FACTUAL BACKGROUND AND OVERVIEW

Introduction

[1] Damien Allred is charged with the second degree murder of Teresa Santos, an elderly woman who lived in his apartment building in Toronto.

[2] After Mr. Allred’s arrest, he was interviewed by the police and denied any involvement in Ms. Santos’s murder.

[3] The Crown seeks admission of the interview for cross-examination purposes. Mr. Allred concedes the voluntariness of his statement to the police but seeks its exclusion alleging that it was obtained in a manner that violated his s. 10(b) rights under the Charter of Rights and Freedoms.

[4] At the conclusion of oral submissions, I dismissed the Charter application. These are my reasons for doing so.

Background Facts

[5] Teresa Santos was 75 years old when she was killed. She lived alone at 24 Shaw Street, in unit 801 in Toronto, and had mobility issues needing a walker to move around the building.

[6] On 11 August 2020, Sabrina Carreiro, another resident, noticed a distinctly unpleasant smell emanating from Unit 801. Concerned, Ms. Carreiro called 911 and asked if someone could check on Ms. Santos. In addition, Ms. Carreiro contacted the building superintendent who accompanied her to unit 801 along with firefighters who had arrived on scene.

[7] When the superintendent unlocked the door to Unit 801, Ms. Santos could be seen laying on the floor in a pool of blood. Her face was covered with a blood-stained pillow bearing the imprint of shoe marks whilst her body displayed visible signs of decomposition.

[8] On 12 August 2020, a CT scan and post mortem examination revealed the presence of a previously unseen knife lodged inside Ms. Santos’ mouth. The attending pathologist concluded that the cause of death was the violent insertion of the knife through the back of Ms. Santos’ mouth through her skull and into her brain stem.

[9] Ms. Santos also bore the mark of numerous other injuries: a 1.3 cm incised wound on the forehead between the eyebrows; five dislodged teeth within the mouth; multifocal haemorrhage of the tongue; joint dislocation with surrounding haemorrhage on neck and face; and multiple fractures to the ribs consistent with someone stomping on her chest.

[10] Police found two blood-stained footprints in Ms. Santos’ bathroom. Those prints appeared to have been made by a pair of Puma shoes or sandals. Using the “Blue Star” compound, a reagent which reacted with blood to display a fluorescent image, police discovered a series of prints leading from Unit 801 to a location between 808 and 809 with an additional fluorescent spot found directly in front of Unit 809. Most of the prints were made by Puma shoes or sandals. However, the last pair were barefoot impressions which faced in opposite directions.

[11] Mr. Allred, the tenant in Unit 809, became a suspect in proceedings after police reviewed a series of video clips showing him wearing what appeared to be Puma style sandals.

[12] After Mr. Allred ’s arrest, police obtained samples of his DNA. The Centre of Forensic Sciences confirmed that Mr. Allred could not be excluded as the donor of DNA samples taken from the fingernail clippings of Ms. Santos’ right hand and that it was one trillion times more likely if they originated from Ms. Santos and Mr. Allred than if they originated from Ms. Santos and another unknown person unrelated to Mr. Allred.

The Arrest

[13] Mr. Allred was arrested on 16 August 2020, five days after Ms. Santos’ body had been discovered. The arresting officer, Police Constable Amanda Arevalo, was told that Mr. Allred was to be arrested for criminal harassment and assault causing bodily harm (offences unrelated to Ms. Santos) but also informed that Mr. Allred was a suspect in a homicide.

[14] PC Arevalo along with another officer attended Unit 809, arriving at approximately 9:15 p.m. She wore an audio device to ensure her interactions with Mr. Allred were recorded.

[15] When Mr. Allred opened the door to his apartment, PC Arevalo informed him that he was under arrest for criminal harassment and assault causing bodily harm. However, she did not refer to the homicide.

[16] When testifying on the voir-dire at this trial, PC Arevalo indicated that to her surprise, Mr. Allred’s family, including two small children, was present in the apartment. As a result, PC Arevalo delayed telling Mr. Allred about the homicide to avoid causing upset to his wife and children.

[17] PC Arevalo did warn Mr. Allred of the recording device and cautioned him not to say anything that might be incriminating.

[18] At 9:23 p.m., PC Arevalo read Mr. Allred his right to counsel from her memo book and led him down to her police cruiser in handcuffs. When Mr. Allred indicated that he might not have fully grasped the meaning of PC Arevalo’s comments, she repeated the 10(b) warning and Mr. Allred indicated that he understood.

