The applicant brought a complaint to the Child and Family Services Review Board alleging that the Children's Aid Society failed to provide reasons for its decisions to place his name on the Child Abuse Register, to subsequently remove it, and to keep his file open.
The Society challenged the Board's jurisdiction, noting that the decision to place the applicant's name on the Register occurred before the Board acquired jurisdiction over such matters on December 1, 2006.
The Board found it had jurisdiction to review all three decisions, reasoning that procedural fairness required reviewing the initial placement decision in conjunction with the subsequent removal decision, especially since the applicant could not practically complain earlier due to pending criminal charges of which he was ultimately acquitted.