Police Investigations 101
Lessons for Prosecutors from William Deverell’s The Long-Shot Trial[1]
Gilles Renaud (Ontario Court of Justice 1995-2023)
Introduction
William Deverell’s signal career at the Criminal Bar saw him both prosecuting and defending a great number of prominent accusations but his success as a litigator is now obscured by his fame as a writer. Writing dozens of highly acclaimed legal novels will do that for your reputation! If you have not had the pleasure of reading one of his books, please go to the library, the bookstore or one of those computer sites that permits you to have a title delivered overnight. Indeed, anyone wishing to enjoy an otherwise dull flight, or train trip or long wait somewhere, should take out one of his books and read for hours of pleasure. Moreover, if you are a litigation lawyer, I suggest that you keep a pencil handy, as I do, and underline every useful illustration of trial tactics, cross-examination, and instruction on human nature on display, not to overlook guidance as to the means of “judging judges, counsel and police officers” that his writings provide in abundance.
The most enjoyable advice is focused upon the skill demonstrated by Arthur Ramsgate Beauchamp, Q.C. This beloved defence lawyer is described defending the second murder trial of his career, at age 29, in 1966, in Northern British Columbia, after having been unsuccessful in defending a young individual a few years earlier, when perhaps he was too young and inexperienced, as suggested at page 26.[2] We read at page 60 that a young Arthur could recite “from Keats with a naked hooker on my lap.”
For those lawyers for both Crown and defendant who wish to enjoy the fruits of Mr. Deverell’s literary labours, so to speak, without reading this book, I offer a thematic review of his instruction on human nature, trial strategies, cross-examination, office politics, work-life balance, and so much more on the study of human foibles. In brief, The Long-Shot Trial is a highly entertaining and yet sobering at times explanation of our criminal justice system.
A final and further introductory observation. The book is full of examples of a young lawyer wishing to influence an apparently honest defendant that she could not have meant to kill her rapist-employer and the various knots he twists himself into in attempting to honour his oath to the Court and his duty to his client is quite illuminating. The struggles of prosecutors when faced with a person who might escape what is judged to be “a fit finding of guilt” is not far removed from that inner debate.
Discussion
Advocate must stay in control
The last lesson on advocacy found in this text is at page 271: “Don’t overdo, stay in control.”
Advocate’s duty to raise issues no matter the secondary costs
Young Arthur mused a great deal about the potential harm to a young man if the defence raised the suggestion made by others that he had recently threatened to kill the victim. In particular, as set out at page 125, he feared that anti-Native bias would be heightened. That said, counsel was experienced enough to know that he had an ethical duty to raise fearlessly all legitimate avenues of defence.
Assumptions
It is always dangerous for the police to assume certain facts. For example, page 33 includes the comment that the detectives “… therefore made the bold assumption that Angelina plugged [shot] him as he turned his back to her and relieved himself.” The fact that his fly was undone and his penis exposed could also be consistent with criminal offences, and the defence exploited the defendant’s immediate comment that the deceased had raped her quite recently. On this subject, it is worthy to quote a further passage from page 33: “I had to assume that they had touched up the report with assumptions, based on the fact that the [deceased] had been shot in the back.”
Audacity of youth over cool headedness
That is how Beauchamp explains his ultimate trial decision, at page 264, to not call her as a witness.
Bias
Prosecutors often gain a good deal of advantage when questioning witnesses for the defence as to their relationship with the defendant, and the bias that may arise from these ties. See page201 for example. What I have noted over the years is that defence counsel will often suggest to a police witness that they will not say anything negative about the actions of their partner or squad mate but never ask about their relationship outside of the office, such as fishing or gold outings, trips, etc.
Coaxing a witness to recall things a certain way
The account of the trial preparations from 56 years earlier includes this comment: “… I was coaxing him, an ill-advised practice.” This advice rings true for all counsel at all levels of Court.