[19] When they reached the cruiser some seven minutes later, at 9:30 p.m., PC Arevalo told Mr. Allred, for the first time, that he was also under suspicion for murder. She again cautioned Mr. Allred and advised him of his right to counsel.

[20] As they drove to 14 Division, PC Arevalo again made Mr. Allred aware that he was a suspect in a homicide and cautioned him again.

[21] When they arrived at the station, at 9:54 p.m., Mr. Allred was paraded before the Staff Sergeant and told that he had a right to speak to a lawyer. When asked if he understood, Mr. Allred replied that he did.

[22] PC Arevalo contacted duty counsel and informed them of all the charges Mr. Allred faced. She also apprised counsel of Mr. Allred ’s status as a suspect in a homicide and made clear that Mr. Allred had been given his right to counsel. Mr. Allred then spoke to counsel.

[23] Subsequently, Mr. Allred was kept at 14 Division overnight and questioned the next morning at 9.23 a.m. by Detective Jason Hillier who testified that the plan was to focus on the homicide investigation. Detective Hillier agreed that he would not have been able to take an “in custody” statement from Mr. Allred if he had not been charged with criminal harassment.

The Charter Application

[24] Mr. Furgiuele, on behalf of the applicant, argues that Mr. Allred was not properly informed of the true reason for his arrest: being a suspect in Ms. Santos’ homicide. According to Mr. Furgiuele, the police only made passing mention of the homicide which resulted in Mr. Allred failing to understand the jeopardy he faced.

[25] Mr. Furgiuele further contends that because the sole focus of the interview was the homicide, the police were obliged to repeat Mr. Allred’s right to counsel during the interview “to ensure he understood his increased jeopardy”, and that “he was entitled to speak with counsel again to engage with legal advice with that jeopardy in mind”.

[26] Mr. Furgiuele also says Mr. Allred did not understand his true jeopardy until after the interview had commenced and argues that Mr. Allred’s repeated requests to speak to a lawyer should have been honoured. These breaches, says Mr. Furgiuele, are sufficiently serious to justify exclusion of Mr. Allred’s utterances under s. 24(2) of the Charter.

[27] Ms. Surban, on behalf of the Crown, opposes the application to exclude the interview, re-iterating the Crown position that, if admissible, the interview would only be used if Mr. Allred’s testimony proved to be inconsistent with his prior statement. She says that there was no breach of Mr. Allred’s Charter rights, and if there was, Mr. Allred has not shown sufficient justification to warrant exclusion under s. 24(2).

LEGAL PRINCIPLES

Section 10 of the Charter

[28] Section 10 of the Charter reads as follows:

10 Everyone has the right on arrest or detention

(a) to be informed promptly of the reasons therefor;

(b) to retain and instruct counsel without delay and to be informed of that right; and

(c) to have the validity of the detention determined by way of habeas corpus and to be released if the detention is not lawful.

[29] Under s. 10(a), a detainee must be informed promptly of the reasons for detention in “clear and simple language”: R. v. Mann, 2004 SCC 52, [2004] 3 S.C.R. 59, at para. 21. Moreover, s. 10(a) requires the detainee to be told of what they are being investigated for before being given their right to counsel: R. v. Roberts, 2018 ONCA 411, at para. 76. When there is more than one reason for a detention all must be disclosed: R. v. Sawatsky (1997), 1997 CanLII 511 (ON CA), 35 O.R.(3d) 767 (C.A.); R. v. Borden, 1994 CanLII 63 (SCC), [1994] 3 S.C.R. 145 (S.C.C.).

[30] The right to counsel test is contextual and relies on “whether what the accused was told, viewed reasonably in all the circumstances of the case, was sufficient to make a reasonable decision to decline to submit to arrest, or alternatively, to undermine his right to counsel under s. 10(b)”: R. v. Evans, 1991 CanLII 98 (SCC), [1991] 1 S.C.R. 869 (S.C.C), at para 30.

[31] The right to counsel and its implementation under s. 10(b) is “to provide a detainee with an opportunity to obtain legal advice relevant to his legal situation.”: R. v. Sinclair, 2010 SCC 35, [2010] 2 S.C.R. 310 at para 24; R. v. Lafrance, 2022 SCC 32, at para 70.

