Court File and Parties

COURT FILE NO.: CR- 20-90000108-00BR DATE: 20200420 ONTARIO SUPERIOR COURT OF JUSTICE

BETWEEN:

HER MAJESTY THE QUEEN Respondent – and – J.R. Applicant

Counsel: J. McGrath, for the Respondent K. Schofield, for the Applicant

HEARD: April 15, 2020.

REASONS FOR DECISION

SCHRECK J.:

[1] J.R. is charged with a number of very serious firearms and drug offences. He has a lengthy criminal record and was detained following a bail hearing. Because he has been in custody for more than 90 days, he is entitled to have his detention reviewed pursuant to s. 525 of the Criminal Code.

[2] The world is in the midst of the unprecedented COVID-19 pandemic. Over 150,000 people around the world have died and that number increases each day. Few if any people have not been affected by the pandemic or the steps that have been taken to control it. The effect of the pandemic on whether J.R. should be granted bail is a central issue on this application.

[3] Because of the pandemic, J.R.’s application was heard by me remotely. Both parties submitted documentary evidence electronically, none of which was challenged in cross-examination, and counsel for both parties made helpful and detailed submissions during a teleconference.

[4] At the conclusion of the hearing, I advised counsel that I was prepared to order J.R. released on very strict conditions to be enforced by electronic monitoring and I would provide my reasons for doing so at a later date. These are those reasons.

I. FACTS

A. The Allegations

[5] The applicant is charged with numerous firearms possession offences, discharging a firearm, possession of cocaine for the purpose of trafficking and possession of proceeds of crime. Because the applicant is yet to be tried and there has been an order made pursuant to s. 517(1) of the Criminal Code, I will not set out the allegations in detail. They are extremely grave. The applicant is alleged to have discharged a firearm in a public place while in a motor vehicle in circumstances where death or serious injury to another person was likely but fortunately did not occur. He is also alleged to have been in possession of a loaded prohibited firearm and several rounds of ammunition that were seized during the execution of a search warrant. Also seized were several grams of cocaine, a digital scale and a quantity of cash.

B. The Applicant’s Circumstances

[6] The applicant is in his mid-30s. He has a lengthy criminal record dating back to when he was a youth. It includes several convictions for serious violent offences, an offence involving a firearm and several convictions for failing to comply with a recognizance. His most recent convictions were in 2015. At the time he allegedly committed the offences he is now facing, he was subject to a number of firearms prohibitions.

[7] The applicant is currently in custody at the Toronto South Detention Centre (“TSDC”). In his affidavit, he expressed a concern that he will contract COVID-19 while in custody. He deposed in his affidavit that he suffers from severe asthma and filed a letter from his physician confirming this. He believes that his condition puts him at increased risk if he contracts COVID-19.

C. History of the Proceedings

[8] The applicant was arrested in September 2019. He had a bail hearing in February 2020 before Hendriks J.P. and was ordered detained. At the time of the hearing before me, he had been in custody for just under seven months. No date has been set for a preliminary hearing or trial because there is still outstanding disclosure, which I will discuss later in these reasons, and because the operation of the courts has been suspended because of the pandemic.

D. The Proposed Plan of Release

[9] The applicant proposes that he be released on a recognizance in the amount of $90,000 with his mother, two cousins and his girlfriend as sureties. He would be subject to house arrest enforced by electronic monitoring through Recovery Science Corporation.

II. ANALYSIS

A. The Nature of the Review

[10] This is a review conducted pursuant to s. 525 of the Criminal Code. Unlike a review conducted pursuant to ss. 520 or 521, this is not a review of any prior judicial order but, rather, a review of the detention itself. The question which the court must answer is whether the continued detention of the applicant is justified within the meaning of s. 515(10) of the Code, that is, whether detention is necessary on the primary, secondary or tertiary grounds set out in that section: R. v. Myers, 2019 SCC 18, at paras. 45-47.

[11] Where, as in this case, there has been a prior bail hearing, the reviewing court must show respect for any findings of fact made by the first-level decision maker if there is no cause to interfere with them: Myers, at para. 47. However, I must be careful not to simply “rubber stamp” the prior decision: Myers, at para. 55.

