Re Evan Little, 2026 CanLII 51053

Re: Evan Little

ORB File No: 7910

Hearing held on: Wednesday, May 13, 2026

Place of hearing: Ontario Shores Centre for Mental Health Sciences 700 Gordon Street, Whitby

Pursuant to: Section 672.81(2) of the Criminal Code

Before: Alternate Chairperson: Ms. C. Finley Members: Dr. P. Prendergast Ms. L. Banks

Parties Appearing: Accused: Evan Little Counsel: Mr. D. Medd

The person in charge of hospital: Counsel: Mr. K. Dow

Attorney General of Ontario: Counsel: Ms. N. MacDonald

REASONS FOR DISPOSITION

(Dated May 27, 2026)

Introduction

1On June 28, 2021, Evan Little was found not criminally responsible on account of mental disorder on two counts of dangerous operation of a motor vehicle causing death, contrary to the Criminal Code of Canada. He is currently subject to a disposition of the Ontario Review Board (ORB/the Board) dated October 20, 2025, discharging him with conditions including that he abstain from the consumption of alcohol or drugs, including cannabinoids, and that he consent to take medications as prescribed, pursuant to s. 672.55(1) of the Criminal Code. He is currently under the supervision of the Forensic Outpatient Service at Ontario Shores Centre for Mental Health Sciences (Ontario Shores/the hospital).

2On May 1, 2026, the ORB received an email from counsel for Ontario Shores, requesting an early hearing pursuant to s. 672.81(2) of the Criminal Code. As a result of that request, the Board convened a hearing at Ontario Shores on May 13, 2026. Mr. Little was present and represented by his counsel, Mr. Medd. Three of the victims’ family also were in attendance.

3At the outset of the proceedings, all parties were canvassed as to their positions on the two issues to be determined by the Board: whether Mr. Little remains a significant threat to the safety of the public, and if so, the necessary and appropriate disposition having regard to the criteria set out in s. 672.54 of the Criminal Code.

4Mr. Dow, on behalf of the hospital, submitted that Mr. Little remains a significant threat to the safety of the public and the necessary and appropriate disposition is a detention order with discretionary privileges up to and including the ability to reside in the community in approved accommodations. Ms. McDonald, on behalf of the Ministry of the Attorney General, concurred in the hospital’s positions. Mr. Medd specifically conceded that Mr. Little currently remains a significant threat. He submitted that the current disposition, a discharge with conditions should continue.

Findings

5For the reasons that follow, the panel found that Mr. Little remains a significant threat to the safety of the public and the necessary and appropriate disposition is a detention order with the terms and conditions as recommended by the hospital.

The Evidence

6The evidence at the hearing consisted of the Hospital Report dated May 7, 2026 (ex. 1), the viva voce evidence of Dr. Pallandi, Mr. Little’s forensic outpatient treating psychiatrist, a number of Patient Progress Notes between March 25, 2026 and May 12, 2026 (collectively ex. 5), and victim impact statements from Andrew Prins, Barbara Prins and Hanna Ruth Prins.

The Index Offences

7The following is a summary of the index offences as detailed in the Hospital Report at pp. 2-4. On September 19, 2017, Mr. Little was driving at a high rate of speed westbound on Ravenshoe Rd., east of Woodbine Ave. in Georgina, Ontario. While attempting to pass a vehicle, Mr. Little’s car clipped the side of a truck. Mr. Little’s car became airborne and collided head on with the victims’ vehicle. This caused a chain reaction involving five other vehicles. The multiple collisions caused two fatalities, multiple injuries, and a large debris field of roughly 160 metres.

Background Information

8The Hospital Report includes details of Mr. Little’s personal background and psychiatric history and need not be reviewed in detail in these reasons beyond the following material points.

9Mr. Little is a 34-year-old married man with no children. At the age of 15, he was diagnosed with “Wegener’s disease”¹ a rare autoimmune disorder. He graduated from high school and attended Queen’s University where he studied engineering. During that time, he developed a depressed mood and intractable headaches. An MRI of his head revealed a pineal cyst with “evidence of remote hemorrhage”. In May 2015, contrary to the advice of his Canadian treating physicians, he underwent neurosurgery in Texas to remove the cyst.