[32] The interrelation between subsections 10(a) and (b) means that “the purpose of s. 10(a) is also to inform an individual of the extent of his or her jeopardy such that he or she can exercise the right to counsel conferred by s. 10(b) in a meaningful way”: R. v. Nguyen, 2008 ONCA 49, at para. 20.

[33] When an accused is in custody, the purpose of s. 10(b) is “to support the detainee’s right to choose whether to cooperate with the police investigation or not, by giving him access to legal advice on the situation [they are] facing”: Sinclair, at para. 32.

[34] However, the police are only obliged to permit a single consultation with counsel unless (1) a new non routine procedure involving the detainee arises, e.g. a polygraph or identification line up; (2) a change in jeopardy occurs where the investigation takes a new and more serious turn; or (3) there is some indication that a detainee who has waived his right to counsel has not understood it: Sinclair, at paras. 50-52.

[35] These categories are not exhaustive but should only be added to where “necessary to ensure that s. 10(b) has achieved its purpose”: Sinclair, at para. 49.

[36] The Court in Sinclair, at para. 65, added:

We conclude that the principles and case-law do not support the view that a request, without more, is sufficient to re-trigger the s. 10(b) right to counsel and to be advised thereof. What is required is a change in circumstances that suggests that the choice faced by the accused has been significantly altered, requiring further advice on the new situation, in order to fulfill the purpose of s. 10(b) of providing the accused with legal advice relevant to the choice of whether to cooperate with the police investigation or not.

WAS THERE A BREACH OF MR. ALLRED’S SECTION 10(B) RIGHTS?

[37] When PC Arevalo arrested Mr. Allred she was obliged to provide him with his right to counsel and inform him of the full reasons for his detention. The fact that he was a suspect in Ms. Santos’ murder was not a peripheral matter especially given the police testimony that their sole focus in Mr. Allred’s interview was that offence.

[38] I accept PC Arevalo’s evidence that she failed to disclose this information because of the presence of Mr. Allred’s family and only told him about the homicide when he was brought to the police cruiser, some seven minutes later. The audio recording indicates her discomfort in arresting Mr. Allred in the presence of his children. In technical terms, it is arguable that this might have been a breach of his s. 10(a) and (b) rights.

[39] However, for the following reasons, even if that were the case that would not be sufficient to warrant exclusion of his statement.

[40] Assuming the police did breach Mr. Allred’s rights when PC Arevalo failed to initially inform him he was a suspect in a homicide investigation, PC Arevalo’s subsequent actions constituted a “fresh start” as defined by the Supreme Court of Canada in R. v. Beaver, 2022 SCC 54. There, the Court indicated that the effect of an initial Charter breach may be dispelled if the police subsequently comply with their requirements under the Charter.

[41] The Court provided examples at para. 103 of indicators where a “fresh start” could be found such as (i) whether the police informed the accused of the Charter breach and dispelled its effect with appropriate language, (ii) whether the police cautioned the accused after the Charter breach but before the impugned evidence was obtained, (iii) whether the accused had the chance to consult counsel after the Charter breach but before the impugned evidence was obtained; (iv) whether the accused gave informed consent to the taking of the impugned evidence after the Charter breach; (v) whether the accused was released from detention after the Charter breach but before the impugned evidence was obtained; and (vi) whether and how different police officers interacted with the accused after the breach but before the impugned evidence was obtained.

[42] The way in which the police interacted with Mr. Allred after he was taken to the cruiser constituted a “fresh start” after the initial Charter breach.

[43] As I have described, PC Arevalo informed Mr. Allred that he was a suspect in a homicide approximately seven minutes after his arrest. He was again cautioned and repeatedly reminded of his right to counsel throughout his interactions with the police including during the ride to 14 Division and when paraded before the Staff Sergeant. When he indicated his desire to speak to a lawyer, duty counsel was contacted and spoke to Mr. Allred before he was interviewed. These actions were sufficient to sever any connection with the any breach that might have occurred when PC Arevalo failed to inform him that he was under suspicion in a homicide investigation.

[44] However, Mr. Furgiuele submits that in the entire time leading up to the interview, Mr. Allred was not sufficiently notified of the jeopardy he faced.

[45] For the following reasons, I disagree and find that Mr. Allred knew of his status as a suspect from the very beginning of his interactions with the police.

