Re: Catherine J. Jackson
ORB File No: 5460
Hearing held on: Wednesday, April 22, 2026
Place of hearing: Centre for Addiction and Mental Health
Pursuant to: Section 672.81(1) of the Criminal Code
Before:
Alternate Chairperson: Mr. M.D. Segal
Members: Dr. T. Verny Dr. S. Wiseman Ms. A. Israel Mr. A. Mete
Parties Appearing:
Accused: Catherine J. Jackson Counsel: Mr. A. Rai
The person in charge of hospital: Counsel: Mr. J. Crowell
Attorney General of Ontario: Counsel: Ms. R. Weinberg
REASONS FOR DISPOSITION
(Dated June 2, 2026)
Introduction
On October 1, 2009, Catherine Jackson was found not criminally responsible on account of mental disorder (“NCR”) on charges of assault (x3), robbery, failing to comply with probation, and failing to comply with a recognizance, contrary to the Criminal Code of Canada (the “Criminal Code”). She is currently subject to a Disposition of the Ontario Review Board (the “ORB”/the “Board”), dated May 12, 2025, detaining her at the Women’s General Forensic Unit of the Centre for Addiction and Mental Health, Toronto (“CAMH”/ the “Hospital”) with discretionary privileges including the ability to reside in the community in accommodation approved by the person in charge.
On April 22, 2026, the Board convened to conduct the annual hearing of Ms. Jackson’s disposition pursuant to s. 672.81(1) of the Criminal Code. Ms. Jackson did not attend the proceedings. Her counsel, Mr. Rai, indicated that he had instructions to proceed in her absence. His request for Ms. Jackson to be excused from the proceedings pursuant to s. 672.5(10) was granted.
At the outset of the proceedings, all parties were canvassed as to their positions on the two issues to be determined by the Board: whether Ms. Jackson continues to represent 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.
Mr. Crowell, on behalf of the Hospital, submitted that Ms. Jackson 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.
Ms. Weinberg, on behalf of the Ministry of the Attorney General, and Mr. Rai both concurred with the Hospital’s position. Thus, a joint recommendation was before the Board.
Findings
- For the reasons that follow, the Board finds that Ms. Jackson 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.
Current Psychiatric Diagnoses
- Schizophrenia;
Other Specified Personality Disorder (Mixed personality features with Borderline, Antisocial, and Histrionic Traits);
Alcohol and Stimulant Use Disorders – Severe, in sustained remission.
The Index Offences
- The circumstances of the index offences are taken from last year’s Reasons for Disposition, as follows:
“With respect to allegations of robbery, the victim in the matter was age 19 years. At that time, the accused was 32. They were not known to one another. On Sunday, June 17, 2007, at approximately 6 pm the victim was at the Eaton’s Centre located at 220 Yonge Street in Toronto. The victim had just stepped off an escalator when she heard the accused, who was behind her, yelling obscenities at her. The victim ignored the yelling and continued to walk away. At that point, the accused grabbed the victim by the shoulder and spun her around and then began to punch the victim by striking her several times above the head and chest. The accused then ripped off the silver necklace from the victim’s neck, breaking the chain and dropping the diamond pennant formerly attached to it. The victim began to scream for help. The accused fled the scene; security was summoned and provided with a description. The accused was arrested a short distance away.
Concerning the charge of assault on October 10, 2008, at about 1956 hours, “the accused was observed by officers of the Toronto Emergency Police Task Force to be standing on the roadway at Bloor Street West and Christie Streets in Toronto. She was observed to be dancing on the roadway while cars were passing her by and thereby endangering herself. She was observed by the officers to assault a woman by punching her in the face. She was arrested by the officers. The officers were then advised by a complainant that the accused had spit into his face at the scene. She was charged with that offence.
Regarding the charges of assault and failure to comply with recognizance from February 22, 2009, “the victim, who was an employee of the Banana Republic store at the Eaton’s Centre in Toronto, observed the accused standing outside the store. The victim was returning to the store from her lunch break when suddenly she realized the accused had violently grabbed her hair, pulled it without any just cause, dragged the victim about 10 feet inside the store and threw her down on the floor. The accused then casually left the store without further words. The victim sustained bruises to her left knee and lost a fistful of her hair from her head. She was in a state of shock and traumatized. The Eaton’s Security Centre then proceeded to arrest the accused and hold her for the police.”
Background Information
The Hospital Report contains detailed information about Ms. Jackson's background and psychiatric history and need not be reviewed here but for the following material points. Ms. Jackson is a 51-year-old woman born in North York, Ontario and raised primarily in Toronto. Her developmental history was marked by significant family instability, conflictual parental relationships, and a family history of serious mental illness, including schizophrenia and bipolar disorder. She left school in adolescence, completed grade 9, and lived independently at a young age. In her teens, she relocated to Vancouver, where she became involved in the sex trade and developed a long standing and severe substance use disorder involving alcohol and crack cocaine.