[12] A s. 525 hearing can only take place where the accused has been in custody for at least 90 days. In considering whether the continued detention of an accused is justified, the court must consider the passage of time. This is particularly relevant to the tertiary ground, as was explained in Myers, at paras. 53-54:

In other circumstances, accounting for the elapsed time or anticipated passage of time may require a more nuanced analysis of its impact on the three grounds which justify detention under s. 515(10). In St-Cloud, the Court indicated that a lengthy delay between the hearing and the eventual trial may be considered in determining whether detention is necessary to maintain confidence in the administration of justice, which is the tertiary ground: para. 71. In this sense, the analysis is not only retrospective, but also forward-looking. For example, let us consider a scenario in which an individual is detained on the basis of s. 515(10)(c), and at the time of the first detention order his trial is only two months away. If the trial date is then rescheduled for a date two years later and remains many months away at the time of s. 525 hearing, the continued detention of the accused may no longer be proportionate, or necessary, for the purposes of this third ground: see also R. v. Whyte, 2014 ONCA 268, 119 O.R. (3d) 305, at paras. 39-43; Piazza, 2015 QCCS 707, at paras. 71-81. In an appropriate case, it may also be possible for the judge to conclude that a hypothetical risk in relation to the primary or secondary ground is simply outweighed by the certain cost of the accused person’s loss of liberty or of a loss of public confidence in the administration of justice.

As part of this analysis, the judge may consider whether either party has been responsible for any unreasonable delay in the trial of the charge: s. 525(3) Cr. C. If an unreasonable delay in getting the case to trial can be attributed to one of the parties, that factor will be relevant in determining whether the continued detention of the accused is proportionate or appropriate. Thus, if the accused appears to have engineered an unreasonable delay in his or her own trial, the basis for making a release order will clearly be weaker, but if the Crown is responsible for an unreasonable delay, this will weigh in favour of release. While the term “unreasonable delay” in s. 525 clearly cannot have the same meaning as it does in the context of s. 11(b) of the Charter, the two can be seen to be conceptually related. That being said, not every delay in getting a matter to trial will be unreasonable, and the accused does not have a right to be at any particular point in the process when the 90-day mark is reached. The judge must therefore rely on his or her judgment and experience in determining what impact, if any, the passage of time and an unreasonable delay should have on the continued detention of the accused.

[Emphasis in original.]

B. The Secondary Ground

[13] The Crown has no concerns with respect to the primary ground. As was the case at the initial bail hearing, the Crown opposes the applicant’s release on the secondary and tertiary grounds.

[14] Section 515(10)(b) of the Code states that detention is justified on the secondary ground where it is necessary for the protection or safety of the public “having regard to all the circumstances including any substantial likelihood that the accused will, if released from custody, commit a criminal offence or interfere with the administration of justice.”

[15] As counsel for the respondent correctly points out, the applicant’s criminal record, including his numerous convictions for failing to comply with a recognizance, is a significant cause for concern, as is the fact that he was bound by several firearms prohibitions at the time of the alleged offences. These factors led the Justice of the Peace at the initial bail hearing to conclude that the applicant did not meet his onus on the secondary ground.

[16] Were the applicant proposing that he only be supervised by his sureties, I would agree that he could not meet his onus on the secondary ground. However, in this case there is also a proposal that he be subject to electronic monitoring. This technology is well known to the courts. The electronic monitoring would ensure that if the applicant left his home without one of his sureties or at a time when he was not permitted to do so, the breach would almost certainly be detected, as would any attempt by him to remove the ankle bracelet he would be required to wear. However, the technology is not foolproof. While it will reveal where a person is, it cannot determine what the person is doing: R. v. Osman, 2020 ONSC 965, at para. 31.

[17] During the hearing, I asked Crown counsel to explain what offences he is concerned the applicant would commit if subject to the proposed bail conditions. He submitted that even with electronic monitoring, it would not be “far fetched” that the applicant would engage in drug dealing. It is not clear to me how the applicant could obtain his product and then provide it to his purchasers without his sureties noticing, given that he would not be able to leave his residence unless in their company. I note, as well, that the applicant does not have any prior convictions for drug offences.

[18] In any event, the test is not whether the possibility of the applicant committing further offences is “far fetched”. Rather, the issue is whether there is a “substantial likelihood” that he will do so if released. This means “a probability of certain conduct, not a mere possibility. And the probability must be substantial, in other words, significantly likely”: R. v. Manasseri, 2017 ONCA 226, at para. 87.

