The respondent confessed to sexually touching young boys after being confronted by the father of one of the victims, who held a knife to his throat and threatened him.
The statements were admitted at trial without a voir dire and without objection from defence counsel.
The respondent was convicted, but the Court of Appeal ordered a new trial.
The Supreme Court of Canada dismissed the Crown's appeal, holding that the evidence of the parents' prior contact with the police and their plan to trick the respondent was sufficient to alert the trial judge to the need for a voir dire to determine if the father was a person in authority.