[46] As I have already noted, Mr. Allred was first told he was a suspect in a homicide at the police cruiser. He responded by saying “Me? Me? Me? You got the wrong person. There's a bunch of weird shit that goes on in this building every day I walk with my family, a bunch of weird shit. You come and drag me out of my -- out of my bed –... With -- when I'm laying down sleeping with my family”.

[47] I agree with Ms. Surban that there is a clear distinction between Mr. Allred’s response to being told that he was being arrested for the offences of criminal harassment and threatening and, on the other hand, his reaction to the information that he was a suspect in a homicide.

[48] In the former case, he defended his actions with an explanation of what he had said to “the old woman” he called “Carolyn” by explaining he was reprimanding her for screaming at his family. However, as regards the latter situation, Mr. Allred did not even enquire about the identity of the victim. This constitutes evidence that Mr. Allred knew he was facing two different kinds of jeopardy.

[49] A further example of Mr. Allred’s understanding of the distinction between the two sets of allegations can be found when Mr. Allred arrived at 14 Division.

[50] There, PC Arevalo explained to the Staff Sergeant that Mr. Allred had been arrested for criminal harassment and threatening to which Mr. Allred said “okay”. She continued “I also advised you when you're down here that you're a suspect in a homicide at this time”. Mr. Allred responded: “You didn't advise me that. You were talking to something on your phone”. Again, this clearly indicates that Mr. Allred knew there were two separate sets of offences for which he was being detained.

[51] The evidence shows that the police complied with their s. 10 obligations.

[52] When he was paraded, PC Arevalo repeated that she had read Mr. Allred his right to counsel and told the Staff Sergeant in his presence “he’s also been informed at this time that he's also a suspect in a homicide”. At this point, Mr. Allred was once again given his right to counsel and cautioned.

[53] When PC Arevalo spoke to duty counsel before Mr. Allred’s consultation with her, PC Arevalo informed her of the offences with which Mr. Allred had been charged with and told her that Mr. Allred was a suspect in a homicide.

[54] At this point, the evidence demonstrates that Mr. Allred had been told that he was a suspect in a homicide three times and given his right to counsel on at least three occasions. The duty counsel whom he was to talk to had also been made aware of the homicide investigation. After these events, Mr. Allred was allowed to speak to duty counsel that night.

[55] Mr. Furgiuele points out that, at the station, when the Staff Sergeant asked Mr. Allred whether he understood the reason for his arrest, Mr. Allred focussed on the “old woman” who was the subject of the criminal harassment charge.

[56] I do not think that this evidence assists the defence. Whilst that may have been Mr. Allred’s way of responding to the Staff Sergeant, he could not have been ignorant of his status as a murder suspect given the numerous times it had been mentioned.

[57] Any doubt about Mr. Allred’s state of mind regarding the jeopardy he faced can be resolved by his responses to Detective Hillier when interviewed on the morning of 17 August 2020.

[58] At the outset of the interview, Hillier informed Mr. Allred that he was a member of the Homicide Squad and was not going to discuss the criminal harassment charges.

[59] The following exchange then took place:

HILLIER: Um...but as the officers in’- informed you, that uh you were a suspect in a homicide investigation. All right.

ALLRED: Um-hmm. Um-hmm.

HILLIER: So that’s – that’s why I’m here ---

ALLRED: Okay.

HILLIER: — is uh to talk to you about that and uh I, I want to explain that all to you so that you understand like why the heck is he saying I’m a suspect.

ALLRED: I’m here.

[60] Later, Mr. Allred recounted his conversation with duty counsel and her advice to remain silent, decline consent to any searches, or refuse any requests for a DNA sample.

[61] After discussing Ms. Santos and restating the police investigation of a homicide, Detective Hillier again reminded Mr. Allred that he was a suspect and described what he meant - that Mr. Allred may possess a degree of culpability in the offence. Mr. Allred replied by telling Detective Hillier that he “understands”.

[62] There is no evidence of any confusion on Mr. Allred’s part in these exchanges. Indeed, they confirm that Mr. Allred knew full well that he was under suspicion for Ms. Santos’ death.

[63] Immediately afterwards, the two men engaged in the following conversation:

HILLIER: Uh with it – and being upfront with you, and that goes back to building that trust ----

ALLRED: In that building, there’s a lot of suspects in that building.

