Re Christopher Deme, 2026 CanLII 56723

Ontario Review Board

Re: Christopher Deme

ORB File No: 6706

Hearing held on: Wednesday, May 13, 2026

Place of Hearing: Southwest Centre for Forensic Mental Health Care, 401 Sunset Drive, St. Thomas

Pursuant to: Section 672.81 (1) of the Criminal Code

Before:

Alternate Chairperson: Mr. J. Weinstein

Members: Dr. R. Kunjukrishnan

Dr. P. Wright

Mr. E. Siebenmorgen (by Zoom videoconference)

Ms. B. Little

Parties Appearing:

Accused: Christopher Deme

Counsel: Mr. J. Chapnick

The person in charge of hospital: Counsel: Ms. J. Zamprogna

Attorney General of Ontario: Counsel: Ms. K. Dalrymple

REASONS FOR DISPOSITION

(Dated June 12, 2026)

Introduction

1. On February 23, 2015, Christopher Deme was found not criminally responsible on account of mental disorder (“NCR”) on charges of being unlawfully in a dwelling house, failing to comply with a probation order, theft exceeding $5000, and failing to attend court, all contrary to the Criminal Code. He was most recently subject to a Disposition of the Ontario Review Board (“ORB” or “the Board”) dated June 30, 2025 detaining him at the Southwest Centre for Forensic Mental Health Care (“Southwest Centre” or “the Hospital”) with a variety of privileges up to living in the community of Elgin and Middlesex Counties in accommodation approved by the person in charge of the Hospital.

2. On Wednesday, May 13, 2026, a panel of the Board convened in person at the Hospital to conduct the annual review of Mr. Deme’s Disposition and to issue a new Disposition. The issues for determination were: (a) whether Mr. Deme represents a significant threat to the safety of the public within the meaning of s. 672.5401 of the Criminal Code; and (b) if so, to create a new Disposition that is necessary and appropriate, being also the least onerous and least restrictive, having regard to the factors in s. 672.54 of the Code. Mr. Deme was present for his hearing and was represented by his counsel, Mr. Chapnick.

3. The evidence for the hearing consisted of the Hospital Report dated April 6, 2026 and the oral evidence of Dr. Ajay Prash, Mr. Deme’s attending psychiatrist.

Positions of the Parties

4. At the start of the hearing, all parties jointly proposed that the necessary and appropriate Disposition was a continuation of the Detention Order in accordance with its previous terms, with the following changes:

• to change the duration of Mr. Deme’s indirectly supervised passes into Southwestern and Southern Ontario from 72 hours to seven (7) days, to facilitate longer visits to a friend and to his mother, who live several hours away;

• to remove the clause requiring Mr. Deme to abstain from substances; and

• to reduce Mr. Deme’s minimum reporting frequency to twice monthly.

5. At the conclusion of the evidence, the parties jointly modified their position slightly to recommend that the substance use abstention clause be varied to create an exemption for the use of alcohol and cannabis. In all other respects, the initial joint position was maintained. The issue of “significant threat” was not in dispute.

Findings

6. For the following Reasons, the panel adopted the joint submission. The panel concluded that Mr. Deme represents a significant threat to the safety of the public and that the necessary and appropriate Disposition is a Detention Order in terms that mirror those of the previous Disposition, with the above-noted changes. The substance use abstention requirement was modified to permit Mr. Deme to consume alcohol and cannabis that is obtained from a legal dispensary.

Index Offences

7. The circumstances surrounding the index offence are taken from last year’s Reasons for Disposition dated July 22, 2025, and are reproduced as follows:

" On May 30, 2013, Mr. Deme, accompanied by another man, broke into an apartment and stole a flat-screen T.V. at a time when he was under probation. On January 30, 2014, he failed to attend Court as required by the terms of his release.”

8. At the time of the index offences, Mr. Deme was subject to a probation order from convictions in 2010 for assault with a weapon and failing to comply with probation.

Background Information

9. Mr. Deme’s personal background is set forth in detail in the Hospital Report and is therefore in evidence. It need not be reviewed in detail for the purpose of these Reasons. The following summary is adapted from last year’s Reasons.

