This morning, Canada’s right-wing government announced it will allow only two days’ debate on its Omnibus Crime Bill C-10. The Bill is just the beginning of the neoCON government’s “crack down on crime” agenda, having swept away criticisms citing the fact that all indicators show the crime rate is falling in Canada by focusing on “unreported” crime.
This despite the fact that the federal NDP has moved to sever portions of the Bill for swift passage to allow full debate on more contentious issues such as mandatory minimum sentencing for some crimes – for instance, the possession of six marijuana plants. The NDP’s Thomas Mulcair says
The Conservatives are trying to shove this down the throats of parliamentarians; there will be no full debate on this bill or on its costing and . . . we will not be hearing from experts in parliamentary committee.
Of course I’m much more concerned that the CONs are shoving this down the throats of Canadians. We’ve had full Senate committee hearings on mandatory minimum sentencing but nobody paid attention. Not the CONs most assuredly but 24% of the Canadian public didn’t care much either, voting the bastardos into a majority government on May 2nd.
An excellent friend of mine, Professor Elizabeth Sheehy of the Faculty of Law at the University of Ottawa, presented evidence to that ole Senate Committee back in 2009 when it was Bill C-15 – one of those Bills that died when Steve prorogued Parliament . She addressed the issue of the discriminatory effect that mandatory minimums have on racialised people, Indigenous people – and women. Particularly women belonging to those marginalised and exploited groups, such women being the twice exploited.
It’s a bit long and maybe legally technical. But everyone in Canada should read it. Because this is what we have to look forward to. Here it is:
Introduction: In Bill C-15, An Act to amend the Controlled Drugs and Substances Act and to make related and consequential amendments to other Acts,2 the Conservative Government seeks to create new mandatory minimum prison sentences. Minimum sentences of incarceration from six months to three years in duration would be required for a number of drug offences.
Under the proposed legislation, trafficking in a Schedule I or II drug (except a Schedule II drug in amounts not exceeding those set out in Schedule VII) will carry a mandatory prison term of one year if the offence was committed for a “criminal organization,” a weapon or violence was used or threatened in the commission of the offence, the offender had previously been convicted of a designated substance offence (ie “double doctoring,” trafficking, importing, exporting or production) or had served a sentence of imprisonment for a designated substance offence, in the last ten years. A minimum period of two years incarceration will be required if the offence was committed in or near a school, school grounds or other place frequently by persons under 18, if a person under 18 was involved, or if the offence was committed in a prison or on its grounds.
Importing a Schedule I substance less than 1 kg or a Schedule II substance (ie cannabis) will carry a mandatory sentence of one year if committed for the purpose of trafficking, the offender abused a position of trust/authority, or had access to a restricted area and used it to commit the offence. The mandatory sentence is increased to two years for Schedule I drugs in excess of 1 kg.
Producing Schedule I drugs would carry at least two years in prison, increased to three years if the offender used the real property of a third party, production was a health or safety risk to persons under 18 in the location or “immediate area,” production posed a public safety hazard, or the accused set a trap likely to cause bodily harm or death. Producing Schedule II drugs, except cannabis, would carry a minimum term of one year if production was for the purpose of trafficking or 18 months if, in addition to the trafficking objective, the health/safety risks noted above applied.
Producing cannabis will carry a minimum term of six months if the person grows between five and 201 plants for the purpose of trafficking; it will be nine months if in addition health and safety factors apply; it will be one year if the plants number between 201 and 501, and 18 months if the health and safety factors apply; it will be two years if the plants number 501 or more, and three years if the health and safety factors apply.
