The appellant, Jeffrey Ronald Brown, appealed his convictions for firearms offences, arguing that the search warrants used to find handgun evidence were invalid.
The warrants were based on an Information to Obtain (ITO) that relied heavily on a confidential informant (CI).
The appellant challenged the trial judge's application of "Step Six" of R. v. Garofoli, which allows for a judicial summary of redacted ITO portions to protect CI identity.
The Court of Appeal upheld the trial judge's finding that the ITO, amplified by the judicial summary, met the Debot criteria for warrant issuance (compelling, credible, corroborated information).
The appeal was dismissed.
