Ontario Review Board
Re: Adoum Issa
ORB File No: 7903
Hearing Held On: Tuesday, March 24, 2026
Place of Hearing: Centre for Addiction and Mental Health
Pursuant To: Section 672.81(1) of the Criminal Code
Before: Alternate Chairperson: Ms. L. Banks Members: Dr. S. Lessard Dr. J. Cheston Ms. A. La Viola Mr. J. Cyr
Parties Appearing: Accused: Adoum Issa Counsel: Mr. M. Schloss The person in charge of hospital: Representative: Dr. T. Wilkie Attorney General of Ontario: Counsel: Ms. J. Graham
REASONS FOR DISPOSITION
(Dated May 12, 2026)
OVERVIEW
- Adoum Issa was found not criminally responsible on account of mental disorder on June 15, 2021, for the offences of assault causing bodily harm, and fail to comply with probation, contrary to the Criminal Code. He is subject to a disposition of the Ontario Review Board dated March 26, 2025, currently detaining him within the General Forensic Unit of the Centre for Addiction and Mental Health, Toronto (“CAMH”). The disposition allows Mr. Issa privileges, including the ability to live within the community in accommodation approved by the person in charge.
ISSUES
On March 24, 2026, the Board convened at CAMH for a hearing further to s. 672.81(1) of the Criminal Code to review the disposition. The Board was asked to determine whether Mr. Issa represented a significant threat to the safety of the public at the time of the hearing, and further, what the necessary and appropriate disposition is in the circumstances according to the factors set out in s. 672.54 of the Criminal Code.
At the outset of the hearing, Counsel for Mr. Issa indicated that he had instructions to proceed with the hearing on behalf of Mr. Issa, and that the reason for Mr. Issa’s absence was that he finds the proceedings very stressful. The Board issued an order under s. 672.5(10)(a) of the Criminal Code permitting Mr. Issa to be absent from the hearing.
The Hospital, along with Counsel for the Attorney General, submitted that Mr. Issa continues to represent a significant threat to the safety of the public, and recommended that the necessary and appropriate disposition is a continuation of the current detention order, under the same conditions and privileges, with a reduction to reporting not less than once every two weeks. Counsel for Mr. Issa took the position that a conditional discharge is the least onerous, least restrictive disposition, and that Mr. Issa would consent to a community treatment order under s. 672.55 of the Criminal Code, and he provided an address for proposed residential housing. Counsel also requested passes for travel in Ontario, Quebec, and international travel to visit family in Africa with an approved itinerary.
FINDINGS
- After hearing the evidence, the Board found that Mr. Issa continues to pose a significant threat to public safety. The necessary and appropriate disposition is continued detention order, with the ability to live in the community, in approved supervised accommodations, and a reduction in the reporting requirements, and the addition of travel passes as outlined in the disposition.
BACKGROUND
The Hospital Report dated March 2, 2026, was entered as an exhibit at the hearing. The following information, including the events surrounding the index offences, has been taken from the Hospital Report, summarized here as follows.
At the time of the index offences, Mr. Issa lived in a rooming house with other tenants where they each rented a room and shared a kitchen and bathroom. On April 9, 2018, Mr. Issa went into the victim’s room in the rooming house, and without provocation, stabbed him three times with a kitchen knife that was approximately seven inches long. The victim sustained one laceration to his back and two lacerations to his chest and was transported to hospital. At the time of the incident, Mr. Issa was on probation from convictions of robbery with a weapon, disarming a peace officer, and obstructing a peace officer.
Mr. Issa was born in Saudi Arabia and spent his early childhood there before relocating to Africa with his father and siblings when he was about five years old. He described his upbringing as positive, noting a devout Muslim family and a supportive home environment, though discipline in the form of physical punishment was common in his community. He attended school up to Grade 12, later finishing high school after immigrating to Canada.
In adulthood, Mr. Issa worked intermittently in warehouses and restaurants, which lasted approximately three months. Regarding substance use, he reported drinking small amounts of beer socially and using cannabis occasionally. Collateral information indicates that cannabis was found in his residence on at least one occasion, and he has previously tested positive for cannabis during hospital admissions, though he has denied problematic use or connection between substances and his mental state.
