Ontario Review Board
Re: Michael G. Hobbs
ORB File No: 2752
Hearing held on: Tuesday, March 24, 2026
Place of hearing: Southwest Centre for Forensic Mental Health Care 401 Sunset Drive, St. Thomas, Ontario
Pursuant to: Section 672.81(1) of the Criminal Code
Before: Alternate Chairperson: Ms. T. Mann Members: Ms. K. Tomaszewski Dr. P. Cook Dr. P. Wright Mr. S. Duffy
Parties Appearing: Accused: Michael G. Hobbs Counsel: Mr. S. Gehl
The person in charge of hospital: Counsel: Ms. J. Zamprogna
Attorney General of Ontario: Counsel: Ms. K. Dalrymple
REASONS FOR DISPOSITION
(Dated May 5, 2026)
On June 17, 1998, Mr. Michael G. Hobbs was found not criminally responsible on account of a charge of criminal harassment, contrary to the Criminal Code of Canada (“the Criminal Code””). Mr. Hobbs is currently subject to a disposition of the Ontario Review Board (“the Board” or “ORB”) dated December 23, 2024, detaining him at the Southwest Centre for Forensic Mental Health Care (“Southwest” or “Hospital”), with privileges including to live in the community of Southwestern or Southern Ontario in accommodation approved by the person in charge.
On March 24, 2026, the Board convened this panel to conduct Mr. Hobbs’ annual review pursuant to section 672.81(1) of the Criminal Code. Mr. Hobbs was present throughout the hearing with his counsel, Mr. S. Gehl.
The issues to be determined are whether Mr. Hobbs represents as significant threat to the safety of the public, and if so, the necessary and appropriate disposition to manage that risk having regard to the criteria set out in section 672.54 of the Criminal Code.
Position of the Parties
At the outset of the hearing, the parties were canvassed as to their respective, without prejudice recommendations to the Board. The parties were joined in their position that Mr. Hobbs posed a significant threat to the safety of the public and that the necessary and appropriate disposition was that of a detention disposition on the same terms and conditions as were previously in place, with an expansion of the geographic area in which he may exercise privileges to include Southwestern Ontario.
All parties maintained their initial positions in their final submissions.
Index Offences
- The following synopsis of the Index Offences is taken from the previous Reasons for Disposition dated January 13, 2025, as follows:
“On April 7, 1998, the victim contacted police to complain that Mr. Hobbs had been constantly and repeatedly harassing her. She stated that on numerous occasions (approximately twenty different times) Mr. Hobbs approached her, tried to engage her in conversation, telling her that he loved her, that he wished to marry her and wanted her to have their children. The victim contacted police in January, at which time police spoke with Mr. Hobbs and advised him not to have any contact with the victim.
There was apparently no contact for approximately one to two months and then Mr. Hobbs began to harass her again. She encountered him repeatedly while walking her dog even though she varied her route and tried to avoid him. On April 7, 1998, Mr. Hobbs appeared at her residence at approximately 18:00 and 19:15 hours. He walked up the driveway and engaged in shouting at her husband. The victim stated that the more contact Mr. Hobbs had with her, the more aggressive he became, and she started to fear for her safety.
Police attended at Mr. Hobbs residence (a group home) and the operator advised the police that another tenant had reported overhearing Mr. Hobbs saying that he wished to kill the victim, that she does not deserve to live and that she is a pig. On police interview, Mr. Hobbs appeared aggressive, both verbally and physically and was arrested for criminal harassment.”
Background
The panel had before it several documents forming the Record as well as Exhibits including:
Revised Notice of Hearing dated December 1, 2025;
Disposition dated December 23, 2024;
Reasons for Disposition dated January 13, 2025; and
Hospital Report dated October 2, 2025, containing within it an Update current as of February 4, 2026.
The Hearing documents and Exhibits provide a great deal of information concerning Mr. Hobbs’ social, developmental, academic and legal background, mental health history, and progress while subject to the jurisdiction of the Board. It is not necessary to reproduce in detail the information contained within them. However, the following brief overview, excerpted from last year’s Reasons for Disposition, is provided for context to the panel’s decision:
Mr. Hobbs had a very difficult childhood. His father left the family shortly after his birth, and Mr. Hobbs and his older sister were sent to live with his grandparents. He also lived with his mother for some period. At about the age of 10, Mr. Hobbs was sent to a foster home in a small town near Kitchener because of his stepfather’s abuse towards him, possibly including sexual advances. This was the first in a series of foster and group homes in which Mr. Hobbs resided as an adolescent and young adult. Mr. Hobbs had difficulty establishing and maintaining relationships related to his limited social skills, including poor understanding of personal space and boundaries.