Counselling the defendant to lie
Mr. Deverell includes a fascinating passage at page 56: “I mused: what if I could persuade [the defendant] to remember that the screen door closed suddenly, striking her elbow, causing the rifle to fire accidentally. I could not counsel her to lie, of course, but she might be open to have her memory jogged?” Over the next few days, the young Arthur regains mastery of his integrity, but he recalls 56 years later how his wish to assist an innocent defendant clouded his better judgment, then and later on …
In this vein, consider what we read at page 64 of Arthur’s attempt to review his work in this case in which his client, charged with murdering her rapist, was quite young and vulnerable to suggestion:” I blush in shame over [my] social awkwardness, [my] pushy interview techniques. I was practically cross-examining my client and offering not a thimble of empathy.”
Cross-examination – a religious person
The Crown wisely did not cross-examine Father Larouche, as the testimony was largely self-serving for the obvious benefit of the defendant, to whom he stood as her religious superior and mentor, and nothing would be gained that could not be obtained through other cross-examination. As we read at page 211, “… it was a loser’s game to attack a holy man.”
Cross-examination – End on a high note
This is a rule of thumb suggested at page 172.
Cross-examination – Judge is content to allow you to do so to your own witness
On rare occasions, possibly by reason of the fact that the judge will grant no weight to the answers or will direct the jury to ignore it all, the Court will tolerate you leading or cross-examining your own witness. See page 238 and page 239, wherein the judged put the brakes on, so to speak, and page 242: “I took [the judge’s] silence as permission to persist…”
Cross-examination of the police – Compare and contrast with other information
Mr. Beauchamp asked a police officer at page 137, “But you’re aware that the dispatcher recalled [the defendant’s] words” as ‘I think I shot [the deceased].’” There is no rule against introducing the words of others, whether on the record already or to be introduced, based on disclosure, even if they were spoken while the witness being cross-examined was excluded. I recall a prosecutor objecting to that situation, but I ruled that the point of excluding witnesses is to allow counsel, for the prosecution or the defendant, to propose such suggestions.
Cross-examination of the police – “Maybe” type of responses
I suggest that there is nothing incorrect in a police officer suggesting that a defence suggestion might be correct, if you cannot reject it outright. As we read at page 141, “maybe” there was a gunshot noise followed by a loud echo…” Later, at page 213, one reads: “Crown. Could have been there for years, right?” “Witness. I guess. I don’t know. I am just a house painter.” I never thought it was useful for a police witness to testify: “Anything is possible” when a precise question is asked. In this instance, the police officer is not denying that there was an echo, which seems reasonable as a gunshot in the mountainous area involved might well lead to an echo. If the officer is too keen to close off a potential avenue that might appear to be helpful to the defence, he or she is likely to be seen as less than objective. In that vein, the officer was asked if a powerful weapon might have led to the victim’s body being spun around and he replied: “It could, I suppose, but I have only seen that in cowboy movies.” See page 142.
Cross-examination of the police – One question too many
This famous rule for lawyers, both Crown and defence, is discussed briefly at page 165 when Mr. Beauchamp asked a forensic officer about the possible actions of the deceased after being struck by the high-powered projectile but before death. This was not a police officer but the same dynamic is involved.
Cross-examination of the police – Suggest absolute answers
Mr. Beauchamp drew out for a police witness the signal unlikeliness that a person who shot at another for the first time in her life, and who did so in so poor a manner that she hurt her shoulder where the gun touched her skin, nonetheless managed to hit the heart, thus the title’s suggestion of a “long shot”. See page 137. It is not the function of the police witness to fence with counsel but rather to accept the suggestions advanced, such as the existence of bruising due to the recoil, and to answer with the information being accepted at face value. Thus: “I am aware of bruising and I take into account your suggestion of never having shot a gun before, but the evidence leads me to inform the court that the deceased was killed by a bullet to the heart.” The Crown will object if the factual suggestions that you are not aware of are false.
