall Clinical Assessment of Risk (at page 219)

It is the opinion of the treatment team that Mr. George continues to pose a risk of serious physical or psychological harm to members of the public. The following evidence supports this opinion:

1. Mr. George is diagnosed with a major mental disorder, namely schizophrenia, which is treatment-refractory. He continues to experience psychotic symptoms, including entrenched delusions and ongoing auditory hallucinations, which have commanded him to act violently in the past when decompensated. He is also impacted cognitively by his illness leading to behavioural disinhibition and inadequate problem-solving abilities;

2. Mr. George has a significant history of absconding, even while residing in a supervised environment. He will require his current treatment team to oversee and evaluate his community reintegration;

3. Mr. George has historically relapsed on substances, which resulted in financial instability and transient living (e.g., living outdoors). His ability to abstain from substances will need to be further evaluated in a less supervised setting;

4. Mr. George’s insight into his mental illness, need for treatment and future risk of violence remains underdeveloped. In the past, he was unable to acknowledge or seek professional help when symptoms of decompensation presented;

5. Mr. George would not be able to arrange appropriate mental health services to support his complex needs absent forensic support; and

6. Mr. George has limited personal support and his professional support is limited to the forensic team.”

7. In consideration of all the evidence, submissions of the parties and criteria set forth in s. 672.54, the paramount consideration being the safety of the public, in addition to the mental condition of Mr. George, his reintegration into society and his other needs, the necessary and appropriate Disposition is to continue with the current Detention Order, with the minor changes recommended by the Hospital.

8. The Board congratulates Mr. George on his completion of his Ontario Secondary School Diploma, and wishes him every success as he transitions to living in the community.

DATED this 14^th day of April 2026, at the City of Toronto, in the Region of Toronto.

Ms. K. Tomaszewski Legal Member Office of the Registrar Ontario Review Board