HILLIER: There’s been lots of interesting people all around, right, so ---

ALLRED: I can exactly guarantee that.

HILLIER: Yeah. Yeah. Um so we’ve already talked about it. You talked to uh Duty Counsel. You got your rights uh to counsel. It sounds like you, you liked the advice that you got from your lawyer.

ALLRED: I do. I do.

[64] These comments further confirm that Mr. Allred knew clearly that he was a suspect in a homicide investigation and had discussed the matter with duty counsel.

[65] I also take into account the facts known by Mr. Allred by the time of his interactions with the police: by his own admission he had seen police outside Ms. Santos’ door and observed them conducting the Blue Star tests outside his unit. He would clearly have been aware of wrongdoing in Ms. Santos’ unit.

[66] Notwithstanding Mr. Allred’s request to speak to duty counsel in the interview, the police were not obliged to provide a second opportunity to do so absent the reasons set out in Sinclair. Accordingly, Mr. Furgiuele argues that there was a change of jeopardy when Detective Hillier began questioning Mr. Allred about the homicide.

[67] I disagree. As already explained, the evidence shows Mr. Allred knew he was a suspect in a homicide well before the start of the interview.

[68] The defence relies on R. v. Carter, 2012 ONSC 94, where the accused was arrested for possession of narcotics and burglary as well as being told that he was a suspect in a missing persons investigation. The trial judge found a breach of s. 10(b) on the basis that the police were aware that they were investigating homicides at the time of the interviews and were obliged to inform the accused that he was suspected of murder.

[69] However, Carter is not applicable to the facts of this case.

[70] There, the judge found the police had deliberately withheld this information and minimised the accused’s jeopardy when they gave him his right to counsel. Here, as described, Mr. Allred had been told on more than one occasion that he was a suspect in a homicide investigation.

[71] I agree with Ms. Surban that this case resembles R. v. Rodgerson, 2016 ONSC 6094, where, although the accused was arrested for drug offences, he was told that he was being investigated for “[S]omething serious. Potentially even murder”. Later the accused was told he was being investigated for "murder all the way down to a simple assault”. The judge held that the accused understood the general nature of his jeopardy with no violation of his s. 10(a) and (b) rights.

[72] For these reasons, I find no breach of Mr. Allred’s ss. 10(a) and 10(b) rights after PC Arevalo informed him he was a suspect in a homicide investigation.

Was the Evidence “Obtained in a Manner”?

[73] As I have already noted, PC Arevalo failed to advise Mr. Allred that he was a suspect in a homicide investigation when she initially arrested and detained him but informed him of that fact and re-read him his right to counsel when they reached the police cruiser. There was a seven-minute gap between Mr. Allred being detained and told of the homicide investigation.

[74] If this delay constituted a breach of s. 10(b), I would still find that the interview was not obtained in a manner that violated Mr. Allred’s Charter rights for the following reasons.

[75] As already described, I have found that the police’s subsequent conduct constituted a “fresh start” which severed any connection between the initial Charter breach and the subsequent utterances made by Mr. Allred in his interview.

[76] If I am wrong on that point, I would still find these utterances were not the product of a Charter violation.

[77] The question is whether the seven-minute delay that caused the breach resulted in the statement taken from Mr. Allred the next day being “obtained in a manner” that infringed his Charter rights such that an examination under s. 24(2) would be required. In my view it did not.

[78] In dealing with the question of whether evidence has been obtained “in a manner” that infringed his Charter rights, a causal connection is not required between the breach and the evidence sought to be excluded: R. v. Strachan, 1988 CanLII 25 (SCC), [1988] 2 S.C.R. 980, at pp. 1005-6; R. v. Goldhart, 1996 CanLII 214 (SCC), [1996] 2 S.C.R. 463, at para. 24. In Goldhart, the Supreme Court of Canada approved an approach which requires examining the whole of the relationship between the evidence and the breach: the court must examine both the temporal and causal link between the two.

[79] In R. v. Mack, 2014 SCC 58, [2014] 3 S.C.R. 3 at para. 38, Moldaver J. summarised the principles in the following way:

Whether evidence was “obtained in a manner” that infringed an accused’s rights under the Charter depends on the nature of the connection between the Charter violation and the evidence that was ultimately obtained. The courts have adopted a purposive approach to this inquiry. Establishing a strict causal relationship between the breach and the subsequent discovery of evidence is unnecessary. Evidence will be tainted if the breach and the discovery of the impugned evidence are part of the same transaction or course of conduct. The required connection between the breach and the subsequent statement may be temporal, contextual, causal, or a combination of the three. A “remote” or “tenuous” connection between the breach and the impugned evidence will not suffice.

