The Queen v. Lawrence Hibbert Case

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In the case, R. v. Hibbert , the appellant is Lawrence Hibbert and the respondent is Her Majesty, the Queen. Although there are multiple legal issues outlined in this case, the legal issue that is of concern is focused on the mens rea of party liability under s. 21 , and the meaning behind the phrase “for the purpose of aiding”. This case is significant due to the fact it highlights the interpretations of particular terms, which ultimately lead to a new trial.

The Ontario Court of Appeal dismissed the accused’s appeal from his conviction for aggravated assault. However, the accused made a second appeal on the ground that the trial judge’s charge to the jury on the issue of duress contained several errors. The accused was granted the appeal and a new trial was ordered. A lot of the discussion in this appeal revolves around the element of duress and the role it has as a defence to criminal charges.

Case Background

Fitzroy Cohen, a close friend of the appellant, was shot four times on the evening of November 25th, 1991. A drug dealer named Mark Bailey shot him in the lobby of his apartment building. The appellant, Lawrence Hibbert, accompanied Bailey during the incident. Cohen survived the shooting and Hibbert was charged with attempted murder, as a party to the offence. At trial, the appellant testified that on the night of the shooting he had unexpectedly ran into Baily, who indicated to him that he was armed with a handgun and ordered the appellant to take him to Cohen’s apartment. When Hibbert refused, Bailey punched him in the face several times. The appellant stated that he feared for his life and believed that Bailey would shoot him if he did not cooperate with him. Bailey drove the appellant to a telephone booth, where t...

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...e of R. v. Hibbert, such as “purpose”, “intention”, “desire”, etc. For instance, the term “purpose” found in s. 21 (1) (b) may have a different meaning in another section of the Code or in another statute. It is important for the interpretations behind of these words to remain open, especially in respect to the mens rea.

Conclusion

To conclude, the Supreme Court of Canada made a valid decision to associate the term “purpose” to “intention” when examining the expression “for the purpose of aiding” in s. 21 (1) (b) of the Code because it reflects the mental state of a person (mens rea), as opposed to the term “desire”. Essentially, I believe it was fair for the SCC to grant the appellant a new trial based on the new interpretation they provided.

Works Cited

Lawrence Hibbert, appellant

v. Her Majesty The Queen, respondent [1995] 2 S.C.R. 973 CCC (3d) 1

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