10. Mr. Deme is now 39 years of age. He was born in Toronto. Mr. Deme was removed from his biological mother's care at six months of age and placed in foster care until his adoption by the Demes at 17 months of age. His adoptive parents currently live in British Columbia. In recent years, he has connected with his biological mother, who lives in Toronto.

11. Mr. Deme was hyperactive at home and in his elementary school. He was diagnosed with attention deficit hyperactivity disorder (ADHD) and treated with Ritalin. On his parents’ initiative, he was placed in special supportive school programs and completed elementary school. His high school years were disrupted by drug use and absenteeism, and he did not initially complete high school. He did, however, obtain his high school diploma in 2018 while under the ORB's jurisdiction and has taken several college courses since then.

12. Mr. Deme began to use alcohol in grade 8 and in grade 9, this progressed to marijuana, ecstasy and cocaine. His substance use continued and expanded to other drugs over the next several years. He also became involved in selling drugs. By 2005, he was using considerable amounts of cocaine, was residing in various shelters, and was supporting himself by working in a nightclub in downtown Toronto.

13. Mr. Deme was married but has been separated for several years. His relationship with his wife (at that time as a girlfriend) dates to 2016 and was reportedly tumultuous, causing significant stress that continued, including during disputes over access to their daughter. Their daughter was born in 2021.

14. Mr. Deme has a criminal record starting in 2002 (Youth Court). His adult convictions started in 2005 and continued up to the time of the index offences, with approximately 30 convictions, including for assault and criminal harassment, as well as for property offenses, driving offenses, breaching probation orders or undertakings, and narcotics offenses. At the time of the index offences, Mr. Deme’s most recent criminal convictions were from October 4, 2012, for criminal harassment and failing to comply with a probation order. He received a suspended sentence and was placed on probation for three years in respect of these convictions.

15. Mr. Deme has a history of admissions to psychiatric facilities, dating back to 2005. The Hospital Report includes a comprehensive review of these admissions, his psychiatric and risk assessments, and his course under the Board's jurisdiction. As the Report is an Exhibit and thus in evidence at the hearing, its contents need not be repeated in these Reasons.

16. Mr. Deme’s current diagnoses are listed as follows in the Hospital Report:

• Schizoaffective Disorder;

• Substance Use Disorder (in remission in a controlled setting);

• Attention Deficit Hyperactivity Disorder (by history);

• Borderline Traits and Antisocial Traits (by history); and

• Post-Traumatic Stress Disorder.

17. The Hospital Report States that Mr. Deme has been living in his own independent apartment since July of 2024, supported by the Forensic Outreach Team and by the Forensic Supportive Housing Program (FSHoP) in London. He was readmitted to the Hospital from September to December of 2024 due to escalating alcohol and substance use and early warning signs of mental status decompensation. There have been no readmissions since then. Over the past reporting year, there has been no demonstration or reporting of positive or residual symptoms of his mental illness.

Evidence at the Hearing

18. Dr. Prakash adopted the Hospital Report in his evidence. He initially explained the rationale for the Hospital’s recommendation for a reduced minimum frequency of reporting. He confirmed that the Outreach Team can increase that frequency if need be. Dr. Prakash noted that the past reporting period represented Mr. Dean's second successful year in the community.

19. For most of the previous reporting period (2024-2025), Mr. Deme did not use substances. His abstinence continued for the more recent reporting period as well. The Hospital Report confirmed that all Mr. Deme’s urine drug screens were negative for substances for this reporting period. Following the previous year’s ORB hearing, the focus for Mr. Deem has been on his addictions and their drivers. Dr. Prakash said that Mr. Deme has been heavily invested in his therapy. This therapy has not been easy and required significant effort on his part. Dr. Prakash said that until two weeks prior to the hearing, Mr. Deme had been engaged with London Counselling Services. That service had previously been free of charge, but Mr. Deme now must pay for the service. He is willing to resume once he can get his finances in order.

20. Mr. Deme is also working with a social worker attached to the Forensic Outreach Team. That therapy relies upon Canadian Mental Health Association (CMHA) Thames Valley Addiction Services principles and curriculum. In addition, Mr. Deme employs his CBT and DBT skills.