According to the Hospital Report, Mr. Hobbs’ first admission to hospital was at the age of seven, when he was admitted to the children’s unit of the hospital in Owen Sound. He was referred because of hitting peers at school, difficulty learning, being aggressive with his two-year-old sibling and overactivity. He was found to be distractable and was described as a child with some autistic behaviour.
Early on in his tenure under the jurisdiction of the Board, Mr. Hobbs was detained at the St. Thomas Psychiatric Hospital (as it then was). After a lengthy hospitalization, in February 2011, he was transitioned to live in a small Christian Horizons residence in Campbellville. The home was staffed 24-hours per day. In 2015, after several incidents of poor impulse control, verbal threats and physically aggressive and assaultive behaviour at the home (necessitating his admission and stabilization in hospital), Mr. Hobbs was ultimately discharged from the Christian Horizons home and returned to reside at the Southwest Centre.
In hospital, Mr. Hobbs experienced an increase in his paranoia and his behaviour deteriorated. At his annual hearing in December 2016, the Hospital recommended a transfer to Waypoint to manage his risk and stabilize him. The Board agreed, and in January 2017, Mr. Hobbs was admitted to the Awenda program at Waypoint.
Mr. Hobbs remained at Waypoint until he was transferred to Southwest Centre in March 2021. Mr. Hobbs has a well-documented history of angry, hostile, and intimidating behaviour, paranoia and verbal and physical outbursts.
In terms of his history, it is important to note that previous efforts to transition Mr. Hobbs’ to living in the community resulted in placement failure. He is stress-vulnerable and prone to misinterpreting information, leading to conflict with others, sexual preoccupation, sexual importuning, rapid escalation of threats and attribution of blame to others. He benefits from structured programing that is reward-based and which provides him with a sense of predictability and security. His mental stability is closely tied to his physical health.
Concerning the reporting period being considered: In January 2025, Mr. Hobbs was transferred from the treatment unit (B2) to the rehabilitation unit (B1) and Dr. Ardani assumed responsibility for Mr. Hobbs’ care. Mr. Hobbs remained on the rehabilitation unit until April 1, 2025, when he began transitioning to a 24/7 staff-supervised Community Living Elgin (CLE) group home pursuant to a 30-day leave of absence (LOA). The CLE home is funded via Developmental Services Ontario (DSO).
The Hospital Report notes that Mr. Hobbs expressed both anxiety and enthusiasm towards the prospect of leaving hospital and going to live at the CLE home. The initial 30-day LOA was extended after medication side-effects caused him to attend a local hospital three times.1Mr. Hobbs remained living in the community without readmission and on June 3, 2025, Mr. Hobbs’ care was discharged to a forensic outreach team at Southwest. Mr. Hobbs’ treatment has continued to be overseen by Dr. Ardani.
Since then, Mr. Hobbs has remained at the CLE home and has been able to follow the program schedule. He participates in the day program Monday to Friday. CLE provides transportation to and from their programming. Staff indicate he has a good rapport with them, and no concerns have been reported. He has a private room and enjoys several activities including watching YouTube videos and building model cars and rockets, activities that his group home is able to accommodate. He denies any auditory or visual hallucinations and the staff report no concerns. Staff report he is active in the home and helpful with chores. He is demonstrating increased independence by completing his chores with minimal assistance.
Clinically, Mr. Hobbs has had some periods of anxiety related to residual paranoia (for example, that he would be returned to Hospital or that he was being laughed at or talked about by others) and some short-term issues related to his finances which increased his anxiety and irritability but then subsided when the issues were resolved. Notably, he was able to cope by asking for reassurance from staff and requesting as-needed medication.
In November 2025, Mr. Hobbs broke his right first toe during a slip and fall at the CLE day program. The severity of the break was such that he needed an air cast boot and pain relief. Mr. Hobbs was able to weather the situation, including attending follow-up appointments at an orthopaedic outpatient clinic, without any deterioration in his mental status. This represented an improvement from previous years in which illness or injury would regularly result in an increase in symptoms of psychosis and a deterioration in his behaviours.
Mr. Hobbs’ insight into the index offence, diagnoses, need for treatment and potential to reoffend remains limited but is showing some areas of growth. He acknowledges that what he did was wrong and is able to identify some factors leading to up to it but is unable to appreciate how his behaviour affected the victim. He identifies that he has Schizophrenia and describes it as physical and emotional “torture”. He understands that this illness “is a lifetime thing” and that he takes medication to help alleviate his pain and suffering. He also identifies that he takes medication to lessen his sexual behaviour. He states he will continue to take his medication even after being discharged from the forensic system. He does not yet link his diagnoses to the index offence in a nuanced way but recognizes that his Schizophrenia “was in rougher shape back them”. He did not remember his other diagnoses but was aware he had them.