Ms. Jackson has an extensive psychiatric history predating the index offences, characterized by evolving psychosis, intermittent treatment, and periods of non-compliance. In 2009, she was found unfit to stand trial and admitted to the Centre for Addiction and Mental Health for treatment. After being rendered fit, she was found not criminally responsible on account of mental disorder on October 1, 2009, in relation to multiple violent offences committed in the context of untreated psychosis and heavy substance intoxication.
Following the NCR finding, Ms. Jackson spent many years in secure and general forensic units at CAMH. Her early institutional course was marked by repeated absconding, substance use, and episodes of affective and behavioural dysregulation, including aggression, largely driven by poor coping, impulsivity, and stress intolerance. Over time, particularly from approximately 2019 onward, she demonstrated gradual and sustained improvement, with increased engagement, improved medication adherence, and better emotional regulation. These gains consolidated following her discharge to Oakwood Arch, 24-hour supervised community placement, in October 2024. Since that time, Ms. Jackson has remained psychiatrically stable in the community, abstinent from substances, compliant with treatment, and without breaches of her Disposition, while continuing to require structured external supports to manage stress and maintain stability.
Current Treatment Year
Since the last disposition, Ms. Jackson has remained in the community under the supervision of the Extended Forensic Outpatient Service while residing at Oakwood Arch, a 24-hour high support residential placement. Her reporting frequency was reduced to biweekly following the April 2025 hearing. Over the review period, she has demonstrated sustained psychiatric stability and has not required recall or readmission to hospital. There has been no evidence of psychosis or major affective disturbance, she has generally presented as calm, cooperative, and appropriate in her interactions with treatment providers and residential staff.
Ms. Jackson has remained compliant with her medication regimen and committed to abstinence from alcohol and illicit substances. Except for one isolated positive alcohol screen in May 2025, which was not supported by clinical findings, all urine drug screens have been negative. She is engaged with outpatient supports, including online Alcoholics Anonymous meetings, and there have been no breaches of her Disposition. While she continues to experience chronic anxiety, sleep disturbance, and personality-based vulnerabilities, these have been managed within the community setting without escalation. Overall, Ms. Jackson has demonstrated ongoing stability, appropriate use of external supports, and continued progress towards greater independence.
Evidence at the Hearing
The evidence at the hearing consisted of a Hospital Report, dated March 12, 2026, marked as Exhibit 1, and the testimony of Dr. O’Sullivan, Ms. Jackson’s treating psychiatrist.
Dr. O'Sullivan testified before the Board. He advised that Ms. Jackson was discharged from the hospital in October 2024 and that he became her outpatient forensic psychiatrist in January 2025. Since that time, he has assessed her approximately every two to four weeks at the clinic.
He described the review period as positive. Dr. O'Sullivan testified that Ms. Jackson has remained in her 24-hour supportive housing placement at Oakwood Arch, has not experienced relapse of schizophrenia, and has not relapsed to drug or alcohol use. He reported a positive therapeutic relationship and engagement with him and the case manager, and he was not aware of any community incidents. He confirmed that there had been no readmission since discharge. And he acknowledged one reported incident of verbal abuse in November 2025, with no physical aggression or violence reported.
Dr. O’Sullivan testified that he attributed Ms. Jackson’s stability to the significant supports available through both the housing and the outpatient team, particularly given her long period of hospitalization and resulting institutionalization. In the residence, staff provide 24-hour supervision and assistance with medication monitoring, meals, cleaning, and transport to or cancellation of appointments as needed, as well as access to activities. He noted that the outpatient team provides monitoring, supervision, and access to supports and programming. Dr. O'Sullivan opined that these supports have been integral to Ms. Jackson's successful transition and continued stability in the community.
With respect to future plans, Dr. O’Sullivan testified that Ms. Jackson's long-term goal is to leave supportive housing and live independently. After the Hospital Report was filed, on April 1, 2026, Ms. Jackson told Dr. O’Sullivan that she intended to request an absolute discharge. He testified, that if granted an absolute discharge, she stated she would remain at Oakwood Arch until she secured independent housing; however, she also said that she would likely stop medication because she did not anticipate a relapse. Dr. O'Sullivan described her insight overall as “fair,” noting that it has improved over the years but fluctuates, and that deficits remain regarding her illness, medication, and risk.