Sadly, Canada is no newcomer to the “race to incarcerate,”3 as the Supreme Court of Canada observed in R. v. Gladue:4
Canada is a world leader in many fields, particularly in the areas of progressive social policy and human rights. Unfortunately, our country is also distinguished as being a world leader in putting people in prison. Although the United States has by far the highest rate of incarceration among industrialized democracies, at over 600 inmates per 100,000 population, Canada’s rate of approximately 130 inmates per 100,000 population places it second or third highest…This record of incarceration rates obviously cannot instil a sense of pride.5
Bill C-15 will not only raise Canada’s incarceration rates: its new minimum sentences will also have a disproportionate, discriminatory impact on groups protected by s. 15 of the Canadian Charter of Rights and Freedoms who already experience historic and current political, social, and economic disadvantage, including Aboriginal Canadians, African-Canadians, Asian-Canadians, and women, particularly African-Canadian women. While sentences of between six months and three years might look mild as compared to US sentence terms, these new minimums may have an inflationary effect, increasing the length of incarceration above the minimum for many such offences. They will pave the way for future bills to increase the number and severity of minimum sentences, as we have already seen with respect to the escalation in the mandatory minimum for many firearms offences from four years to five if a “criminal organization” is involved. They will send the message that these crimes are somehow worse than crimes of violence against the person, where we do not (and should not) impose mandatory prison sentences. For example, the median sentence for sexual assault in this country is reported by Statistics Canada as 360 days imprisonment.6 It is disturbing to see drug offences designated as requiring stronger denunciation than crimes of sexual violence.
Witnesses before the Inter-American Commission on Human Rights, an autonomous organ of the Organization of American States, testified in its March 3d, 2006 hearing on the impact of mandatory minimum sentencing in the federal criminal justice system in the US:
[M]andatory minimum sentences—prison terms predetermined by Congress and automatically levied for drug and gun crimes—have resulted in excessively severe and arbitrary sentences, undermine judicial discretion, and result in disastrous social consequences. ….[T]he laws are violations of protected human rights …specifically the right to equal protection of the law, the right to a fair trial, and the right to judicial protection against violations of fundamental rights.7
Section 15 and Discriminatory Effects: Section 15 of the Canadian Charter of Rights and Freedoms guarantees equal protection and equal benefit of the law without discrimination. Canada’s courts have never been called upon to evaluate mandatory minimum sentencing against equality standards, and the evidence supporting the discriminatory impact of such laws is formidable. The Supreme Court has foreclosed judges from using the device of “constitutional exemption” to shield individuals from the harsh effects of mandatory minimum sentences,8 making constitutional challenges to the law itself the only safety valve to protect vulnerable groups from such laws. Our courts will face increasing pressure to invalid laws like Bill C-15 using the Charter.9
Laws can “discriminate,” contrary to s.15 through disparate impact on vulnerable groups either because they affect those groups in a manner disproportionate to their population or because those groups will feel particularly harsh effects emanating from those laws. As an example of the first kind of “discriminatory effects” claim, two judges of the Supreme Court of Canada in Sue Rodriguez’s case would have found the Criminal Code prohibition on assisted suicide to be unconstitutional because it was more likely to criminalize people with disabilities who cannot themselves end their own lives but require assistance to do so.10 Another example is provided by R. v. C.M,11 a decision in which Justice Abella at the Ontario Court of Appeal found that section 159 of the Criminal Code, which criminalized anal intercourse using a higher age of consent than that used for other forms of intercourse, had a discriminatory effect on gay men, in violation of s. 15. The Quebec Court of Appeal has reached the same conclusion.12
As an example of the second kind of “discriminatory effects” claim, Carol Daniels succeeded before the Saskatchewan Queen’s Bench in arguing against her incarceration in the Prison for Women in Kingston, Ontario (when we had only one women’s federal penitentiary) because the effects for her as an Aboriginal woman of being imprisoned far from home and community in an institution that had seen a high rate of suicide by Aboriginal inmates was particularly punitive and discriminatory.13 Another example can be found in a decision of the Saskatchewan Court of Appeal that found that the requirement for a licensing fee for an on-reserve bingo (taking it therefore out of the illegal gaming house provision in the Criminal Code) violated s. 15 for its discriminatory impact on Aboriginal accused who are entitled to tax exemption.14
Mandatory sentencing laws have discriminatory effects on many racialized groups in part because they are at the receiving end of targeted policing, whereby the neighbourhoods in which they live are subject to increased surveillance, and they are the subjects of “racial profiling,” whereby they are more frequently stopped by police for investigative purposes than are non-racialized individuals. The reality of racial profiling by police in Canada has been demonstrated by numerous studies,15 acknowledged by some police,16 and judicially noticed by the courts.17
Yet this targeting is not warranted when one examines the rate at which these groups are involved in drug crimes:
According to a Human Rights Watch Report released in April of 2009, although “Whites and blacks engage in drug offenses at similar rates, […] blacks were 2.8 to 5.5 times more likely to be arrested than whites in every year between 1980 and 2007,” the Drug War Chronicle reports (“Blacks Arrested on Drug Charges in Wildly Disproportionate Numbers, Rights Group Charges”). … As the organization’s senior counsel Jamie Fellner stated, “Jim Crow may be dead, but the drug war has never been color-blind. […] Although whites and blacks use and sell drugs, the heavy hand of the law is more likely to fall on black shoulders.”18
Further, the parameters used to impose mandatory sentences often exacerbate targeted policing. For example, the aggravating factor in Bill C-15 of alleged participation in a criminal organization will likely have disproportionate and discriminatory impacts on racialized and otherwise marginalized Canadians. As criminologist Mark Totten, Ph.D. noted in a 2008 Research Report, police statistics show that nationally a disproportion of reported young “gang members” is African-Canadian (25%); another disproportionately large group of youth gang members are Aboriginal (22%), while only 18% are Caucasian.19 A study prepared for the Department of Justice notes that various ethnic groups (especially African-Canadians and Asian-Canadians) are over-represented in certain “high-risk” neighbourhoods.20 In turn, the over-representation of these racialized groups in high-risk neighbourhoods for gang activity is related to their general disproportionate poverty and marginalization in Canadian society.