A check of the Canadian Police Information Centre database shows that Mr. Issa’s first involvement in the criminal justice system was in 2016, with subsequent convictions for offences of robbery with a weapon, disarming a peace officer, and obstructing a peace officer, resulting in custodial and community sentences. His legal difficulties continued into 2018, culminating in the index offences.
The documented psychiatric history dates back to approximately 2016, characterized by auditory hallucinations, visual phenomena, religious and referential delusions. Mr. Issa has required multiple psychiatric admissions since 2018, and he has consistently demonstrated limited insight into his illness. He frequently denies having any mental disorder.
Mr. Issa’s current diagnosis is Schizophrenia. He is currently incapable of making decisions about his psychiatric treatment and his brother is his substitute decision maker. He has been found incapable of managing his financial affairs. He receives financial support through the Ontario Disability Support Program.
For the most part of the clinical course over the current reporting year, Mr. Issa’s behaviour has been stable, with no episodes of psychosis, or physical aggression. However, on June 3, 2025, his indirectly supervised passes were suspended following an incident of sexually inappropriate behaviour (exposure of his genitals to female staff). As a result, his passes were reduced to escorted passes only.
In August 2025, Mr. Issa transitioned to approved, 24/7 supervised community living. Since that time, he has resided in a structured, supportive setting and has complied with his disposition, including regular reporting to the treatment team. He has adjusted well to community living, managing daily routines with support and maintaining stability without any reported concerns regarding substance use, safety, or community functioning. Although his insight into his mental illness remains limited, he has been cooperative with treatment and has maintained an organized routine.
EVIDENCE AT THE HEARING
The evidence at the hearing included comprehensive testimony from Dr. T. Wilkie regarding Mr. Issa’s current mental health status, behaviour and updates regarding his recent transition to community living.
Dr. Wilkie testified in her capacity as Mr. Issa’s outpatient psychiatrist in the Forensic Outpatient Program. She stated that Mr. Issa has had a significant year, having transitioned from the inpatient unit to a 24-hour supervised community residence, where he has functioned well. Dr. Wilkie identified three updates. Mr. Issa has now received a renewed work permit, discussions are underway regarding increased housing independence, and there may be changes to his medication regimen over the coming year.
With respect to potential employment, Dr. Wilkie testified that Mr. Issa had not sought work while waiting for his work permit, but since receiving it has contacted employment services as a top priority for him. Dr. Wilkie noted that Mr. Issa has not worked in a long time and has prominent negative symptoms of schizophrenia, such that employment, although beneficial, it could also prove stressful and will require monitoring.
Regarding housing, Dr. Wilkie stated that Mr. Issa has expressed a desire for greater independence. Mr. Issa currently manages his activities of daily living independently and functions well in his current residence. An occupational therapy assessment is planned to reassess the level of support required, as a prior inpatient assessment recommended a high level of supervision, which may no longer be necessary. Dr. Wilkie testified that less supervised housing options may be available through the same housing provider. At present, on site staffing provides medication supervision and regular observation. Dr. Wilkie emphasized that while Mr. Issa has done well in his current placement, reassessment is necessary to determine what level of supervision is appropriate going forward.
In relation to treatment, Dr. Wilkie testified that Mr. Issa meets regularly with the outpatient team, and he began individual therapy with a psychologist in January 2026. Therapy focuses on understanding Mr. Issa’s internal experiences and whether residual psychotic symptoms persist, as his speech and interactions can at times be unusual or bordering on bizarre. Dr. Wilkie described Mr. Issa as responsive to treatment, but further assessment of residual symptoms is also necessary.
Dr. Wilkie testified that Mr. Issa denies hallucinations, though some of his descriptions of internal experiences (such as perceiving ‘spirits’) are difficult to interpret. There has been no aggressive behaviour in the community and no sexually inappropriate behaviour reported since his transition to the community. The prior inpatient incident of sexualized behaviour occurred in the context of medication change and has not recurred.