21. Dr. Prakash was referred to Mr. Deme’s attitude to substance use, as recorded at p. 259 of the Hospital Report. Mr. Deme said that he would enjoy the occasional social drink and stated that his real problem with substance use involved crystal methamphetamine. He is interested in exploring the use of cannabis in the form of CBD gummies as he believes it may help his anxiety and assist with trauma-related nightmares. He acknowledged that he has not yet completed his full research on the subject yet. Mr. Deme has stated that cannabis is not a drug of choice for him.

22. Dr. Prakash advised that Mr. Deme has demonstrated the benefits of his counselling over the course of the reporting year. He has dealt with many stressors, most notably the ongoing family court proceedings involving his ex-wife and daughter. Those proceedings have still not resolved. His daughter is in the care of Mr. Deme’s ex-wife and Mr. Deme wishes to have contact with his daughter. He is concerned for his daughter’s safety, and these matters are all stressors for him.

23. Another stressor has been Mr. Deme’s inordinate use of visits to a hospital Emergency Room (ER), on close to 30 occasions. Dr. Prakash confirmed that Mr. Deme does have several physical health conditions, including complaints of severe back pain and a history of heart and respiratory issues. Despite his many somatic complaints and hospital visits, he has maintained his mental health stability. In the past, as noted at para. 20 of last year’s Reasons, a large number of these ER visits have correlated with early warning signs of mental status decompensation. The treatment team sees this correlation.

24. Dr. Prakash stated that cannabis use can have an exacerbating impact upon Mr. Deme’s schizoaffective disorder, and Mr. Deme understands that it can be risk-enhancing. With respect to his desire to consider using cannabis to treat his trauma-related nightmares, Dr. Prakash confirmed that Mr. Deme is currently on medication for this already. In response to questions from a panel member, Dr. Prakash confirmed that he has advised Mr. Deme against using cannabis in any form. There is a real possibility that he would use cannabis anyway, regardless of the treatment team’s advice. Dr. Prakash stated that the reason for the Hospital’s recommendation to remove the abstention clause from Mr. Deme’s Disposition is twofold: to assess his internal commitment to abstinence, and to promote his community reintegration.

25. In response to a concern expressed by a panel member about whether the removal of the abstinence clause could set Mr. Deme up for failure in his reintegration, Dr. Prakash stated that there is also the possibility that maintaining the clause could cause Mr. Deme to become frustrated.

26. Dr. Prakash agreed that Mr. Deme is not yet ready for a Conditional Discharge, noting at the outset that his last documented use of crystal methamphetamine was in September of 2024. From Mr. Deme’s history, this substance has been more destabilizing for him than cannabis has been. In terms of speed of mental status decompensation with methamphetamine use, Dr. Prakash noted that in 2024, Mr. Deme started using it with friends around August 16. There were several outreach visits and his apartment remained in a tidy condition. He used methamphetamine again on August 30, was seen on September 1, and was ultimately admitted to the Hospital on September 16. By then, he was unable to cope. The timeframe involved a matter of weeks overall.

27. Dr. Prakash said that among the triggers that led to Mr. Deme’s crystal methamphetamine use in 2024 were boredom, loneliness, and his invitation of peers who brought the substance along with them. These factors were a major target for his therapy during the past reporting year, and Mr. Deme has decided to remove himself from the “world” of substance use.

28. Asked what he would like to see before recommending Mr. Deme for a Conditional Discharge, Dr. Prakash stated that sustained abstinence from substances and a sustained stable mental state should first be apparent. He agreed, in response to another panel member’s question, that as noted at p. 268 of the Hospital Report in the Risk Assessment portion, a risk factor for Mr. Deme is reduced engagement with the treatment team and supportive monitoring. He said that this factor can be managed even with the proposed reduction in the minimum number of monthly appointments, particularly with a Detention Order in place along with the ability to “flex” the frequency of appointments if required.

29. No further evidence was led following Dr. Prakash’s testimony. However, during his closing submissions supporting the joint position, Mr. Deme’s counsel stated that on the morning of the hearing, Mr. Deme expressed to him that he was deeply appreciative of what the Hospital has done for him, and that his treatment team knows him better than anyone.

Analysis and Conclusions

30. The panel had no difficulty accepting the parties’ joint position and found independently, first, that Mr. Deme represents a significant threat to the safety of the public, and second, that the necessary and appropriate Disposition for the management of this risk is a Detention Order containing the terms of last year’s Disposition as modified by the parties’ joint proposal.