10Following his neurosurgery, Mr. Little’s friends and family noted gradual changes in his personality and behaviour leading up to the time of the accident. Mr. Little became socially isolated, more irritable, agitated and impulsive. Cognitively, Mr. Little presented as increasingly confused. He related ideas of reference, describing the television talking to him. He also reported experiencing visual hallucinations and unusual somatic experiences.

11Following the accident referenced in the index offences, Mr. Little underwent multiple surgeries. In October 2017, he began exhibiting psychotic symptoms including auditory hallucinations, delusions, paranoia, bizarre behaviours and thought form disorganization.

12Between October 2017 and May 2021, Mr. Little had multiple admissions to hospital pursuant to the Mental Health Act following being brought to hospital by police. The police had been contacted by Mr. Little’s family after his seemingly unprovoked physical aggression.² Upon admission, he frequently appeared agitated and paranoid in the context of suspected noncompliance with medication and or substance use.

13During this time, Mr. Little was supported by a psychiatrist with the Ross Memorial Hospital and his family physician. In March 2021, Mr. Little was discharged from hospital and agreed to enter into a Community Treatment Order. Mr. Little also was receiving support from the Traumatic Brain Injury Association of Peterborough and a community psychotherapist.

14Following his NCR verdict in June 2021, Mr. Little came under the care and supervision of the Ontario Shores Forensic Outpatient Service (FOS). He resided with his parents in the community. During the first few weeks, Mr. Little was co-operative with the treatment team and provided urine drug screens (UDS) per his Disposition. All of these UDS returned as positive for cannabis. On November 23, 2021, Mr. Little was admitted to hospital for detoxification and monitoring. He was discharged back to his parents’ residence in January 2022.

15Shortly after his discharge, Mr. Little’s oral antipsychotic medication was changed to a long-acting injectable form, administered every three months. During this period, Mr. Little was cooperative with the treatment team, and adherent to his medication. All urine drug screens were negative. He continued to enjoy support from both of his parents and his older sister. In September 2022, he moved to a CMHA supported apartment in Peterborough.

16In 2023, Mr. Little had two admissions to hospital following a deterioration in his mental status: from January 20, 2023 to February 14, 2023, and then from February 17, 2023 to June 19, 2023. In January 2023, Mr. Little’s clinician observed a dramatic deterioration in his mental status over the course of a week. He was transported to hospital with the assistance of police. Mr. Little appeared thought disordered and paranoid. He was responding to internal stimuli and harboring thoughts to harm others. The cause of this deterioration was believed to be a combination of perceived stressors within his family and problematic administration of his medication by his Community Treatment Order team. The decision was made to change his long-acting form of antipsychotic medication to monthly doses.

17Within days of his discharge, Mr. Little once again became very unwell and was brought to hospital by police for readmission. He presented as paranoid and floridly psychotic. It was thought that his long-acting medication was wearing off prematurely. Mr. Little agreed to receive his medication on a more frequent basis and at a higher dosage. Over the following months, Mr. Little’s mental status slowly returned to his baseline, and he was discharged from hospital in June 2023.

18Over the next two years, Mr. Little’s mental illness appeared to be well-managed with the support of the FOS team. In December 2024, Mr. Little travelled to the Philippines to be married. He returned with his wife in January 2025.

Course Since the Last Disposition

19Mr. Little’s current diagnoses are:

Psychotic disorder due to another medical condition (with delusions) Unspecified major neurocognitive disorder Substance use disorders (cannabis, alcohol, stimulants and hallucinogens – in remission) Personality change due to another medical condition

20Mr. Little remains capable of making treatment decisions. He is currently being treated with the oral antipsychotic medication paliperidone.

21Mr. Little has continued to reside with his wife in Peterborough in a one-bedroom apartment. He is financially supported by a combination of Ontario Disability Support and insurance payments resulting from his injuries from the accident. He expressed an intention to return to school.

