This week’s top three summaries: R v Cervini, 2023 ONCJ 469: #hearsay police notes, R v Lowry, 2023 BCCA 399: 3rd party #records for appeal, and R v JP, 2023 ONSC 6002: s.151 implausibly #reckless.
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R v Cervini, 2023 ONCJ 469
[October 23, 2023] Principled Exception to Hearsay: Police Memoranda Notes [Justice R. Marion]
AUTHOR’S NOTE: In circumstances where there is no body-worn camera footage and a police officer is no longer able to testify in a trial, their notes can become the subject of an application under the principled exception to hearsay. Herein, Justice Marion reviews some of the applicable case law providing a useful overview for future applications. In the end, the court declines to admit the evidence noting that issues such as grounds for arrest and breach of constitutional rights cannot be encapsulated in point form notes which are effectively a memory aid and not meant to be a complete record of what transpired.
[2] Due to serious illness, the officer-in-charge of the investigation, P.C. Zack Glaves is unable to testify at trial.
[4] The Crown has brought a Khan Application seeking to have admitted in evidence P.C. Glaves’ typed reports and his handwritten duty book notes regarding the alleged incident.
[8] Due to P.C. Glaves’ illness and that evidence of a similar value cannot be obtained from another source or witness at trial, I am satisfied that the test of necessity has been met.
[10] The test of reliability encompasses two stages. At the initial stage, threshold reliability is assessed by the trial judge. The trial judge is limited to determining whether the particular hearsay statement exhibits sufficient indicia of reliability, so as to afford the trier of fact a satisfactory basis for evaluating the truth of the statement. Only when assessing ultimate reliability is the truth of the declaration determined and only if it is determined to be true by the trier of fact, judge or jury, will the evidence be admissible. Ultimate reliability is only determined after threshold liability has been established.
[11] Before I address threshold reliability, it is important to set out what the officer’s notes and reports are. They are an “aide mémoire” and not evidence. The officer’s notes and reports were never intended to be adduced as evidence. If an officer has an independent recollection of an event, it is the officer’s testimony that constitutes the evidence. The notes or report commonly contain names, addresses, time, observations, hearsay statements, perceptions and opinions.
[12] If an officer has no memory of an event and his notes and report are unable to refresh his memory, the notes or report cannot be admitted as the officer’s evidence. Even if they sparked the officer’s memory, the officer should not be permitted to simply read their notes or report as their evidence. The witness’ testimony based on their actual memory is the evidence and not the notes or report.
[13] P.C. Glaves is the only officer who interacted with the accused at the roadside and his evidence is critical to the issues raised by the accused’s Charter Application.
[14] P.C. Glaves’ notes are legible. The typed reports and notes appear to be contemporaneous with the incident.
[16] P.C. Meloche and his partner arrive on scene and follow the accused’s vehicle until the traffic stop. The officers can provide evidence of driving conduct to that point. P.C. Glaves, in his own cruiser, is following the cruiser operated by P.C. Meloche. P.C. Meloche stops behind the accused’s vehicle while P.C. Glaves passes both vehicles and stops in front of the accused’s vehicle.
[18] It is in those two areas “reasonable grounds” and “rights to counsel” that the Crown seeks a determination of admissibility of P.C. Glaves’ written notes and typed reports entitled Case File Synopsis and General Report. Initially, the Crown sought a declaration of admissibility of all of the contents of the notebook and both reports to provide a fulsome picture as to the reliability of the hearsay evidence. Counsel, in oral argument of the Application, however, limited the scope of the evidence to be considered as set out above. It is important to note that the Crown has not adduced any evidence in support of its Application but relies on the contents of P.C. Glaves’ notebook entries and the contents of the two reports and its written and oral submissions.
