Photo: Clifton Campville Church Bells by Brian Webster (CC BY-SA 2.0)
The Supreme Court’s recent decision in R. v. Quesnelle, 2014 SCC 46 has got the legal community confused. In some respects Quesnelle is clear: police occurrence reports generated outside the present investigation fall under the Mills framework in cases of sexual offences. What is less clear are the implications of Quesnelle for non-sex offence cases – that is, cases that don’t have the added protections of the statutory framework in ss. 278.1-278.91 of the Criminal Code. In their paper, Frank Addario and Sarah Rankin make the case for police occurrence reports as first party Stinchcombe disclosure in cases that don’t fall under the Mills regime. Read the paper here: For Whom Quesnelle Tolls (2015).
