Ontario Review Board
Re: Jonathan D. Lock
ORB File No: 7294
Hearing Held On: Wednesday, March 25, 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: Jonathan D. Lock
Counsel: Mr. R. Sherman
The person in charge of hospital: Counsel: Mr. K. Dow
Attorney General of Ontario: Counsel: Ms. J. Graham
REASONS FOR DISPOSITION
(Dated May 12, 2026)
OVERVIEW
- Jonathan D. Lock was found not criminally responsible on account of mental disorder on January 17, 2018, for the offences of aggravated assault, assault causing bodily harm, and failing to comply with probation, all contrary to the Criminal Code. He is currently subject to a disposition of the Ontario Review Board dated February 25, 2025, detaining him at the General Forensic Unit of the Centre for Addiction and Mental Health, Toronto (“CAMH”). The disposition includes privileges, including the ability to live within the community of the GTA, in accommodation approved by the person in charge.
ISSUES
On March 25, 2026, the Board convened at CAMH for a hearing further to s. 672.81(1) of the Criminal Code to review Mr. Lock’s disposition. The Board was asked to determine whether Mr. Lock 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, the parties all submitted a joint recommendation that Mr. Lock continues to represent a significant threat to the safety of the public and the necessary and appropriate disposition is a continuation of the current detention order, under the same conditions and privileges, with no change at this time.
FINDINGS
- After hearing the evidence, the Board found that Mr. Lock continues to pose a significant threat to public safety. Accordingly, the Board determined that the existing detention order remains the least onerous and least restrictive disposition capable of managing risk, protecting public safety, and supporting continued rehabilitation.
BACKGROUND
The Hospital Report dated March 10, 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.
On May 24, 2017, the first victim was crossing Eglinton Avenue at Yonge Street. Mr. Lock rushed past and then struck him, smashing a wine bottle on the right side of his face, causing a laceration to his right ear. The first victim subsequently attended at hospital and was treated for a laceration to his right ear and multiple small abrasions to the right side of his face. A short time later, as a second victim was walking, he felt Mr. Lock come from behind him and scratch his neck. He turned around and pushed Mr. Lock’s arm away. Mr. Lock was holding the stem of the broken wine bottle.
Mr. Lock is 49 years old. He began exhibiting problematic behaviour from a young age, reporting that he began stealing at the age of four and progressed to more serious offences, including break and enter, and robberies, by age 14, as well as participation in drug trafficking.
Throughout his adulthood, Mr. Lock worked primarily in the food service industry, though his employment history was marked by instability. He indicated that his shortest period of employment lasted three days, while his longest was approximately five years, which he attributed the terminations largely to his substance use. He struggled with a cocaine addiction for approximately ten years, including the use of both powdered and crack cocaine, and also reported a history of using ecstasy, marijuana, benzodiazepines, opiates, and heroin. Prior to his arrest in 2017, he had no fixed address and lived primarily in shelters.
A check of the Canadian Police Information Centre database indicates that Mr. Lock has a significant criminal record that includes convictions for robbery, assaults, drug offences and failing to comply with court orders. He has accumulated more than 50 adult convictions.
Mr. Lock first came into contact with psychiatric services in 2015, when he was prescribed antipsychotic medication while incarcerated. During that period, he was diagnosed with substance induced psychosis and ADHD. Following his release, he was initially followed by an Assertive Community Treatment (“ACT”) team in Barrie before transitioning to the ACT team at St. Michael’s Hospital in Toronto.
Records show that Mr. Lock experienced multiple hospital admissions. In 2017, police brought him to emergency departments after he exhibited symptoms consistent with psychosis. On each presentation, urine drug screens were positive for cocaine and either benzodiazepines or oxycodone. On at least one occasion, he had missed his scheduled antipsychotic injection and required both chemical and physical restraints. He has participated in multiple addiction treatment programs, including inpatient services in Elliot Lake and the Rainbow Program at CAMH.
Mr. Lock remained at CAMH, until his transition to supervised community living in November 2020. Since that time, he has required several readmissions related to positive urine drug screens and associated deterioration in his mental status. Mr. Lock had a substance-induced relapse in April 2025, which led to hospitalization until November 27, 2025. He demonstrates some improved insight into the connection between substance use and decompensation, and his primary ongoing risk factor remains relapse into stimulant use, which has historically precipitated rapid deterioration.
Mr. Lock’s current diagnoses are Schizophrenia, Stimulant Use Disorder (severe), and Antisocial Personality Traits, and Historical Diagnosis of Attention Deficit Hyperactivity Disorder (not currently meeting diagnostic criteria). Mr. Lock is currently capable of consenting to psychiatric treatment, and he is capable of managing his financial affairs. He receives financial support through the Ontario Disability Support Program.
EVIDENCE AT THE HEARING
The evidence at the hearing included comprehensive testimony from Dr. N. Ugwunze regarding Mr. Lock’s current mental health status, behaviour, and community placement.
Dr. Ugwunze testified that he has been Mr. Lock’s treating psychiatrist for nearly four years. The doctor advised that there had been no material updates since the Hospital Report. He indicated that Mr. Lock has remained in the community, has continued to engage appropriately with the treatment team, and that no new concerns have arisen during this period.
Dr. Ugwunze explained that the year under review had been marked by some challenges, particularly with respect to Mr. Lock’s substance use. He noted that Mr. Lock required admission to hospital in April 2025, following a relapse, and that his inpatient stay was prolonged, in part due to placement issues rather than clinical deterioration. Since then, Mr. Lock has returned to community living, has engaged with the treatment team, and has expressed a commitment to abstaining from substances, which he understands is a longstanding and essential component of his risk management. Dr. Ugwunze stated that he and the treatment team have been clear with Mr. Lock that sustained abstinence from substances is essential to maintaining his stability and mitigating risk.