With respect to medication, Dr. Wilkie stated that Mr. Issa receives a long-acting injectable, and an oral antipsychotic medication, which was added following deterioration during a prior medication change. Mr. Issa has expressed a desire to take oral medication independently, or he will discontinue it. Any change would require consultation with his substitute decision maker and careful monitoring, particularly in light of potential housing and employment changes.
Dr. Wilkie testified that Mr. Issa has remained abstinent from substances, with negative urine drug screens and no reported cravings since his transition to the community. However, substance use remains a salient risk factor requiring ongoing monitoring.
Regarding travel, Dr. Wilkie stated that Mr. Issa has family in Montreal and maintains contact with family in Chad, Africa, and that he is engaged to a woman in Cameroon. His statements about travel fluctuate, and there has been no detailed planning. Dr. Wilkie testified that she would not support overseas travel in the coming year and that any travel would require detailed planning to ensure stability and risk management. She expressed uncertainty about whether Mr. Issa would agree to a voluntary hospitalization were he to deteriorate, emphasizing the importance of the hospital’s ability to intervene at an early juncture to effect a rehospitalization, if necessary.
Finally, Dr. Wilkie testified that although Mr. Issa has transitioned well to the community, anticipated changes in housing, employment, and medication, combined with limited insight and potential destabilizing factors, require that the authority to approve accommodation and intervene promptly. Dr. Wilkie stated that a detention order remains necessary at this juncture for appropriate risk management.
SUBMISSIONS
Dr. Wilkie submitted that while Mr. Issa is presently stable, his stability has occurred within a structured and supervised framework. A less restrictive disposition would remove critical safeguards at a time when flexibility and rapid intervention may be required. With respect to travel, overseas travel is not supported by the treatment team at this time. Any consideration of out of province travel would require detailed information and safeguards, and there is insufficient information to support such travel.
Counsel for the Attorney General acknowledged that Mr. Issa has had a positive year and that his engagement with the outpatient team has been appropriate. However, the evidence demonstrates that Mr. Issa is likely facing a number of stressful transitions in the coming months. The concern is that, should decompensation occur, the hospital’s ability to intervene quickly is essential for risk management purposes. Continued oversight ensures that appropriate mechanisms are in place to address risk should Mr. Issa’s mental state deteriorate. Accordingly, the disposition should maintain sufficient structure and oversight, consistent with the Hospital’s recommendation.
Counsel for Mr. Issa submitted that a conditional discharge is the appropriate disposition. Mr. Issa has been stable in the community, has not engaged in violence or aggression since the index offence, has abstained from substances, and has complied with treatment. There are no acute concerns identified in the evidence. Further, the existing legal mechanisms provide adequate safeguards. Should Mr. Issa decompensate, the Mental Health Act, including Box B criteria for substantial mental deterioration, would permit hospitalization even without consent. Breach provisions are also available should conditions not be followed. With respect to housing, Counsel submitted that a conditional discharge could specify Mr. Issa’s current residence, and if circumstances were to change following an occupational therapy assessment, an early review hearing could be requested to allow for alternative housing to be identified. Counsel submitted that these measures provide flexibility while respecting Mr. Issa’s liberty interests and continued stability in the community.
ANALYSIS AND CONCLUSION
(a) Significant Threat
The Board must first determine whether Mr. Issa continues to pose a significant threat to the safety of the public, as defined in Winko v. British Columbia (Forensic Psychiatric Institute), 1999 CanLII 694 (SCC), [1999] 2 S.C.R. 625. This determination must be made based on the totality of the evidence before the Board, including the Hospital Report, the viva voce testimony of Dr. Wilkie, and Mr. Issa’s current clinical and functional presentation.
Mr. Issa was found not criminally responsible on account of mental disorder for serious violent offences, including assault causing bodily harm involving the use of a knife. The index offences occurred in the context of untreated psychosis, limited insight into his illness, and non‑compliance with legal and clinical supervision. The violence was unprovoked and resulted in significant injury to the victim. This history remains a relevant and material risk factor in assessing the potential threat to public safety.