22On March 24, 2026, Mr. Little had a virtual meeting with his treating forensic psychiatrist, Dr Pallandi. Mr. Little reported that he had used alcohol and cannabis and had been having difficulty sleeping. His wife, who was present during the appointment, reported that Mr. Little had been having “episodes” where he was acting suspicious and paranoid towards her, his family members and some neighbours. In response to the heightened concerns, the FOS team increased their supervision to daily visits.

23Two days later, the team determined that Mr. Little needed to be admitted to hospital for detoxification and stabilization as his insomnia and cannabis use was continuing and he was well off his baseline. Mr. Little was admitted pursuant to a Form 1 under the Mental Health Act³ and extended by a Form 3 and then a Form 4 until his discharge on April 28, 2026. His urine drug screens were positive for cannabinoids. Some samples were notably diluted, raising the possibility that the samples had been tampered. While in hospital, Mr. Little was guarded and isolative and, on occasion, challenging and paranoid during interactions with staff.

24Dr. Pallandi testified before the Board. He indicated that he has been Mr. Little’s treating psychiatrist for quite some time. Consequently, he has had the opportunity to see Mr. Little when he is doing well in the community and while he has experienced a deterioration in his mental status. Before the end of March 2026, Mr. Little had been doing well and was making good progress.

25On March 24, 2026, Mr. Little was observed to have a significant deterioration in his mental state. He was expressing paranoia directed at his wife. Possible reasons for such a deterioration included substance use (alcohol and cannabis), insomnia, noncompliance with medication, and some environmental stressors. The changes were of such a magnitude and the treatment team’s concern so heightened that Mr. Little was admitted to hospital for stabilization, detoxification and clarification of the cause(s) of the change in his mental state.

26During his admission, Mr. Little was compliant with medication and abstained from the use of substances. All of his urine drug screens were negative. By April 28, 2026, he had improved significantly and his wife expressed a desire for him to be discharged back to their home. However, he still was not back at his baseline. Dr. Pallandi stated that there were concerns that he may have been tampering with his urine samples as they appeared to be dilute. Further, Mr. Little presented as somewhat guarded with ongoing paranoia, albeit at a reduced level. Dr Pallandi testified that Mr. Little was uncharacteristically short and abrupt with him when he was being discharged. In the doctor’s opinion, this was indicative of ongoing residual psychotic symptoms. Notwithstanding that Mr. Little was not yet returned to his baseline presentation, the team determined that Mr. Little was suitable for discharge.

27The next day, Mr. Little’s wife contacted Mr. Little’s clinician and reported that he was acting out of character, accusing her of infidelity, accusing his mother and sister of abusing him many years ago and accusing the pastor of their church of cursing at him. Mr. Little’s family were concerned about his wife’s safety. The clinician attended at the Littles’ apartment that day and observed that Mr. Little remained quite psychotic.

28Notably, Mr. Little’s wife indicated that she was actually fearful of him which was not something that she had indicated in the past. His parents also expressed concern for his wife’s safety and that they believed that he may have been noncompliant with medication. Mr. Little had switched to oral medication before his trip to the Philippines and had opted to continue with that form after his return. Dr. Pallandi testified that this information from Mr. Little’s family heightened the team’s concerns.

29Dr. Pallandi issued a Form 1 under the Mental Health Act. The team had concerns for their own safety and requested that the police bring Mr. Little to hospital for admission. On May 1, 2026, Mr. Little was brought to Peterborough Health Centre and then transferred to Ontario Shores the next day. Upon admission, Mr. Little endorsed delusions and paranoia, including accusations of his wife’s infidelity, his parents and sister sexually abusing him and of his upstairs neighbours deliberately making noise to aggravate him. There was significant concern that Mr. Little would act out aggressively in response to these perceptions.