The new mandatory minimums will produce both forms of discrimination prohibited by s.15: members of racialized communities will be represented disproportionately among those arrested, convicted and sentenced under mandatory sentencing laws, and those sentences of certain imprisonment will exacerbate the social, economic and political inequality of already marginalized members of society. For example, according to the Supreme Court of Canada, “aboriginal offenders are, as a result of  unique systemic and background factors, more adversely affected by incarceration and less likely to be ‘rehabilitated’ thereby, because the internment milieu is often culturally inappropriate and regrettably discrimination towards them is so often rampant in penal institutions.”21 The Commission on Systemic Racism in the Ontario Criminal Justice System documented the particularly harsh consequences of imprisonment for African-Canadian men, who in prison are racially segregated and face alarming rates of racial abuse from other inmates and from guards, as well as other forms of discrimination.22 Imprisonment is also experienced disproportionately harshly by women, in light of the fact that women as mothers will be separately from their children, often permanently, receive fewer and less resourced programming, and may also experience gendered harms such as strip searching by male guards.23
It is true that s. 15 challenges can be defended by arguing that the problem is not the law but rather discriminatory enforcement,24 or that s. 15 violations can be justified in a free and democratic society using s. 1 of the Charter. One can only hope that the resilience of racial profiling practices by police will force our courts to re-think the wisdom of drawing such a sharp line between discriminatory laws and enforcement practices for Charter purposes when they work together to such ill-effect. Further, reliance on s. 1 to justify discriminatory effects on racialized Canadians seems manifestly undemocratic, particularly when all the social science evidence indicates that mandatory minimum sentences “do not appear to influence drug consumption or drug-related crime in any measurable way.”25
Canada faces a crisis of legitimacy with respect to the criminal justice system in light of the high rates incarceration of Aboriginal people that are grossly disproportionate to their representation in the population. The Supreme Court of Canada in R. v. Gladue spoke clearly on this issue:
Not surprisingly, the excessive imprisonment of aboriginal people is only the tip of the iceberg insofar as the estrangement of the aboriginal peoples from the Canadian criminal justice system is concerned. Aboriginal people are overrepresented in virtually all aspects of the system.
These findings cry out for recognition of the magnitude and gravity of the problem, and for responses to alleviate it. The figures are stark and reflect what may fairly be termed a crisis in the Canadian criminal justice system. The drastic overrepresentation of aboriginal peoples within both the Canadian prison population and the criminal justice system reveals a sad and pressing social problem.26
The Court exhaustively reviewed the data on overrepresentation when it interpreted the legislative intent behind Code s. 718.2(e). This section directs sentencing judges to consider all available sanctions other than imprisonment that are reasonable in the circumstances, “with particular attention to the circumstances of aboriginal offenders.”