[19] The proposed plan of release requires the applicant to be in his home at all times unless in the company of a surety. There is no suggestion that the sureties, whom the Justice of the Peace at the initial hearing referred to as “solid”, would not discharge their supervisory obligations. In addition to this, the applicant would be subject to electronic monitoring so any attempt by him to leave his residence in contravention of his bail conditions would be detected. In this regard, I note that the applicant has been subject to electronic monitoring while on bail in the past and did not breach any of his conditions. Based on this, I am satisfied that there is not a substantial likelihood of the applicant committing further offences if released.

C. The Tertiary Ground

(i) Overview

[20] Section 515(10)(c) provides that detention is justified on the tertiary ground if it is necessary to “maintain confidence in the administration of justice, having regard to all the circumstances.” Public confidence refers to the perception of reasonable members of the community who are informed about the philosophy behind the bail provisions in the Code, Charter values and the actual circumstances of the case. It does not take into account the perceptions of those prone to emotional reactions, those who do not have knowledge of the circumstances of the case or who disagree with society’s fundamental values: R. v. St. Cloud, 2015 SCC 27, [2015] 2 S.C.R. 328, at paras. 75-80.

[21] The tertiary ground is conceptually distinct from the primary and secondary grounds. The latter relate to an assessment of the probability that the accused will behave in a certain way, that is, fail to attend court or commit further offences. The tertiary ground is not concerned with predictions about the accused’s behaviour but, rather, with public perception. Having proper regard for the views of reasonable members of the public while disregarding views that may be based on purely emotional reactions or misunderstandings is not an easy task: St. Cloud, at para. 81. Furthermore, there is not necessarily a direct correlation between detention and the maintenance of public confidence. In some cases, detaining an accused without justification will undermine public confidence: St. Cloud, at para. 86.

(ii) The Statutory Factors

[22] Subsections (i) to (iv) of s. 515(10)(c) provide a non-exhaustive list of circumstances which the court should consider in relation to the tertiary ground: (i) the apparent strength of the prosecution’s case; (ii) the gravity of the offence; (iii) the circumstances surrounding the commission of the offence, including whether a firearm was used; and (iv) the fact that the accused is liable, on conviction, for a potentially lengthy term of imprisonment.

[23] Both counsel made extensive submissions about the strength of the prosecution’s case which I will not discuss in detail because of the publication ban. There appear to be significant shortcomings in the Crown’s case with respect to the allegation that the applicant discharged a firearm in public. However, the Crown’s case with respect to the possession charges is, in my view, strong, although there are certainly triable issues.

[24] The remaining factors set out in s. 515(10)(c) all favour detention. The offences are very grave. The circumstances surrounding their commission involve the use of a firearm and endangerment of the public. If convicted, the applicant is liable to a very lengthy penitentiary sentence.

[25] However, as noted earlier, the factors set out in subsections (i) to (iv) are not exhaustive: R. v. St. Cloud, at paras. 66-71. In this case, there are two additional factors which, in my view, are relevant to the tertiary ground: (1) the COVID-19 pandemic; and (2) the passage of time.

(iii) COVID-19

(a) The Pandemic

[26] There is currently a pandemic of a coronavirus disease, COVID-19, which is caused by a novel coronavirus that was first discovered in late 2019. While much about the virus is unknown, it is clear that it spreads easily. The pandemic has affected most of the world’s population in some way or other. At the time these reasons were prepared, over 2,000,000 people worldwide have been infected with the virus and over 160,000 have died as a result. There are over 30,000 cases in Canada, more than 10,000 of which are in Ontario, and over 1,500 deaths, over 500 of which are in Ontario. [1]

[27] Most governments, including those of Canada and Ontario, have taken various measures to control the spread of COVID-19. One of the primary measures is physical distancing, that is, a requirement that individuals avoid being in the company of others as much as possible and at the very least remain at least two metres apart. The purpose of this is to slow the spread of the virus in order to ensure that the health care system is not overwhelmed by having to deal with too many cases at once. This strategy is common referred to as “flattening the curve.”

(b) Dr. Aaron Orkin

[28] On this application, the applicant filed an affidavit by Dr. Aaron Orkin, a physician and epidemiologist. Dr. Orkin’s credentials are impressive. In addition to a medical degree, he holds a graduate degree in public health and is a doctoral candidate in clinical epidemiology. He practices emergency medicine at two Toronto hospitals and is the Medical Director of the St. Joseph’s Health Centre COVID-19 Assessment Centre. He is also responsible for planning a COVID-19 response strategy for Inner City Health Associates, an organization which provides health services to people experiencing homelessness. He has authored and co-authored numerous peer-reviewed publications, including several relating to health care for individuals in prison. Dr. Orkin was not cross-examined and his evidence was not challenged by the respondent.

