Bruce Carson v. Her Majesty the Queen

(Ontario) (Criminal) (As of Right)


Criminal law - Influence peddling - Interpretation - Whether the phrase “any matter of business relating to the government” in s. 121(1)(a)(iii) of the Criminal Code, R.S.C. 1985, c. C-46, as adopted by reference in s. 121(1)(d) of the Criminal Code, includes the sale of point of use water purification systems to First Nations Bands.


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The appellant was charged with influence peddling, contrary to s. 121(1)(d) of the Criminal Code, in relation to his attempt to persuade First Nations communities to buy water treatment systems being sold by a company that employed his then-girlfriend. While the appellant admitted he was a person who had influence with the government and that he had demanded a benefit for his girlfriend in exchange for exercising his influence on behalf of the company for which she worked, the trial judge entered an acquittal on the basis that the appellant’s conduct did not fall within the purview of s. 121(1)(d). Specifically, she found that the appellant’s activities did not involve “any matter of business relating to the government”. A majority of the Court of Appeal allowed the appeal and entered a conviction. Simmons J.A., dissenting, would have dismissed the appeal.

Lower Court Rulings

November 17, 2015
Ontario Superior Court of Justice

13-20008, 2015 ONSC 7127
Appellant acquitted of influence peddling
February 17, 2017
Court of Appeal for Ontario

C61464, 2017 ONCA 142
Appeal allowed