When asked if he believed he had the potential to re-offend, Mr. Hobbs responded in this fashion (p. 246 of the Hospital Report):
“No, I am positive thinker. Rose [victim of the index offence] won’t happen again because that was not right, and I am on medications now.”
- The Hospital Report (p. 246) also indicated that:
While denying any risk of re-offence, Mr. Hobbs continued to develop emotions towards strangers, including members of his treatment team over the recent years and shares his emotions with them. He continues to suffer from the inability to appreciate the psychotic nature of his feelings/misinterpretations, and the inappropriateness of his behaviours.
- The Hospital Report describes Mr. Hobbs’ re-offence scenario as follows (p. 252):
Absent forensic intervention, Mr. Hobbs would not follow his highly structured daily regime independently, which includes taking his medication and attending to his ADLs, as he requires extensive support and supervision to maintain adherence. Should he deviate from his routines, he would experience an increase in his paranoia and anxiety, mostly directed from a perceived social interaction. Due to his inability to cope with stressors, his mental state, already fragile, would rapidly deteriorate. He would experience more intense symptoms, including paranoia, and mis-interpret cues in the community; for example, he would develop erotomanic beliefs. He would exhibit increased disinhibited behaviours due to his intellectual disability in response to his delusional beliefs. He would behave similar to the time of the index offence and would pose the community at risk.
- Mr. Hobbs’ current diagnoses are schizophrenia, autism spectrum disorder, and intellectual developmental disorder. He is treatment-capable and cooperative with his medication regimen. Group home staff administer his oral medication.
Evidence at the Hearing
In addition to the documentary evidence, the Board also had the benefit of oral evidence from Mr. Hobbs’ forensic psychiatrist, Dr. A. Ardani. Dr. Ardani confirmed he was a signatory of the Hospital Report and its update and continued to endorse the findings and recommendations of the Hospital contained within those documents.
Dr. Ardani advised that the new home is well suited to Mr. Hobbs’ needs. Mr. Hobbs engages in repetitive behaviours that others would find stressful. Fortunately, the home he is residing in has a “recreation room” in the basement to which Mr. Hobbs has access and enjoys using. This room lessens the frequency of his contact with other residents of the home which has resulted in fewer conflicts. Dr. Ardani said the physical layout of the home, and Mr. Hobbs being permitted use of the basement for his hobbies, is a protective factor in terms of mitigating his potential to escalate in response to conflict or an increase in paranoid and persecutory ideation.
With respect to personal supports, Mr. Hobbs’ sister is an approved person and a strong support. She takes Mr. Hobbs out for day trips and they had a Christmas day visit. His sister reported that this was the most stable she had seen Mr. Hobbs in a long time, and that when worried or anxious, he was more easily reassured and re-directable. Mr. Hobbs has a roommate, and they seem to have a good relationship. Mr. Hobbs sees his DSO support worker, Isaiah, weekly.
Mr. Hobbs has a history of not being able to sustain community tenure, but at this time he enjoys where he is staying and is very motivated to avoid being returned to hospital by doing his best to “stay out of trouble”. It is Dr. Ardani’s view that this motivation would decrease absent a disposition detention.
Dr. Ardani confirmed that Mr. Hobbs’ insight remained “partial” and noted that the risk assessment (HCR-20) which was completed this year and is detailed at page 251-252 of the Hospital Report found Mr. Hobbs presents a low to moderate risk under a detention disposition, but should his liberties be increased, the risk of re-offending would be elevated.
He confirmed the re-offence scenario found in the Hospital Report, that, should Mr. Hobbs reside in the community without the current 24/7 supervision and support available to him currently he would be unlikely to adhere to his medications due to the complexity of his medication regimen (number of medications, dosing schedules) and his intellectual developmental disorder.
It was also noted by Dr. Ardani that historically Mr. Hobbs has been mostly unable to identify the symptoms of decompensation and he would act out based on his beliefs. He continues to carry some of these beliefs now and while not as severe as a delusional belief, nonetheless, as he is unable to identify them, he is unable to seek help in a timely fashion. Moreover, the nature of criminal harassment (psychological harm) limits the treatment team’s ability to act proactively. As such the Mental Health Act would not be sufficient to manage the risk.