[29] In his affidavit, Dr. Orkin discusses COVID-19 outbreaks in what he refers to as “congregate living facilities”, a public health care term that refers to settings where many people live together, such as long-term care facilities, homeless shelters, and correctional institutions. Dr. Orkin states:

Preventing outbreaks in congregate living facilities is a top priority for a flatten-the-curve strategy, for four reasons:

(1) First, outbreaks in tight spaces happen extremely quickly and are near-impossible to control once they occur. Global experiences with cruise ships are a case-in-point.

(2) Second, people living in congregate living facilities tend to have underlying comorbidities that make them more prone to serous adverse outcomes (ICU admission or death) from COVID-19. This is true in long-term care facilities, homeless shelters, and prisons.

(3) Third, outbreaks in congregate living facilities can overwhelm health care systems, meaning that scarce resources are consumed by local congregate living outbreaks before the epidemic takes hold in the general population.

(4) Fourth, outbreaks in congregate living facilities serve as tinder for the fire in more generalized outbreaks. Unlike cruise ships, people in congregate living settings including the staff who work there transfer disease into the general population.

Therefore, preventing disease in congregate living facilities is critical for flattening the curve across the entire population. All this means that protecting congregate living settings and preventing outbreaks there is about protecting the health of the entire population.

[30] In Dr. Orkin’s view, the degree of physical distancing required to reduce COVID-19 transmission is simply not possible in a correctional institution because of the space constraints. As he puts it, “This is a geometry problem, not a policy or strategy problem.” As a result, “it is extremely likely that a COVID-19 outbreak will occur in correctional facilities”, which would put the health of inmates, the staff and the public at risk.

[31] Dr. Orkin recognizes that courts must take several considerations into account is determining whether an individual should be released, but states that from a public health perspective:

… [e]very person who is discharged from a correctional facility to a private residence is an opportunity to flatten the curve and improve health for the individual involved, other inmates in the facility in question, staff at the facility in question, and the public.

(c) The “Response to COVID-19 Information Note”

[32] The respondent relies on a document entitled “Response to COVID-19 Information Note” (the “Information Note”). It is dated April 7, 2020 and the author is listed as being “Institutional Services Division, Assistant Deputy Minister’s Office.” While it is not apparent from the note, I assume that this refers to the Deputy Minister of the Ministry of the Solicitor General (“MSG”). I was advised during submissions that one of the authors of the document is a strategic advisor employed by the MSG who does not have a medical background. While the Crown has called this person as a witness during other proceedings, it did not do so before me. The identity and qualifications of the other author or authors was not disclosed to me.

[33] The Information Note states that “we are confident in the care we are providing our inmate population.” It states that as of April 7, 2020, there were 6,096 inmates in custody at 25 Ontario institutions. Of those, 103 had been tested for COVID-19 and 63 had negative results, five had positive results, and results were pending for 38. Three of the positive cases were at the TSDC, where the applicant is incarcerated.

[34] The Information Note also states that two correctional staff members, one of whom worked at the TSDC, also tested positive. According to the Information Note, all positive cases were responded to “in accordance with operating procedures.”

[35] The steps the MSG has taken in order to prevent the spread of COVID-19 include suspending personal visits for inmates (although visits from lawyers and spiritual volunteers continue), screening every staff member and inmate entering the institution and minimizing the number of court appearances and inmate transfers. Facilities are cleaned “regularly and/or as required.” The extent to which these procedures have been successfully implemented is not discussed.

[36] The Information Note also states that a proper handwashing and cough and sneezing protocol has been communicated to all Ontario inmates and that all of them are provided with soap. This was contradicted by the applicant, who states in his affidavit that the TSDC has run out of soap and that inmates can only wash their hands with water or with shampoo from the shower when they have access to it. On this issue, I accept the evidence of the applicant over that contained in the Information Note, which does not identify the source of its information.

[37] Dr. Orkin reviewed the April 7, 2020 Information Note and earlier versions of it that had been used in other proceedings. He concluded that they do not affect or change his opinion.

[38] There are several reasons why I attach little weight to the Information Note. First, its authors are not identified. There is no indication as to what qualifications they have to express an opinion on the adequacy of the measures undertaken by the MSG to control the spread of COVID-19 or whether they are justified in being “confident in the care we are providing our inmate population.”