[19] I have prepared a comparative table to reflect the contents of P.C. Glaves’ two reports and notebook as pertinent to grounds for arrest and rights to counsel.
| Male opened wallet, driver’s licence visible and takes his time to locate driver’s licence |
The driver opened his wallet with his driver’s licence clearly visible from P.C. Glaves’ perspective. The male took his time scanning his wallet for his driver’s licence which was in plain view. |
Had a delayed response when he produced his driver’s licence, ownership and insurance |
| Opens centre console and searches for ownership / insurance |
Scanning through his centre console looking for his ownership and insurance |
See above |
| At 00:10 unable to smell odour of alcohol as bag of fresh McDonald’s sat on passenger seat |
Similar to notes | No mention |
| Suspicion of alcohol prior to operating motor vehicle |
Same | Same |
| 00:13 A.S.D. demand, which he understood |
Same | Same |
| 00:15 Fail
00:16 R.P.G. |
Same
Cervini exited his motor |
Same Same Cervini was emitting a strong odour of alcoholic beverage from his breath (my emphasis) |
| 00:16 – I asked him “have you done this before” Cervini says “yeah” “What was the result” “Not good” |
“Have you ever done one of these before” “Pfft, yeah the results were good |
No entry in this regard |
| 00:16 (while awaiting the results of the roadside test) P.C. Glaves asked: “What do you think the results will be” “Well I did have a couple of drinks” |
Same | No entry |
| 00:17 R.T.C. from (Rights to Counsel) Force Card “Do you understand?” “Yes” “Do you want to call a lawyer now?” “No, my regular lawyer died”00:18 Caution – Force Card “Do you understand?” “Yes” |
Same
Same “Do you wish to call a Same |
No entry
No entry No entry No entry |
| 00:19 Breath demand – Force Card “Do you understand?” “Yes”02:21 “Asked again if he would like a lawyer” “Why, my regular lawyer is dead, and duty counsel will just tell me don’t say anything” |
Same
During lodging asked Cervini |
No entry
No Entry |
| No entry | No entry | Cervini uttered throughout the police interaction that he was a seasoned drinker |
[20] There are a few cases dealing with the admissibility of a police officer’s notebook entries and reports for the truth of their contents. R. v. Prasad3 was a prosecution under the Controlled Drugs and Substances Act. The Crown sought to admit a deceased officer’s notes from the searches conducted as well as property reports prepared after the searches. The Court found that the Crown failed to establish threshold reliability. The Court was not satisfied that the notes and report were so reliable that contemporaneous cross-examination would not add to the process and the circumstances did not establish that the evidence was inherently reliable. The officer was not available for cross-examination. The hearsay evidence was not under oath or affirmation. The evidence was in the form of notes and reports and not audio or video recorded.
[21] In R. v. Clarke4, the accused was charged with possession of a loaded firearm and ammunition. There was an Application by the accused to introduce a statement referred to in a police officer’s notebook, that there was possibly another male on the premises that was armed, as evidence of the truth of its contents. The police officer was too ill to participate. The accused argued that the statement was necessary to make full answer and defence. The Court was not satisfied that the officer’s statement was necessary or even reliable. Other officers conducting surveillance at the relevant time could offer evidence of other males entering or leaving the premises. In addition, it was not clear as to whether the officer had any direct knowledge upon which to base his statement or whether he was imparting information received from others. The Application was dismissed.
[23] In R. v. Rowley6, the investigating officer was deceased and the Crown sought the admission of a portion of the officer’s notes to establish the continuity of samples obtained in furtherance of a prosecution for possession for the purpose of trafficking. The Court noted “the portion of the officer’s notes sought to be entered, appear to pertain to the facts or procedural aspects of the seizure, when and where it was made and what the officer did with the substance seized.” The Court further states “that the officer’s opportunity to observe, as established by other independent evidence and the routine nature of the note-taking tend to guarantee the circumstantial reliability of the particular notations made.” The only portion of the notes entered into evidence related to the substance seized and that he provided the seized drugs to another officer. The Court further states “I undertake to remind the trier of fact of the inherent frailty of this sort of evidence, keeping in mind that defence counsel is deprived of the opportunity for cross-examination.”
[24] Threshold reliability is established if the hearsay statement is substantively reliable and/or procedurally reliable. The onus is on the Crown to establish threshold reliability on a balance of probabilities.
[25] Many of the safeguards associated with procedural reliability are absent in this case as follows:
- the officer was not under oath when making the statement;
- the statement was not audio or video recorded;
- at the time of making the notes and reports the officer was not cross-examined; and
- the officer will not be available to be cross-examined in court.
[26] The Crown submits that procedural reliability is met because P.C. Glaves was an officer acting in the course of his duties. He knew the importance of telling the truth and that his notes and authored reports would be relied upon for the truth in a criminal proceeding. P.C. Glaves was duty bound to make detailed, accurate and reliable notes.