Dr. Ugwunze stated that, notwithstanding difficulties related to substance use, Mr. Lock has demonstrated the capacity, over time, to live independently in the community. He indicated that the primary area of concern continues to be substance relapse and that, in the absence of substance use, the treatment team has not identified behavioural, or other safety concerns associated with his community living. Dr. Ugwunze testified that substance use is likely to trigger a decompensation in Mr. Lock’s mental state regardless of his ongoing compliance with his long-acting injection of antipsychotic medication.
Dr. Ugwunze emphasized that the primary risk for reoffence arises in the context of substance use relapse. He explained that when Mr. Lock abstains from substances and remains engaged with treatment, he has been able to live independently in the community without safety concerns. By contrast, periods of stimulant use have historically been associated with clinical destabilization and have necessitated hospitalization. In response to questions asked, the doctor noted that even when Mr. Lock has suffered a decompensation in his mental state, he has not incurred further criminal convictions. In his view, the risk of reoffence is situational rather than persistent, and is mitigated through continued treatment engagement, monitoring, and abstinence from substances. In the absence of relapse to substance use, Dr. Ugwunze did not identify elevated concern for offending while Mr. Lock resides in the community.
Finally, Dr. Ugwunze explained that, in light of Mr. Lock’s overall functioning and current stability, he was recommending no change to his existing disposition. He stated that continued structure, monitoring, and support remain appropriate, and that the current disposition adequately addresses both Mr. Lock’s clinical needs and public safety considerations.
ANALYSIS AND CONCLUSION
(a) Significant Threat
The Board must first determine whether Mr. Lock continues to pose a significant threat to the safety of the public as the term is defined in Winko v. British Columbia (Forensic Psychiatric Institute), 1999 CanLII 694 (SCC), [1999] 2 S.C.R. 625. In applying the test, the Board considers whether there is a real risk of serious physical or psychological harm to members of the public, including a pattern of behaviour that demonstrates a likelihood of such harm, having regard to the totality of the evidence.
The Board’s assessment is informed by the circumstances of the index offences and by Mr. Lock’s psychiatric and criminal history. The index offences occurred in the context of psychosis and substance use and involved unprovoked violence in a public setting. Mr. Lock has a history of repeated admissions, periods of medication, nonadherence, substance dependence, and behavioural instability when not in a structured environment. This history remains relevant to risk.
The Board accepts the evidence of Dr. Ugwunze and the Hospital Report that Mr. Lock’s psychiatric stability is closely linked to medication adherence, ongoing treatment engagement, and abstinence from substances. The evidence establishes that when Mr. Lock relapses into stimulant use, he is at risk of rapid clinical deterioration, which has historically required hospitalization and has been associated with increased risk-related behaviour.
While Mr. Lock has demonstrated periods of stability in the community with appropriate supports, the evidence also establishes that the primary ongoing risk factor remains substance relapse. In light of the seriousness of the index offences, Mr. Lock’s history of destabilization because of substance use, and the need for a structured framework to ensure monitoring and timely intervention, the Board is satisfied that Mr. Lock continues to pose a significant threat to the safety of the public.
(b) Necessary and Appropriate Disposition
Having found that Mr. Lock continues to pose a significant threat to public safety, the Board must determine the disposition that is necessary and appropriate in the circumstances. The disposition must be the least onerous and least restrictive option, which is capable of managing risk and protecting the public, while giving due consideration to Mr. Lock’s liberty interests, mental condition, and reintegration into society, as required by s. 672.54 of the Criminal Code.
The Board accepts that Mr. Lock has demonstrated stability during the review period while residing in approved, supervised accommodation since his most recent transition to the community in November 2025. He has remained at his clinical baseline, has engaged with the treatment team, and as described by Dr. Ugwunze, no new behavioural or safety concerns have arisen during periods of abstinence and treatment engagement. These are positive indicators of progress.
However, the evidence also establishes that material risk factors remain. Mr. Lock’s ongoing risk is driven primarily by relapse into stimulant use, which has historically precipitated rapid clinical destabilization and a need for re-hospitalization. The treatment team emphasized that sustained abstinence, close monitoring, and continued engagement with treatment are essential components of risk management. In these circumstances, the Board is not satisfied that a conditional discharge would provide a sufficient legal and clinical framework to manage the risk in the event of decompensation in the community.
The hospital must be in a position to retain oversight of Mr. Lock’s housing to ensure that it provides him with the requisite degree of support, supervision and structure to safely manage his risk profile. Further, in the context of propensity to relapse to substance use, the hospital must have the authority to rapidly intervene to effect his rehospitalization for the purpose of preventing escalating use and to restabilize Mr. Lock. For these specific reasons, at this point in time a conditional discharge is premature. A detention order is required until a longer period of stability has been established in order to protect the public and ensure Mr. Lock’s stability in the community.
The evidence supports that Mr. Lock’s stability and public safety are best maintained through a structured disposition that includes ongoing supervision, monitoring, and supports approved by the person in charge.
The Board therefore finds that a continuation of the existing detention order remains the least onerous and least restrictive disposition capable of adequately managing the risk posed by Mr. Lock to the safety of the public, while supporting his ongoing rehabilitation and supervised community living. The current disposition appropriately balances public safety with Mr. Lock’s treatment needs and liberty interests. The Board orders that the detention order continue, with no change at this time.
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