Dr. O’Sullivan testified that if Ms. Jackson stopped medication, he would be concerned she could disengage from the treatment team and struggle to manage stress, with paranoia re-emerging. In that state, he considered her more likely to become agitated and potentially re-offend in a manner similar to the index offences. He added that, notwithstanding the dates of the index offences, similar risk-enhancing behaviour occurred in hospital, including assaults on nursing staff, substance use, and absconding. He further testified that Ms. Jackson has consistently stated she values sobriety and views substances as highly harmful to her; however, if she stopped medication and relapsed, she might be less able to make healthy choices and could be at increased risk of returning to substance use.
Dr. O’Sullivan testified that Ms. Jackson could, in future move from “high support” housing to a lower or medium support placement. He characterized this as a reasonable medium-term goal over the coming years. However, he stated that the treatment team presently considers continued approved housing necessary. He indicated that factors the team would want to see over the next review include increased confidence in the community, a stronger social network, and increased autonomy, noting she still benefits from prompting for appointments and some structured supports. He stated she is heading in a positive direction towards a possible conditional discharge in due course.
In response to questions by the panel regarding ongoing interventions, Dr. O’Sullivan testified that Ms. Jackson receives psychoeducation and behavioural support through regular reviews with him and the case manager, rather than formal therapy. He described work focused on sleep, hygiene, diet, caffeine intake, exercise, and routines, including addressing periods where she pursued intermittent fasting and high caffeine consumption that negatively affected sleep. He stated she has made some gains, though progress can be uneven, and that she sometimes attributes difficulties to medication rather than basic lifestyle contributors. He also confirmed that Ms. Jackson is medication compliant on an oral regimen.
Dr. O’Sullivan testified that Ms. Jackson commenced Alcoholics Anonymous, initially in person, but transitioned to an online group due to discomfort with the environment around the in-person location. He stated she speaks positively about the online group and the support she receives.
Analysis and Conclusion
The Board carefully considered the Hospital Report and the evidence of Dr. O’Sullivan and unanimously found that Ms. Jackson continues to represent a significant threat to the safety of the public.
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 expert evidence of Dr. O’Sullivan, in addition to the documentary evidence before us.
Ms. Jackson has a major mental illness, a history of significant violence when unwell, a history of medication non-adherence, and a history of substance use. The Re-offence Scenario is described at page 58 of the Hospital Report:
“Ms. Jackson has a primary diagnosis of schizophrenia, a co-morbid personality disorder, a history of trauma and an extensive history of problematic substance use. Her clinical course has been complicated by medication non-compliance, substance use, poor coping, and homelessness.
In risk assessment, one of the best predictors is a patient’s history of violence. In addition to the index offences, Ms. Jackson’s history also includes violence under the controlled conditions of an inpatient forensic unit. She also has a history of non-violent antisocial behaviour (in the form of theft, deceit, false accusations, and convictions for mischief). If she were to engage in violent re-offending, this would likely transpire in the context of a relapse of mental illness, a decompensation of personality-based vulnerabilities, or both. The use of substances, changes in medication compliance or increased psychosocial stressors are likely to be factors. In the event of a deterioration of her mental health, she may disengage from mental health services. She has a history of absconding from hospital, for example. When AWOL from the inpatient setting, Ms. Jackson has repeatedly exhibited a pattern of risk-enhancing behaviours, consisting of substance use, missed medication administration, and exposure to traumatizing environments. While residing in the community, her risk of exposure to destabilizers would be further exacerbated in the absence of adequately stable and supported housing.
In the absence of assertive management and external controls as afforded by her current detention order, including the ability to quickly return Ms. Jackson to hospital for stabilization and containment, her psychological distress, behavioural dysregulation, and paranoia would likely continue to intensify, with a high risk of impulsive, unprovoked, violence, akin to the index offences.”
- In the view of the treatment team at page 60 of the Hospital Report:
“Under the current detention order, the risks associated with her underlying maladaptive coping style (affective instability, inconsistent therapeutic engagement, impulsivity, and historical propensity to abscond and use substances) continue to be mitigated by the outpatient clinical team’s ability to approve housing, enforce treatment compliance, and rapidly readmit to hospital should dynamic risk factors intensify prior to her certifiability under the Mental Health Act.”
The Board unanimously agrees with the joint submission that the necessary and appropriate disposition is a Detention Order. It allows the Hospital to ensure that Ms. Jackson continues to receive the support and supervision she requires. This is critical to managing her risk in the community.
In consideration of all the evidence, the submissions of the parties, and the criteria set forth in s. 672.54 of the Criminal Code, the paramount consideration being the safety of the public, in addition to the mental condition of Ms. Jackson, her reintegration into society and her other needs, we conclude the necessary and appropriate disposition is to continue with the detention order disposition without change.
DATED this 2nd day of June, 2026, at the City of Toronto, in the Toronto Region.
Ms. A. Israel Legal Member
Office of the Registrar Ontario Review Board