[80] In R. v. Edwards (appeal by Pino), 2016 ONCA 389, 130 O.R. (3d) 561, the Court of Appeal for Ontario set out a practical approach to determine if the temporal connection is sufficiently strong. Writing for the court, Laskin J.A., at para. 72, outlined the factors to be considered when deciding whether evidence had been “obtained in a manner”:

The approach should be generous, consistent with the purpose of s. 24(2)

The court should consider the entire "chain of events" between the accused and the police

The requirement may be met where the evidence and the Charter breach are part of the same transaction or course of conduct

The connection between the evidence and the breach may be causal, temporal, or contextual, or any combination of these three connections

But the connection cannot be either too tenuous or too remote.

[81] See also: R. v. Tim, 2022 SCC 12, at para. 78.

[82] Here, the statement was taken some 12 hours after Mr. Allred’s arrest. The breach was not causally related and the connection was too remote, particularly given the subsequent numerous occasions where Mr. Allred was told of his status as a suspect, the repeated reading of his right to counsel, and the length of time that had elapsed between the breach and the interview.

[83] For these reasons, I find that the contents of the interview were not obtained in a manner that violated Mr. Allred’s Charter rights.

Section 24(2)

[84] If I am wrong on that point, I would still admit the interview applying s. 24(2) of the Charter.

[85] When deciding whether admission of evidence obtained in a manner that infringed Charter rights should be excluded, R. v. Grant, 2009 SCC 32, [2009] 2 S.C.R. 353 directs a court to consider:

The seriousness of the breach

The impact of the breach on the accused’s Charter protected interests

Society’s adjudication on the merits of the trial

[86] For the following reasons, I the evidence admissible under s. 24(2).

[87] First, the breach was not serious and only technical in nature. There was only a seven-minute delay between Mr. Allred’s detention and being informed that he was a suspect in a homicide. Moreover, the delay occurred because the officer did not want to subject Mr. Allred’s wife and children to unnecessary stress.

[88] When Mr. Allred was told of his status as a suspect, PC Arevalo repeated his right to counsel and cautioned him. This is not a case where “the police engaged in misconduct from which the court should dissociate itself”: R. v. Thompson, 2020 ONCA 264, at para. 83. Rather, PC Arevalo acted on compassionate and humanitarian grounds. This limb favours admission.

[89] Secondly, the impact on the accused’s Charter protected interests were minimal. No officer sought information from him in the seven-minute period or influenced him in any way. The statement that he provided was exculpatory and voluntary. This limb also favours admission of the evidence.

[90] Finally, although exclusion of the statement would not significantly impact its case, it would have an effect if Mr. Allred testified and deviated from the account told to the police on 17 August 2020. If that were the case, the Crown would be prevented from confronting Mr. Allred with any inconsistency no matter how significant. Once again, this limb favours admission.

[91] A balancing of the Grant factors favours the admission of Mr. Allred’s police interview. I am cognisant of the need to view the factors as a whole rather than parse them into individual categories: Tim at para. 98, R. v. Mengesha, 2022 ONCA 654.

[92] For these reasons, the application to exclude Mr. Allred’s interview is dismissed.

S.A.Q. Akhtar J.

Released: 3 February 2023

COURT FILE NO.: CR-21-10000515

DATE: 20230203

ONTARIO

SUPERIOR COURT OF JUSTICE

BETWEEN:

HIS MAJESTY THE KING

– and –

DAMIEN WARD ALLRED

REASONS FOR JUDGMENT

S.A.Q. Akhtar J.

R. v. Allred, 2023 ONSC 798

Case Summary

FACTUAL BACKGROUND AND OVERVIEW

Introduction

Background Facts

The Arrest

The Charter Application

LEGAL PRINCIPLES

Section 10 of the Charter

WAS THERE A BREACH OF MR. ALLRED’S SECTION 10(B) RIGHTS?

Was the Evidence “Obtained in a Manner”?

Section 24(2)

Judge

Counsel

Parties

Areas of Law

Fact Patterns

Issues

Statutory Provisions 3

Legal Tests 3

Legislation 1