30Dr. Pallandi testified that Mr. Little is slowly improving. He has been compliant with treatment and cooperative with the treatment team and his inpatient forensic psychiatrist Dr. Wong. There have been no concerns that Mr. Little has been using substances. In Dr. Pallandi’s assessment, Mr. Little has not yet returned to his baseline. Further, his insight was characterised as “poor” and he minimized his experience of psychotic symptoms. Given the concerns about Mr. Little’s possible noncompliance with medication, discussions about resuming long-acting injectable medication will likely occur between Mr. Little and Dr. Wong.

31When asked if he believed Mr. Little would stay in hospital as a voluntary patient, Dr. Pallandi testified that when Mr. Little is well he is agreeable to following the team’s recommendations. However, when he is experiencing paranoia, including paranoia in relation to members of the treatment team, Mr. Little may not be willing to follow recommendations nor be amenable to cooperating with the team.

32Dr. Pallandi testified that the Mental Health Act is not sufficient to manage Mr. Little’s heightened risk in the community at this juncture. The hospital presently requires the ability to admit Mr. Little quickly before his risk rises to the level required under the Mental Health Act for an involuntary admission. Further, the hospital requires the ability to keep Mr. Little in hospital until he has been stabilized and he has returned to his baseline. The recent admissions underscore this requirement. The risk to the safety of his wife, his family and his neighbours is heightened when he is experiencing a deterioration in his mental status.

33Dr. Pallandi testified that a detention order is also necessary and appropriate in order to allow the hospital to approve Mr. Little’s accommodation in the community. At this point, it is not known where Mr. Little plans to reside. Mr. Little’s parents have advised the current treatment team that they are not supportive of their son returning to reside with him. Mr. Little’s parents and his wife have voiced safety concerns. In the most recent inpatient progress report, there is a note that Mr. Little’s wife did not want the team to provide Mr. Little with her phone number. Given his delusions, Mr. Little may not choose to return to reside with his wife or his parents. Those delusions have attenuated somewhat during his readmission but they have not entirely resolved. At present, Mr. Little’s residence in the community remains an open question.

34In response to questions from Mr. Medd, Dr. Pallandi indicated that before his admission to hospital in March, Mr. Little had received three injections for treatment for his autoimmune disease under the supervision of a rheumatologist at Sunnybrook Hospital. Although some patients with this condition have experienced disruptions with sleep, Mr. Little did not appear to experience any side effects from those injections and appeared to tolerate them well.

35Dr. Pallandi agreed that on March 24, 2026, Mr. Little voluntarily attended the hospital in the company of his clinician. At that point, Mr. Little’s wife had not raised any concerns about her safety but was concerned about Mr. Little’s well-being.

36In response to questions from the panel, Dr. Pallandi agreed that there were three areas of concern that impacted on Mr. Little’s risk to the safety of the public. The first relates to Mr. Little’s delusions of his wife’s infidelity and the potential heightened risk to her. This risk is new and continues even when his wife indicates that she has no concerns for her own safety.

37The second new area of concern relates to Mr. Little’s delusions about his perception that he suffered previous sexual abuse perpetrated by his parents. As with the previously described delusion, this is a new area of concern that raises a new risk factor that will need to be evaluated and closely monitored.

38The third risk relates to Mr. Little’s physical condition and his “vulnerable brain”. Accepting that Mr. Little’s immunotherapy may have contributed to his deterioration, this too merits close examination and supervision. All three issues add to his current risk profile and will require ongoing assessment and monitoring. Given the number of unknowns in relation to the cause of his deterioration and the increase in his risk, the hospital requires the ability to approve his residence when he is ready for discharge.

39Dr. Pallandi agreed that when unwell, Mr. Little has demonstrated the capacity for physical aggression. Notably, when the treatment team met with Mr. Little on May 12, 2026, they were accompanied by security due to Mr. Little’s level of irritability.

40Mr. and Mrs. Prins and their daughter read their Victim Impact Statements. Clearly the victims of the index offences were loving parents who contributed significantly to their community. The profound loss continues to be felt acutely by their family.

41No further evidence was called by the parties. All parties maintained their initial positions in closing submissions.