[27] At this stage of the analysis, the focus is not, however, on the truth of the statement but whether the trier of fact will be in a position to rationally evaluate the statement. [my emphasis]
[28] The other consideration at this stage is whether the notes and reports are substantively reliable. In other words, are they inherently trustworthy because they were made in circumstances that speak to the truth of their contents and accuracy.
[29] The Crown’s submissions in this regard are similar. Essentially, it is argued that the statements were made by an officer who was duty bound to make detailed and accurate notes pertinent to the investigation.
[30] The Crown submits that substantive reliability of the notes and reports would be bolstered by P.C. Meloche and P.C. Gray’s testimony if they testify….
[31] There is no evidentiary basis to believe that P.C. Meloche and P.C. Gray would provide any corroborating evidence in regard to the roadside interactions between P.C. Glaves and the accused.
[32] The nature of the evidence that the Crown seeks to admit is not simply a recording of fact which can be established by independent evidence. They touch on issues which require a probing of all circumstances surrounding the interaction between P.C. Glaves and the accused.
[33] The notebook entries and statements in the General Reports and Case File Synopsis are on occasion inconsistent. Although these differences may appear insignificant, clarity in the least would likely be sought in cross-examination. The comparative table above offers a sample of areas of inconsistency to be queried. Was it a strong odour of alcohol or an odour of alcohol? Did the accused exhibit a delayed response in producing his licence, insurance and ownership or was he just taking his time in producing them? Did the odour of alcohol emanate from him or his breath?
[34] In the Case File Synopsis Report, P.C. Glaves indicates that the accused made statements that he was a seasoned drinker throughout the police interaction. This statement is not recorded in his notebook or General Report. In the very least, this suggests that the conversation between P.C. Glaves and the accused may have extended beyond what was noted. All conversations with an accused during an investigation may be significant and that potential is heightened when dealing with grounds for arrest and Charter issues.
[35] The evidence relevant to issues such as “grounds to arrest” and “breach of a constitutional right” cannot be encapsulated in point form notes, and what is effectively a mere summary of an incident intended to be an “aide mémoire”. The issues raised involve a series of events including conversations and their chronological order. That evidence would be tested, clarified and potentially expanded upon or challenged through cross-examination.
[36] The traditional safeguards associated with procedural reliability are absent in the case at bar and no cross-examination on the contents of the hearsay statements can occur.
[37] The presumption of innocence requires that every shred of evidence adduced to establish an accused’s guilt be procedurally tested at trial at the discretion of the Defence and as deemed appropriate by the presiding judicial officer.
[40] The Application is, therefore, dismissed.
R v Lowry, 2023 BCCA 399
[October 30, 2023] Appeals: Third Party Records Applications for Fresh Evidence [Reasons by Fitch J.A. with Grauer and Skolrood JJ.A. concurring]
AUTHOR’S NOTE: Per R v Suter, the collateral consequences of conviction may serve to decrease the sentence of an offender. Sometimes this kind of evidence or consequence does not arise until after the person begins serving their sentence. This case provides a first step example of what to do for appellate lawyers seeking to force an accounting for such events that is meaningful to the imprisoned. Here, the appellant sought and was granted a third party records application against correctional authorities to produce the video recording of violence visited upon the offender in prison. This evidence was ordered for the purpose of a fresh evidence application that was not decided as of the writing of this summary.
I. Nature of the Application
[1] The appellant applies, pursuant to s. 683(1)(a) of the Criminal Code, R.S.C. 1985, c. C-46, for the production of CCTV video footage held by a third-party record holder, the Correctional Services of Canada (“CSC”), depicting a post-sentence assault perpetrated on him by a group of other inmates. If the video footage is ultimately provided to the appellant, it is his intention to apply to have it admitted as fresh evidence on his outstanding appeal from sentence.
II. Background
[3] The appellant was convicted by a Supreme Court judge on July 17, 2020 of aggravated assault, kidnapping, extortion, forcible confinement, and overcoming resistance: R. v. Cantrill, 2020 BCSC 1110. He was found to be one of three men who participated in the beating and confinement of the named victim. The appellant was 49 years old at the time of sentencing. He had no prior criminal record.