The Court noted that:
By 1997, aboriginal peoples constituted closer to 3 percent of the population of Canada and amounted to 12 percent of all federal inmates: Solicitor General of Canada, Consolidated Report, Towards a Just, Peaceful and Safe Society: The Corrections and Conditional Release Act — Five Years Later (1998), at pp. 142-55. The situation continues to be particularly worrisome in Manitoba, where in 1995-96 they made up 55 percent of admissions to provincial correctional facilities, and in Saskatchewan, where they made up 72 percent of admissions.27
In spite of s. 718.2(e) and the Court’s guidance to the lower courts in Gladue, the over-representation of Aboriginal people in prisons has only increased since 1999, when the decision was released. One study reported an increase in Aboriginal admissions to custody of 3% as of 2001, bringing the national rate for Aboriginal offenders serving jail terms to 19%;28 most recently, this incarceration rate has climbed further, to 22%, according to Statistics Canada.29 In fact, the main beneficiaries of the sentencing reform appear to be non-Aboriginal offenders, who experienced a decrease of 22% in admissions.30
The legacy of colonization and specifically the use of the Indian Act to separate Aboriginal peoples from their lands, their culture, their children, and their governance, is a population that is both impoverished and vulnerable to the use of drugs31 to escape what Justice Murray Sinclair has called “collective social depression.”32 As noted by the Supreme Court in Gladue:
The unbalanced ratio of imprisonment for aboriginal offenders flows from a number of sources, including poverty, substance abuse, lack of education, and the lack of employment opportunities for aboriginal people. It arises also from bias against aboriginal people and from an unfortunate institutional approach that is more inclined to refuse bail and to impose more and longer prison terms for aboriginal offenders.33
The new mandatory sentencing laws will undoubtedly add to the over-incarceration of Aboriginal people given the profiling of Aboriginal people (for example the Kingston study found that Aboriginal pedestrians were 1.4 times more likely to be stopped by police than were Whites34) and the profiling of “Aboriginal gangs.” Professor David Tanovich provides the following example: “Having identified Aboriginal membership in certain street gangs such as the ‘Indian Posse,’ ‘Ruthless Posse,’ and ‘Manitoba Warriors, a number of Winnipeg police officers appear to be routinely conducting spot checks based on nothing more than a person’s Aboriginality and, sometimes, clothing.”35 Several reports of major drug arrests show a focus on Aboriginal reserves as locales for drug production, such that reserve lands may in future be subject to targeted surveillance.36 In addition to the “criminal organization” factor that will trigger the mandatory sentences the factor of firearm use may also disproportionately affect Aboriginal accused.37
The proposed mandatory sentencing laws will negate one important tool, s. 718.2(e), which can and should be used to keep Aboriginal offenders out of jail, especially for drug offences. As the Supreme Court said in Gladue:
There are many aspects of this sad situation which cannot be addressed in these reasons. What can and must be addressed, though, is the limited role that sentencing judges will play in remedying injustice against aboriginal peoples in Canada. Sentencing judges are among those decision-makers who have the power to influence the treatment of aboriginal offenders in the justice system. They determine most directly whether an aboriginal offender will go to jail, or whether other sentencing options may be employed which will play perhaps a stronger role in restoring a sense of balance to the offender, victim, and community, and in preventing future crime.38
Bill C-15 will effectively repudiate s. 718.2(e) and swell even further our jails with Aboriginal offenders, in violation of s. 15. As Larry Chartrand outs it: “any statutory provision that denies Aboriginal offenders the benefit of such a targeted and remedial provision is itself discriminatory.”39
It is well documented that the impact of mandatory minimum sentences instituted in the United States has been disproportionately felt by African-Americans,40 the over-incarceration of whom has contributed to vicious cycles of continuing social problems, including poverty in American inner cities and in African-American communities and families. Family and social relationships, employment and education opportunities all suffer upon incarceration. 41 When released, support systems may have disappeared and jobs are hard to come by. Drugs and crime may be one of the few options available.
Patterns of incarceration in the United States since the “war on drugs” policies were adopted in the 1980s, using mandatory minimum sentences, show a huge increase in the prison population, with African-Americans over-represented and a high recidivism rate. In 1994, African-Americans represented about 13% of drug users in the United States, but 74% of those imprisoned for drug offences.42 In spite of the harsh approach to sentencing that has been taken in the States, it has not been shown to decrease crime. This disproportionate impact and its devastating consequences have been important reasons why legislatures in the US are moderating mandatory minimum sentence laws43 just as Canada’s current government seeks to introduce them.
While the Canadian social context is unique and different f.rom that of the United States, similarities are significant in that there is widespread and systemic racism against Canadians of African descent and these individuals are economically and politically marginalized. The conditions leading to disproportionate impact of US mandatory minimum sentences on African-Americans are substantially similar those that lead to disproportionate impact of mandatory minimum sentences on African-Canadians, should Bill C-15 become law.