Analysis and Conclusion

42The panel carefully considered the Hospital Report, the patient’s hospital records, and the evidence of Dr. Pallandi and unanimously concluded that Mr. Little remains a significant threat to the safety of the public. Although the panel acknowledged the joint submission on the issue of significant threat, the panel considered the issue independently.

43Mr. Little first experienced psychotic symptoms following his neurological surgery in 2015. His current diagnoses are psychotic disorder due to another medical condition (delusions), unspecified major neurocognitive disorder, substance use disorder and personality change due to another medical condition. Mr. Little had several psychiatric admissions in the context of treatment nonadherence, substance use, psychotic symptoms, and violent behaviour, most, if not all, subsequent to the index offences.

44During the past several months, Mr. Little has experienced a dramatic deterioration in his mental status. He has expressed delusions and paranoia that currently relate to his wife, his family and his neighbours causing him harm. The treatment team currently is working to identify what factors contributed to this decline. Medication noncompliance, substance use, sleep disruption and/or environmental stressors are all possibilities. When Mr. Little is well, he is calm, agreeable and unassuming. However, when he is unwell, he has been aggressive, violent, irritable and impulsive. His family and the treatment team have expressed concerns for their safety. Mr. Little remains a significant threat to the safety of the public.

45Having found that Mr. Little represents a significant threat to the safety of the public, the panel must consider the necessary and appropriate disposition taking into consideration the criteria set out in s. 672.54 of the Criminal Code, which includes the need to protect the public from dangerous persons, the mental condition of the accused, the integration of the accused into society and the other needs of the accused.

46The panel found that, at this time, a detention order is the necessary and appropriate disposition. On April 28, 2026, the treatment team concluded that, although Mr. Little was not at his baseline, he could be safely discharged back to reside with his wife. Within days, his wife contacted the treatment team expressing concern. His clinician attended their home and determined that Mr. Little remained quite psychotic and was expressing paranoid delusions relating to his wife, his parents and neighbours. The team determined that he needed to be admitted to hospital as soon as possible and requested that the police be engaged to that end.

47The evidence is clear that the treatment team needs time to investigate the precipitating factors behind Mr. Little’s mental deterioration. He had been doing well in the community for two years and the factors leading to his deterioration remain unclear. Mr. Little’s new delusions are cause for significant concern and, as Dr. Pallandi testified, require ongoing assessment and monitoring. The hospital requires the ability to continue to treat Mr. Little in hospital until he has returned to his baseline and the team is able to manage his risk in the community.

48A detention order also is necessary in order for the treatment team to be able to intervene quickly should Mr. Little be residing in the community and show signs of decompensation. Mr. Little’s mental decline was rapid and the subject of his current delusions are his wife, parents and neighbours. When unwell, the risk he poses to their safety increases significantly. It is critical that the team exercise their own judgement on the management of his risk. His wife’s assessment of the risk that her husband may pose to her should not be determinative.

49Finally, a detention order is necessary in order for the hospital to be able to approve his accommodations. At this point in time, the relationships that he has with his wife and family are under stress. Historically, they have been his main sources of support. It is unknown where, once he returns to his baseline and is ready to be discharged back to the community, he intends to reside, and whether or not he will be welcomed to reside there.

50The panel found that terms and conditions as recommended by the hospital and outlined on page 26 of the Hospital Report are necessary and appropriate and represent the least onerous and least restrictive conditions to manage Mr. Little’s threat to the safety of the public.

51In arriving at this conclusion, the panel has considered the paramount factor of the safety of the public, Mr. Little’s community reintegration, his mental condition, and his other needs as required by s. 672.5 of the Criminal Code.

Footnotes

1. 1Now called granulomatosis with polyangiitis (GPA)
2. 2As an example, in January 2021, Mr. Little reportedly grabbed his brother-in-law’s collar and tried to choke him.
3. 3Dr. Pallandi testified that it was fortuitous that he had met with Mr. Little virtually within the seven-day window required under the Mental Health Act. Otherwise, the risk presented by Mr. Little may not have risen to the level required for a Form 1.