[4] On July 16, 2021, the appellant received a global sentence of nine years’ incarceration: R. v. Cantrill, 2021 BCSC 1652.
[5] On November 18, 2022, the appellant was assaulted by other inmates while incarcerated at Matsqui Institution. He claims to have lost the vision in his left eye as a consequence of the assault.
[8] No CSC staff member witnessed the assault. The appellant is, however, in possession of redacted copies of written reports prepared by CSC personnel that describe the assault based on what the videos depict. The reports also document the dealings CSC staff had with the appellant in the aftermath of the assault. The appellant does not seek the production of unredacted copies of any of these written reports.
[9] On August 11, 2023, the appellant filed an application to adduce fresh evidence concerning the circumstances of the assault and the impact it has had on him. The appellant also seeks to adduce as fresh evidence medical challenges he has experienced since his incarceration, which appear to be unrelated the assault.
[12] Counsel for the third-party record holder has waived the requirement that the application be commenced by the issuance of a subpoena duces tecum. The parties were unable to identify any other known individuals who should receive notice of the application at this time.
[13] …Second, the appellant seeks only the production of video footage depicting the commission of the assault. This narrows the request for production to four videos. Third, the appellant seeks only production of the two or three minutes on each of the four videos that depict commission of the assault. Finally, counsel for the appellant acknowledges that, even if produced to the Court, the videos would have to be pixelated to protect the privacy interests of others before being provided to counsel for use on the appeal.
III. The Test for Production: The First Stage
[15] In the context of this application, the onus is on the appellant to establish that the records are “likely relevant” to the appeal: O’Connor at para. 19; R. v. Gubbins, 2018 SCC 44 at para. 25; R. v. McNeil, 2009 SCC 3 at para. 28.
[16] To meet this test, the appellant must show there is a reasonable possibility the records could assist on the application to introduce fresh evidence, and a reasonable possibility the records may be received as fresh evidence on the appeal: R. v. Trotta (2004), 23 C.R. (6th) 261 (Ont. C.A.) at para. 25; R. v. Johnston, 2019 BCCA 107 at paras. 68–69, 80; R. v. Orr, 2020 BCCA 319 at para. 21; R. v. Schirmer, 2022 BCCA 214 at para. 54.
[17] While the sources and types of new evidence are more flexible in relation to sentence appeals, the criteria set out in Palmer v. The Queen, [1980] 1 S.C.R. 759, 1979 CanLII 8 apply. The Palmer criteria are inherently flexible and designed to serve the interests of justice: R. v. Lévesque, 2000 SCC 47 at paras. 14, 21. The interests of justice sometimes require balancing the “human realities” of the case along with the institutional limits of appellate courts and the important value of finality in criminal proceedings: R. v. Sipos, 2014 SCC 47 at para. 30.
[18] The burden to show “likely relevance”, while significant enough to empower a court to weed out speculative and unmeritorious requests for production, is not onerous. In assessing likely relevance, this Court is not determining whether the records would be admissible as fresh evidence; rather, at the production stage, the assessment is focused on a reasonable possibility of admissibility: Schirmer at para. 54.
IV. Analysis
[20] The Crown concedes that the appellant has met the test applicable at the first stage of the application. Crown counsel says the appellant has an arguable case that the assault perpetrated on the appellant “is a collateral consequence of his sentence which may serve to reduce that sentence on appeal.” In support of its position, the Crown cites a number of authorities including R. v. Suter, 2018 SCC 34, where Moldaver J., writing for the Court, said this:
[51] Our courts have held that where an offender is attacked by fellow inmates in a prison and the attack is related to the offence for which the offender is in custody, such violence may be considered as a factor at sentencing: see R. v. MacFarlane, 2012 ONCA 82, 288 O.A.C. 114, at para. 3; R. v. Folino, 2005 ONCA 258, 77 O.R. (3d) 641, at para. 29; R. v. Anderson, 2014 ONSC 3646, at paras. 14 and 18 (CanLII). Although being assaulted by a fellow inmate is not the same thing as being abducted and attacked by vigilantes, the rationale for taking these collateral consequences into account when sentencing an offender remains. In both scenarios, attacks relating to the commission of the offence form part of the personal circumstances of the offender. To ensure that the principles of individualization and parity are respected, these attacks are considered at sentencing.
