The Ontario Court of Appeal has recently released its decision in R. v. Michaud, 2015 ONCA 585 . This decision is of importance as the Court’s endorsement of the hybrid model of ex ante / ex post legislation has the effect of recognizing the role of risk assessment as a legal necessity.

The Supreme Court of Canada released its anticipated decision in Guindon v. Canada[1] on July 31, 2015, which held that administrative monetary penalties (“AMPs”) under section 163.2 of the Income Tax Act (the “ITA”)[2] are not offences that trigger constitutional protections such as the right to be presumed innocent. Other…