[39] Second, I accept the evidence of Dr. Orkin, who stated:

COVID-19 is an absolutely unprecedented threat in Ontario’s health history. This is no ordinary outbreak.

In my opinion, no expert public health or health care practitioner can be “confident” in the care we are providing to any population or sub-population in Ontario. This is equally true at the public health units, the emergency department, the prisons and homeless shelters, and in any place where health and confinement intersect. In my professional opinion, at this moment in history, an expression of bald “confidence” in the safety of a group living in a congregate setting suggests a serious deficiency of public health expertise.

[40] Third, while counsel for the respondent relies on the fact that there are only five confirmed cases of COVID-19 out of 6,096 inmates, only 103 inmates, or less than two percent, have been tested. Of these, results are pending in 38 cases. This may not give an accurate picture about the prevalence of COVID-19 within correctional institutions, especially since some people who are infected with the virus show little or no symptoms. [2]

[41] Fourth, the information in the Information Note was a week old at the time of the hearing. Between March 29 and April 11, 2020, the rate of confirmed cases of COVID-19 in Canada doubled every five to eight days. [3] This shows how quickly information about the rate of infections can become outdated. Indeed, it appears that since this application was argued, an Ontario correctional facility is being closed down because of a new COVID-19 outbreak in which at least three staff members and possibly a number of inmates have contracted the disease. [4]

[42] Fifth, for the reasons explained earlier, I reject the assertion in the Information Note that all inmates are provided with soap. This calls into question the reliability of some of the remaining information in the Information Note, which I am concerned may be more aspirational than factual.

[43] I recognize that some courts have found comfort in the assurances provided by the Information Note, although I note that none of them had the benefit of Dr. Orkin’s evidence: R. v. Jeyakanthan, 2020 ONSC 1984, at para. 31; R. v. Budlakoti, [2002] O.J. No. 1352 (S.C.J.), at para. 14; R. v. Phuntsok, 2020 ONSC 2158, at paras. 26, 29. Respectfully, I do not share that view.

(d) Relevance of COVID-19 to the Tertiary Ground

[44] The COVID-19 pandemic is relevant to the tertiary ground for the reasons explained by Harris J. in R. v. Rajan, 2020 ONSC 2118, at paras. 69-70:

The traditional grounds for the imposition of tertiary ground detention expressed in Hall, 2002 SCC 64, [2002] 3 S.C.R. 309, Mordue, 223 C.C.C. (3d) 407 (Ont. C.A.) and St. Cloud as quoted above continue to militate towards detention. However, the threat of the virus pulls strongly in the other direction, towards release. In the end, the threat, if not the actuality of COVID-19, goes a long way to cancelling out the traditional basis for tertiary ground detention.

The Canadian public understands the momentous nature of this crisis and would be greatly concerned for the health of inmates and staff in institutional settings. In the public’s mind, the real and tangible threat of contracting the virus may well supplant the otherwise negative reaction to the release of an accused person. The public is not short-sighted but would look at the long-term reputation of the administration of justice. In the face of the pandemic, bail release, in the absence of primary or secondary ground concerns, may well not shake the confidence of the public.

See also R. v. J.S., 2020 ONSC 1710, at para. 18-19; R. v. Cain, 2020 ONSC 2018, at para. 25; R. v. T.L., 2020 ONSC 1885, at paras. 35-36; R. v. King, 2020 ONSC 1935, at paras. 60-61; R. v. C.J., 2020 ONSC 1933, at para. 8.

[45] Counsel for the respondent submitted that the applicant’s health should not take precedence over other factors. However, the issue in considering the tertiary ground is not simply whether the applicant’s release would be beneficial to him. As the evidence of Dr. Orkin makes clear, reducing the prison population benefits not only inmates, but also correctional staff and the public as a whole. This was recently recognized by Harvison Young J.A. in R. v. Kazman, 2020 ONCA 251, at para. 18:

As the public health authorities have emphasized at this time, the need for social distancing is not only a question of protecting a given individual but also the community at large. In the prison context, a COVID-19 outbreak may turn into wider community spread as prison staff return home. As we are repeatedly hearing during this pandemic, the wider the spread, the greater the pressure will be for scarce medical resources.

[46] It could be argued that one less person in the detention centres will not make any difference to our attempts to “flatten the curve.” The same argument could be made by any individual who is not inclined to engage in social distancing and would rather spend time with a group of friends. However, it is easy to see what the effect would be if everyone reasoned in this way.