31. Mr. Deme’s schizoaffective disorder has significantly disrupted his mental stability, causing him to struggle with impulsivity, anxiety, severe bouts of depression and mood changes. In addition, Mr. Deme has a history of reverting to substance use, especially crystal methamphetamine and significant alcohol consumption, when he becomes overly stressed. This pattern was evident during the 2024-2025 reporting period when he relapsed into substance use and had to be readmitted to the Hospital for several months. The combination of his major mental illness and his use of substances would likely lead to violent acts resulting in serious physical or psychological harm in the absence of the structure and support provided within the forensic system.

32. The panel accepts as plausible and realistic the reoffence scenario at p. 268 of the Hospital Report, reproduced here:

“Without ongoing forensic support and supervision, Mr. Deme would likely experience a decline in stability and become non-adherent with his treatment plan and medication regimen. In the absence of structure and monitoring, he would likely utilize maladaptive coping strategies, including substance use (e.g., alcohol, cannabis, or methamphetamine) and associating with negative peer groups. Such circumstances could increase the likelihood of disorganization, impulsivity, and poor decision-making. Should these factors re-emerge, his risk of behavioural instability and potential violence would be expected to increase.”

33. The panel finds that a Detention Order is currently necessary to manage Mr. Deme’s risk. While he has made excellent progress in the past reporting year in addressing the factors that have led him to relapse into methamphetamine and excessive alcohol use, that progress is recent. Commendably, he has abstained from substance use during this past year, and it is appropriate to give him a further opportunity to internalize his commitment to abstinence by removing the prohibition on alcohol and cannabis consumption, while retaining the Hospital’s ability to monitor any substance use. This is an important transitional period during which Mr. Deme’s ability to maintain his stability in the face of ongoing stressors will be assessed by is treatment team. In Mr. Deme’s particular circumstances, this is best accomplished through the mechanism of a Detention Order. Significantly, no party suggested that a Conditional Discharge could manage Mr. Deme’s risk as effectively over the next reporting period.

34. The panel had no difficulty with the proposal to extend the duration of Mr. Deme’s indirectly supervised passes so that he can visit his mother and a friend in other communities some distance from the Hospital. The reduction in the minimum monthly reporting requirement is also appropriate, in recognition of Mr. Deme’s engagement with the treatment team and the protective factors listed in the next paragraph.

35. The panel carefully considered the question of whether it is now appropriate to grant a partial exemption, in relation to cannabis and alcohol, from Mr. Deme’s general substance use abstention clause. These substances are risk factors for him, though on the evidence, they have not exacerbated the symptoms of his illness in the way that methamphetamine use has. At the same time, Mr. Deme has developed impressive protective factors that help mitigate his risk. In view of the substantial efforts that he has made to move away from substances that amplify his risk to public safety, it is appropriate to modify the abstention clause as noted near the beginning of these Reasons. We wish to recognize Mr. Deme’s protective factors by quoting them in full from the Hospital Report, as follows:

“Mr. Deme demonstrates several meaningful strengths and protective factors that support his overall stability and recovery. He remains consistently engaged in treatment / social‑work sessions and actively participates in the review of Relapse Prevention programming, with strong insight into how repetition enhances his learning. His commitment is further reflected in his completion of homework and his sustained involvement in weekly trauma‑focused psychotherapy, which he identifies as beneficial. Mr. Deme effectively utilizes CBT, DBT, and trauma‑informed coping strategies, including grounding and emotional‑regulation techniques, contributing to a noted reduction in night terrors. He demonstrates motivation for positive co‑parenting, actively seeks guidance to manage interpersonal stressors, and maintains collaboration with multiple care providers, highlighting strong help‑seeking behaviour and treatment adherence. His stable engagement with services, capacity for reflection, and ongoing development of communication and boundaries serve as significant protective factors as he navigates family‑system stressors and potential transitions in parenting arrangements.”

36. In approaching this matter, the panel has considered the evidence through the lens of the factors in s. 672.54 of the Criminal Code.

DATED this 12^th^ day of June, 2026, at the City of Toronto, in the Toronto Region.

Eric Siebenmorgen

Legal Member

____________________________

Office of the Registrar

Ontario Review Board