Conscious and unconscious racism colour who police and security forces in Canada monitor, arrest and charge. African-Canadians are more likely to be stopped by police than Whites by a factor of 3.7, according to a police-initiated study in Kingston.44 Racial profiling has been documented as a practice at the level of police and airport security,45 and extends even to African-Canadian police officers, who themselves report being “profiled” by fellow officers.46 African-Canadians are also more likely to be charged, less likely to benefit from prosecutorial discretion in terms of Crowns electing to proceed by way of indictment instead of summary conviction, less likely to be released on bail, and face harsher sentencing compared to Whites. Research based on Toronto police reports between 1996 and 2002 reveals that:
1) Black people charged with simple drug possession are taken to police stations more often than Whites facing the same charge;
2) Black motorists are ticketed at a rate of 4.2 times that of Whites for violations that only surface following a traffic stop and;
3) Blacks accused with a crime and taken to a station are held overnight for a bail hearing twice as often as Whites.47
As Faizal Mirza observes, “the impact of racial profiling and the poor use of prosecutorial discretion are even more severe under mandatory prison sentencing laws: Black people who are unfairly and disproportionately targeted for criminal investigations will likely succumb to more guilty pleas, stiffer penalties, and higher incarceration rates.”48 He explains: “Overall, disparate rates of charging and pre-trial imprisonment of Black people combined with the threat of mandatory prison sentences upon conviction, may induce more Black defendants to accept a guilty plea and prison time (albeit reduced) regardless of their level of blameworthiness in order to avoid long periods in prison.”49
Increased incarceration rates of African-Canadians will further embed systemic racism against the African-Canadian community, wrongly give the impression that African-Canadian crime is increasing, and convey that African-Canadians are more likely to be involved in drugs and crime.50 In fact, argues David Tanovich, the “war on drugs” has become a “war on Blacks.”51 The Commission on Systemic Racism in the Ontario Criminal Justice System reported in 1995 on the massive over-representation of African-Canadians in Ontario jails, noting a 204% increase in admissions among African-Canadians from 1986/87 to 1992/93. When focused on drug-related admissions, the Commission found that the increase rate was several thousand per cent.52 While representing only 3% of the population, African-Canadians were being incarcerated at a rate of 15.3%.53 Further, “the majority of accused admitted to Metropolitan Toronto prisons for drug trafficking and drug importing offences were Black.”54 Tanovich argues that this war on drugs is seriously misguided, in that it contributes to gun and gang violence:
With its use of a drug courier profile and intensive policing of poor and racialized communities, the war on drugs and racial profiling have created a one-way ticket to jail for many young Black men in Toronto. The limited education and employment opportunities that existed for them before prison because of systemic racism become even scarcer upon release. Is it really a surprise that many of them turn to informal structures where they find self-worth, respect, community, and a means of earning a living?55
The new mandatory minimums will exacerbate the incarceration crisis of African-Canadians, and further reinforce racial divisions and disparities in Canadian society.
The potential for discriminatory impact of mandatory minimum sentencing on Asian-Canadians must be examined in light of both the historical and present-day realities of the Asian-Canadian experience. There is a long history of legislative discrimination against Asians in Canada, including restrictions on immigration and exclusion from eligibility from holding public office, or practicing certain professions.56 In fact, Canada’s first narcotic drug-control legislation was primarily aimed at criminalizing Chinese opium users.57 Nor has such treatment been limited to days gone by.
While Asian-Canadians do not yet seem to be over-represented in our prisons, that may change in light of racial profiling and the increased surveillance of gang-related activity. For example, Alberta’s Annual Report of Criminal Intelligence Service for 2004/05 reported: “There are a large number of groups composed of Asian criminals who, collectively, dominate the distribution of cocaine and marijuana.”58 The 1998 Annual Report of the Criminal Intelligence Service of Canada reported: “Vietnamese gangs, made up of both ethnic and Chinese Vietnamese…control much of the street level drug trade in Vancouver….More than half the targets of the Calgary Police Service Drug Undercover Street (DUST) team are Asian criminals. There is every indication that these individuals are actively expanding their share of the local drug trafficking scene.”59 In fact a 1998 study reported that 45% of Vancouver gang members were Asian.60 Canadian courts are seeing racial profiling cases involving Vietnamese accused,61 and we should expect that the new mandatory minimum sentences will also affect Asian-Canadians.