[21] I would accept the Crown’s concession. As noted in Sipos at para. 31, “[g]iven the almost infinite variety of circumstances that may arise, it is neither desirable nor possible to formulate any hard and fast, detailed rules about the sorts of after-the-fact evidence that should or should not be considered in all cases.”
[22] Against this framework of established principles, I cannot exclude the reasonable possibility that a division of this Court would admit the new evidence at issue on this application. I emphasize that we are not deciding the admissibility of this evidence on appeal. That is a matter for determination by the division at the time of the hearing. We are only being asked to determine whether the appellant has discharged his onus of establishing the “likely relevance” of the proposed new evidence in the sense set out in para. 16 of these reasons.
[23] Accordingly, I would direct that counsel for the record holder obtain and produce to the Court those portions of the four videos that depict commission of the assault.
[25] Counsel for the record holder shall produce to the Court a vetted copy (containing any proposed deletions, redactions or video pixelations) and an un-vetted copy of the CSC records in question. At the same time, counsel for the record holder shall provide a brief written submission, not to exceed three pages, setting out the basis for the deletions, redactions or video pixelations in the form of a sealed memorandum to the Court, amplified by such further in camera and ex parte submissions and evidence as the record holder considers necessary and the Court permits.
R v JP, 2023 ONSC 6002
[November 1, 2023] Sexual Interference with a Minor: Implausible Recklessness [J.M. Barrett J.]
AUTHOR’S NOTE: Allegations of historical sexual interference/assault on minors are an area where there is rarely any evidence other than the testimony of witnesses. Where the account of both the accused and complainant seems credible in terms of demeanour and lack of motivation to fabricate, a jurist can consider (in the right factual circumstances) the shear implausible recklessness of the acts alleged to suggest they did not happen. Here, the complainant alleged full penetration sex while the adult partner of the accused went out for a cigarette. This struck the court as implausibly reckless leading to an acquittal.
OVERVIEW
[1] Mr. P. is charged with one count of sexual interference, contrary to s. 151 of the Criminal Code. The charge is based on allegations that between April 28, 2016 and December 31, 2019, he had vaginal and anal intercourse with his great niece, CH, when she was between four and eight years old.
[2] Mr. P. is married to CH’s maternal great aunt, MH. There is no issue that CH regularly slept over at the accused’s home on Saturday nights during the period of the alleged offence. There is also no issue that the conduct described by CH constitutes the offence of sexual interference. Consequently, the only issue is whether any of the acts alleged occurred.
THE EVIDENCE
[3] The background context to these allegations is not disputed.
ANALYSIS
[21] Having carefully considered the totality of the evidence in this case, I turn now to my conclusions regarding the allegations in the indictment.
[22] There is much consistency in the evidence of the Crown and defence witnesses. For instance, there is no dispute of the following: CH loved her Saturday overnight visits with her aunt; CH never voiced any complaint about any visit, even when her mother explicitly inquired after each visit; MH’s bedroom was about twenty steps from the front door; MH’s bedroom door had a lock; CH was never alone with Mr. P., other than when MH went to the front porch to smoke; when MH was outside smoking, CH stayed in MH’s bedroom watching videos on MH’s cellphone; and, when MH returned inside, she would go to her bedroom and find CH on the bed watching videos.
[23] The consistency in the evidence ends with what happened when MH went outside to smoke a cigarette. The only direct evidence on this issue is that given by CH and Mr. P. MH’s testimony provides some circumstantial evidence supportive of Mr. P.’s denial that any inappropriate touching occurred. MH’s testimony confirms the very limited opportunity that Mr. P. had to engage in the acts alleged.
[24] Mr. P. and his wife, MH, gave their evidence in a forthright manner. They were unshaken in cross-examination. Mr. P. was unwavering in his evidence that nothing inappropriate occurred. There were no material inconsistencies in the testimony of Mr. P. and his wife.
[25] The Crown argues that I ought to reject their testimony because neither gave credible evidence. In particular, the Crown argues that Mr. P. and his wife attempted to minimize Mr. P.’s opportunity to commit the alleged acts. The Crown further argues that MH’s testimony about her smoking habits1 was not credible; it is illogical that MH would only take four puffs of each cigarette and simply discard the rest. The Crown argues that this is an obvious attempt to assist her husband, as is MH’s claim that her husband was always in the living room watching television when she returned from the front porch. While I accept that MH has an obvious bias, I find that it did not affect her honesty and the reliability of her evidence.