[47] Everyone must play a part if attempts to control this pandemic are to be effective. This includes the courts. In my view, during this pandemic, reasonable members of the public would expect the courts to give significant weight to the public health implications of incarcerating individuals. Obviously, there will be some people who cannot be released notwithstanding the pandemic. However, in my view, while this pandemic is ongoing, where a person’s detention is not required on the primary or secondary ground, detention on the tertiary ground alone will rarely be justified.

(e) The Applicant’s Health

[48] The Crown submits that there should be scepticism about the applicant’s assertion that he has “severe asthma” because the letter from his physician, which is attached to his affidavit, simply refers to him having asthma and does not use the adjective “severe.”

[49] While the applicant’s physician’s letter does not refer to his asthma as being severe, she does state that the applicant is “at increased risk of severe illness during the current COVID pandemic because of asthma.” I accept that the applicant has a medical condition which places him at increased risk if he contracts COVID-19.

[50] In any event, for the reasons outlined earlier, reducing the inmate population does not only benefit the inmate being released but, rather, the community as a whole. It follows from this that in considering whether bail should be granted, the accused’s health, while relevant, is by no means dispositive. I must respectfully disagree with decisions such as Jeyakanthan, at paras. 33-35; R. v. Nelson, 2020 ONSC 1728, at para. 41; and R. v. Brown, [2020] O.J. No. 1432 (C.J.), at para. 59, which suggest that there is some type of onus on an applicant seeking release because of the risk of COVID-19 to adduce evidence that he is somehow more susceptible to the disease than others: C.J., at para. 9; Cain, at para. 11.

(iv) The Passage of Time

[51] The applicant was arrested in September 2019. The evidence against him with respect to the discharge of the firearm consists primarily of a number of surveillance videos from the area where the offence took place. As I understand it, the same surveillance video was relied on to obtain the search warrant that led to the gun possession charges. This video has apparently been in the possession of the police since July 2019. Despite repeated requests from the applicant’s counsel, the video was not disclosed to her or even provided to the Crown. The video was apparently sent to counsel by e-mail during the hearing of this application, after counsel relied on the delay to argue for the release of her client. There has been no explanation for the delay. As noted in Myers, at para. 54, “if the Crown is responsible for an unreasonable delay, this will weigh in favour of release.”

[52] The passage of time is also relevant in another way because of the COVID-19 pandemic, as was explained by Molloy J. in T.L., at para. 34:

At the current time, all courts are effectively closed except for emergency applications. All matters scheduled for trial in the Superior Court of Justice from mid-March through to the end of May have been adjourned to June. Even assuming the courts are open for business as usual at that point, a significant backlog will have been created. It is very difficult to predict when Mr. L.’s trial will be reached, but we can expect it will be many months from now, probably longer. The additional time that Mr. L. will be in custody pending his trial is a factor to take into account on the tertiary ground.

This applies equally to the applicant’s case.

III. DISPOSITION

[53] For the foregoing reasons, the applicant was ordered released on a recognizance in the amount of $90,000 with four named sureties. Among other conditions, he is to remain in his residence at all times unless in the company of a surety, not to possess any weapons and is subject to electronic monitoring.

[54] I wish to thank both counsel for their efforts in making helpful submissions in difficult circumstances.

Justice P.A. Schreck

Released: April 20, 2020.

Footnotes

[1] https://covid19.who.int/; Public Health Agency of Canada, “Daily Epidemiology Update – April 18, 2020”, p. 2.

[2] Public Health Agency of Canada, “Coronavirus Disease (COVID-19): Symptoms and Treatment,” https://www.canada.ca/en/public-health/services/diseases/2019-novel-coronavirus-infection/symptoms.html

[3] Public Health Agency of Canada, “Coronavirus Disease 2019 Daily Epidemiology Update -- April 18, 2020”, p.3

[4] “Brampton jail shutting down amid COVID-19 pandemic, union leader confirms,” CBC News, April 20, 2020, https://www.cbc.ca/news/canada/toronto/brampton-jail-closure-1.5538097; “Inmates await test results at Brampton jail after 3 correctional officers test positive for COVID-19,” Toronto Star, April 19, 2020, https://www.thestar.com/news/gta/2020/04/19/inmates-await-test-results-at-brampton-jail-after-3-correctional-officers-test-positive-for-covid-19.html