Women, and Particularly African-Canadian Women
Mandatory prison sentences affect women very harshly. When judges lose the ability to mitigate sentences by reference to women’s lack of prior criminal history, the non-violent nature of their crimes, and their family obligations as mothers with the primary responsibility for their children, women’s incarceration rates soar. These effects are worsened when women have been brought into the criminal justice system through their histories of sexual abuse, victimization and addiction—particularly when they serve sentences in male institutions or under male guard. Women also feel the effects of imprisonment acutely when they lose custody of their children in consequence, the prison programs available are inadequate, and the prisons are far from their homes.62 Moreover, the worst effects of women’s imprisonment for drug crimes will be felt by their children, whose “[n]egative behavioural manifestations can include sadness, withdrawal, low self-esteem, decline in school performance, truancy and use of drugs or alcohol and aggression.”63
The discriminatory effects of mandatory jail terms are heightened for women when added to drug offences. In the US, women are described as the fastest-growing prison population, a phenomenon almost exclusively attributable to mandatory sentencing laws for drug crimes.64 This is partly due to racial profiling, discussed below, but also because women’s involvement in the drug trade is invariably at the low level where visibility to law enforcement is high. Many such women are themselves drug-dependent, which renders them more vulnerable to both participation and detection. Further, as the Canadian HIV/AIDS Legal Network points out, mandatory minimum sentences fail to consider the relational position of women, wherein many women charged for drug-related offences have had minimal involvement with the crimes, but instead were involved with a male partner engaged in drug trafficking. If the woman was dependent upon that male, or involved in a violent relationship, the unfairness of a mandatory sentence that ignores minimal or coerced involvement is compounded.65 In the US many women have been convicted of drug crimes in spite of having minimal involvement with drug trafficking: “Unlike typical conspirators, these women find themselves involved in criminal activity because of social or cultural pressures, and their criminal activity is an uninvited and often unforeseen repercussion of choosing an intimate relationship.”66
African-Canadian women will be the sub-group of women most dramatically affected by mandatory prison sentences. They are already profiled disproportionately to their involvement in drug importing,67 and over-incarcerated at seven times the rate of White women.68 A report developed by the Commission on Systemic Racism in the Ontario Criminal Justice System reveals that while both African-Canadian men and women are over-represented in the criminal justice system, incarceration rates in provincial prisons are significantly higher for African-Canadian women in comparison to their male counterparts.69
Although clause 5 of Bill C-15 allows a court to delay sentencing to allow an offender the opportunity to participate in and complete a Drug Treatment Court Program, and possibly to avoid the mandatory prison term, this clause will be of little assistance to many women caught by these new laws. This is a significant problem for African-Canadian women convicted of drug trafficking because many of these individuals will not fall within the substance abuser category: “Situated at the intersections of the North and the South are the women from poor countries and the poor women from rich countries who work as couriers, carrying small quantities of prohibited drugs from source and transit states into those in which consumers reside.” 70 It seems evident that the new mandatory minimum sentences will augment the number of women currently imprisoned, with African-Canadian women and their children feeling the worst effects.
Conclusion: Should Bill C-15 become law, offenders who may have received compassionate sentences such as a conditional imprisonment or suspended sentences, will be imprisoned. Prisons will be filled, and will have to increase in size. The federal government has already doubled its budget for prison construction and maintenance to prepare federal institutions for an influx of inmates resulting from its new crimes bills, including the mandatory minimum sentencing laws.71
Bill C-15 will have financial and social costs that are not justified by corresponding benefits. All evidence suggests that mandatory drug sentencing laws in the US have “imprisoned mostly low-level, non-violent offenders,” and that “treatment-oriented approaches are more cost effective than harsh prison sentences.”72 More and lengthier jail terms will not only raise prison maintenance costs will increase those associated with supporting children whose parents are incarcerated and reintegrating offenders after incarceration. Fewer resources will be allocated to education, social welfare and social programs such that the root causes of crime, such as poverty, unemployment, and social marginalization will be flourish. Sadly, Bill C-15 will lead to more drug crime, not less.
Elizabeth Sheehy, LLB, LLM, LLD