[26] The Crown invites me to find that CH’s evidence is credible and reliable. The few inconsistencies that exist in her evidence and her inability to recall certain details, such as the number of times she was abused, must be considered in the context of her young age and the passage of time: see R. v. B. (G.) [1990] 2 S.C.R. 30, at pp. 52-54; R. v. W. (R.), [1992] 2 S.C.R. 122, at p. 134; R. v. P.S., 2019 ONCA 637, at paras. 25-26. Following from this, the Crown argues that if accept CH’s evidence, this is an adequate basis upon which to reject Mr. P’s denial: see R. v. D. (J.J.R.) (2006), 215 C.C.C. (3d) 252 (Ont. C.A.), at para. 53.
[27] The allegations in this case do not involve fondling — acts that could have easily occurred in a passing moment when CH’s aunt was not present. Instead, CH’s allegations are of anal and vaginal penetration which occurred after the partial removal of CH’s pants and underwear. According to CH, she told Mr. P. to stop but was ignored. He stopped only when his wife came back inside. However, the uncontested video of the home shows that the bedroom is a very short distance from the front door where the front porch is located. MH’s bedroom is at the end of a straight hallway from the front door. Yet, MH’s testimony is that after having just a few puffs of her cigarette, when she returned inside, she never saw Mr. P. in her bedroom, or exiting her room. Rather, she would invariably return to find CH as she had left her: on MH’s bed watching videos on MH’s cellphone. In these circumstances, which I find existed, it strikes me as implausibly reckless for Mr. P. to have repeatedly committed a sexual assault of this nature, given the unpredictable nature of MH’s return inside.
[29] CH presented as an amiable young girl, who believes she was sexually abused by her great uncle. However, proof beyond a reasonable doubt is a high standard. The inconsistencies in her evidence are not just about the number of assaults, their timing, or other such peripheral matters. While the Crown argues that the core of CH’s allegations has remained consistent, other than alleging that Mr. P. put his penis inside her vagina and butt, CH’s “core” account had minimal detail. Moreover, CH’s evidence was inconsistent as it related to her allegation that she was forced to sit on Mr. P.’s penis, and whether all of the assaults occurred in her aunt’s bedroom. In the circumstances of this case, I find that both of these inconsistencies relate to material issues. Ultimately, I am most troubled by the implausibility of CH’s account given the nature of the alleged assaults and the minimal opportunity of Mr. P. to commit the acts. [30] Although there is no apparent motive to explain why CH was upset and disclosed the abuse after learning of a planned overnight visit with her aunt in July 2020, it would be wrong to equate this apparent lack of motive to fabricate with a proven absence of a motive to fabricate: see R. v. B.T.D., 2022 ONCA 732, 163 O.R. (3d) 561, at para. 82; R. v. Gerrard, 2022 SCC 13, 468 D.L.R. (4th) 389, at paras. 4-5. Accordingly, the absence of an apparent motive to lie is of limited assistance in assessing CH’s evidence: see R. v. M.S., 2019 ONCA 869, at para. 16. Also, while CH was emotional at times during her police statement and at trial, reliance on demeanour evidence must be approached with caution.
[31] Having considered the evidence as a whole, I find there is no logical evidentiary basis to reject Mr. P.’s evidence. Regardless of whether or not I believe Mr. P.’s denial of any inappropriate sexual conduct, the defence evidence leaves me with a reasonable doubt.
CONCLUSION
[32] In all the circumstances of this case, I am not satisfied beyond a reasonable doubt that Mr. P. ever touched CH for a sexual purpose. I find Mr. P. not guilty.
Our lawyers have been litigating criminal trials and appeals for over 16 years in courtrooms throughout Canada. We can be of assistance to your practice. Whether you are looking for an appeal referral or some help with a complex written argument, our firm may be able to help. Our firm provides the following services available to other lawyers for referrals or contract work:
- Criminal Appeals
- Complex Criminal Litigation
- Ghostwriting Criminal Legal Briefs
Please review the rest of the website to see if our services are right for you.