In answer to questions from the Board, Dr. Ardani expanded on the support that Mr. Hobbs has been able to receive from his current group home and community partners, including funding for transportation to attend his CLE programs during weekdays and his support worker on weekends. It was also learned that two walkie-talkies are employed so Mr. Hobbs can remain in contact with the staff at the home should he be out in the community and wish to connect with any of the staff, or they with him.
Analysis and Conclusions
The Board concurs with the joint submission of the parties. Quite apart from the joint submission, the Board has no difficulty coming to an independent conclusion that Mr. Hobbs’ current constellation of symptoms and behaviours is such that he poses a significant threat to the safety of the public in accordance with the criteria set out in s. 672.5401 of the Criminal Code.
The Board accepts in their entirety, the clinical risk assessments and re-offence scenarios set out at pp 249-253 of the Hospital Report, as well as the uncontroverted expert evidence of Dr. Ardani.
Mr. Hobb’s risk flows from his diagnoses of schizophrenia, autism spectrum disorder, and intellectual developmental disorder. The evidence indicates Mr. Hobbs poses a low to moderate risk under continuous supervision and medication adherence with reminders but that the Hospital needs to maintain authority to rapidly readmit him upon his decompensation, threatened decompensation, or placement failure. The Board agrees with the Hospital Report that absent forensic oversight Mr. Hobbs would have “considerable difficulty organizing housing and professional support and making everyday decisions”. He also “lacks sufficient personal support to help mitigate his risk to the safety of the public” (p. 253 of the Hospital Report).
In turning to the appropriate disposition, the Board notes Mr. Hobbs has had good year overall and there are many positive aspects to his treatment over the reporting period. There has been clinical stability and adherence to treatment. These factors enabled him to successfully transition from a treatment unit to a rehabilitation unit (January 2025), to a community residence (April 2025) and Outreach (June 2025).
This staff-supported home in St. Thomas with a basement recreation room very much suits Mr. Hobbs’ needs. The walkie-talkie/s allows him independent movement up to a 2 km radius from the home and he has been able to attend CLE programs as well as maintain positive family contact with his sister. He has also been compliant with his medication regime, including clozapine, methotrimeprazine (antipsychotic medications), lithium (mood stabilizing medication) and cyporterone (anti-androgenic medication).
However, due to his cognitive limitations, Mr. Hobbs’ insight remains partial. His medication adherence has been made possible by the continuous support and supervision of staff who provide prompts due to Mr. Hobbs’ organizational limitations tied to his intellectual developmental disorder.
Mr. Hobbs’ community tenure is still in its infancy. Given the failure of past efforts to maintain his placement in the community, it is important to proceed cautiously; a further year of stability is necessary to monitor and support Mr. Hobbs’ ability to live safely outside of a hospital setting. The Hospital needs the ability to approve Mr. Hobbs’ accommodation, as this is a key factor in his risk management strategy and is only available within the context of a detetention disposition.
If Mr. Hobbs were not subject to a detention disposition, he would undoubtedly fall away from treatment and the civil commitment provisions Mental Health Act, being reactive in nature, would not be proactively protective of the safety of the public. When provoked, upset/irritated or physically unwell, Mr. Hobbs can escalate quickly; the Hospital needs the ability to intervene and admit him to hospital in the event of actual or threatened deterioration in his mental status or behaviours.
Thus, in considering the legal tests, including the needs of Mr. Hobbs and protection of the public, the Board finds that a conditional discharge disposition does not have an air of reality at this time. Mr. Hobbs continues to be in need of treatment and care to manage his mental health needs; these are best accomplished within the legal framework of a detention disposition and on the conditons recommended by the Hospital.
To Mr. Hobbs’ great credit, he has had an excellent year and is doing very well. The geographic expansion of privileges to include both Southern and Southwestern Ontario will allow Mr. Hobbs to broaden the places he can visit with his sister and his DSO worker. The Board wishes Mr. Hobbs well in his on-going recovery over the coming year.
In coming to this determination, the Board has considered the criteria set out in s. 672.54 of the Criminal Code, the paramount consideration being the safety of the public, the mental condition of Mr. Hobbs, his reintegration into society and his other needs.
DATED this 5^th^ day of May 2026, at the City of Toronto, in the Toronto Region.
Ms. T. Mann Alternate Chair
Office of the Registrar Ontario Review Board
Footnotes
- Mr. Hobbs experiences on-going constipation from clozapine (a known side-effect). The medication he had been prescribed while in hospital was no longer available to him in the community, as he lost coverage from ODSP when his LOA commenced. Substitute medication proved ineffective. Eventually the problem was resolved with the assistance of the Office of the Public Guardian and Trustee. Mr. Hobbs is now able to pay out-of-pocket for his medication.