The Board accepts that Mr. Issa carries a longstanding diagnosis of Schizophrenia, manifested by psychotic symptoms including hallucinations and delusional beliefs. Although he has shown significant clinical improvement over the past year, the evidence establishes that this stability has been achieved within a highly structured and closely supervised treatment environment, supported by consistent medication management and therapeutic oversight.
While Mr. Issa has remained stable in the community, the Board finds that this stability is provisional. His insight into his mental illness remains limited, and his history reflects a pattern of minimizing or denying psychiatric symptoms. The Board accepts that adherence to antipsychotic medication, abstinence from substances, and ongoing clinical monitoring continue to be essential protective factors for Mr. Issa, and in their absence, the risk of psychiatric decompensation would increase.
The Board further accepts that Mr. Issa is presently entering a period of anticipated transition, including potential increases in housing independence, engagement in employment, and possible adjustments to his medication regimen. While these developments are positive and consistent with his rehabilitation trajectory, they also introduce new stressors and elements of uncertainty that must be given due consideration when balancing Mr. Issa’s individual needs with the overriding factor, which is public safety.
In these circumstances, the Board is satisfied that Mr. Issa continues to pose a significant threat to the safety of the public at this time, within the meaning of Winko, absent the ongoing structure and oversight provided by his disposition.
(b) Necessary and Appropriate
Having found that Mr. Issa continues to pose a significant threat to public safety, the Board must determine the disposition that is necessary and appropriate in the circumstances, in accordance with s. 672.54 of the Criminal Code. In doing so, the Board must select the least onerous and least restrictive disposition capable of adequately managing the risk, having regard to the paramount concern for public safety, Mr. Issa’s mental condition, his reintegration into society, and his other needs.
The Board carefully considered whether a conditional discharge would meet these statutory requirements. A conditional discharge would require that the risk posed by Mr. Issa could be adequately managed in the community without the ongoing authority of a detention order. While the Board acknowledges the substantial progress Mr. Issa has made, the evidence does not support a finding that a conditional discharge would be sufficient at this time.
The evidence establishes that Mr. Issa’s current stability has been achieved within a framework of structured supervision, including approved accommodation with onsite staffing, medication oversight, and regular monitoring by the forensic outpatient team. Although Mr. Issa has functioned well in this environment, his insight into his illness remains limited, and his history demonstrates a pattern of minimizing psychiatric symptoms and questioning the need for treatment. The Board accepts the evidence that medication adherence, abstinence from substances, and early clinical intervention remain essential protective factors.
The Board also acknowledges Mr. Issa’s stated desire for greater independence, including increased autonomy in housing, employment, and treatment decisions. These goals are consistent with recovery and rehabilitation. However, the evidence establishes that Mr. Issa’s current level of stability has not yet been demonstrated in the absence of supervision, and that the risks associated with reduced oversight have not been sufficiently mitigated at this stage.
The Board also places significant weight on the fact that Mr. Issa is entering a period of potential transition. The evidence indicates that changes may be forthcoming in housing independence, employment, and medication regimen. While these developments are consistent with rehabilitation, they also introduce additional stressors and uncertainty. In these circumstances, it is important to retain the authority to approve accommodation and intervene promptly and at an early juncture should Mr. Issa’s mental state deteriorate, or risk factors emerge. A conditional discharge would materially limit that capacity.
For these reasons, the Board is not satisfied that a conditional discharge would adequately address the risk posed by Mr. Issa at this time. The Board finds that a detention order remains the least onerous and least restrictive disposition capable of managing that risk, while still permitting meaningful community living, graduated increases in independence, and continued rehabilitation under appropriate supervision. The necessary and appropriate disposition is therefore a continuation of the existing detention order, with a reduction in the reporting requirements to not less than once every two weeks or as directed, and including travel passes for up to 14 days, accompanied by an approved person, or indirectly supervised, to the Province of Quebec, for the purpose of visiting family members, subject to prior approval of an itinerary by the person in charge of the hospital.
DATED this 12th day of May, 2026, at the City of Toronto, in the Toronto Region.
Ms. A. La Viola Legal Member
__________________ Office of the Registrar Ontario Review Board