Crown’s opening statement
What Mr. Deverell illustrated at pages 130-131 is the classic wise tactic: “Brief and emphatic”, and Crown counsel acknowledged the tragedy of the fate that had befallen the defendant, with the background of a rape accusation.
Demeanour
Page 157 includes these words: “His face showed contrition and repentance.” This strikes me as a reasonable inference, though I am a poor partisan of demeanour evidence.[3] An example that I find difficult to credit is found at page 258: “When she finally made eye contact, her look was intense and pleading. I’m trying my best. Is this what you wanted?” Finally, I do agree with the suggestion made by Mr. Beauchamp as to the trial judge: “He can’t help it. His face is hard-wired to look pissed off.” See page 262.
Devising defences
We read that page 27 that defence lawyers spend some of their time devising defences. Prosecutors must elaborate prosecution theories, in the same vein. Of course, some potential defences are ludicrous such as the line consigned at page 49: “Can’t she just say she forgot hunting season was over and mistook her boss for a moose?” Noteworthy is the quote found at page 61: “Bereft of ideas about how to defend her, I could only hope to bluff my way through the trial, hoping for a miracle. I would need one, because even a sympathetic hometown jury would be strapped to come up with a doubt remotely reasonable.”
Evaluate the strength of your potential witnesses
This is illustrated at page 118 when a young Arthur judged that “Ned Best would be a risky witness.” He was, as the prosecution made him concede that there was only one gun blast, harming the defence theory of an alternative shooter.
Fighting for success as a defence lawyer; seeking justice as a prosecutor
As we read add page 30, defence lawyers must be tenacious in defending the interests of their client. Crown counsel, in conformity with the Boucher principle. Fight for justice.
Find out what you must know
Counsel must not follow the poor example shown by the young Arthur who avoided ascertaining if one of his prime secondary suspects possessed an alibi during the time of the shooting. See page 116.
Evaluating your potential witnesses
We read at page 258: “I was mindful of another dictum [from the advocacy greats]: An equivocating client is a witness best not heard…” This suggestion is not always governing in the case of Crown counsel who may be duty bound to present a witness that appears to have merely a passing acquaintance with the truth by reason of the duty to ensure a fair trial to the defendant, such as when the defence requires an alibi witness to be made available from a detention centre.
Honest clients were rare, in Arthur’s experience
The author notes that the young Beauchamp defended a great number of narcotics cases and is quoted at page 58 as follows: “But would I find it awkward relating to a client who, apparently, was incapable of telling lies. Most of my defendants hadn't suffered that handicap.” The next page includes a correct direction to a client in preparing her for testimony: “Please think deeply before you say anything. This was an extremely tense time period you may not have remembered --.”
Hubris
All lawyers who earn their living in the courtroom must be mindful of the dangers of hubris becoming an obstacle to their success, as Arthur muses at page 255 when he appears hungover in court. For my purposes, it is best defined as “excessive pride or self-confidence”.
“I am not sexist” type of comment is typically followed by a sexist comment
We read at page 20: “Not sounding sexist, which I'm probably not, but cleaning is generally accepted as ladies work…”
Influence on the defendant’s testimony of what they hear in Court
Unlike all other potential witnesses, the defendant in a criminal case cannot be excluded and the Crown will often score points by suggesting, in cross-examination, that certain responses were tailored to reply to testimony that the defendant heard in Court. See page 202 wherein we read “… it sounded like … let us say, a convenient memory prompted by what she’d heard in court.” This may be influenced by what was said during the preliminary inquiry. At page 257, the defendant is being interviewed again by Mr. Beauchamp in preparation for her testimony and she refers to a truck that was nearby, leading defence counsel to think: “This was pathetically untruthful. She had adapted her story to fit with [what he heard in court]. … I was the Svengali who had corrupted the incorruptible – I had transformed this virtuous maiden into an inelegant liar …” Finally, at page 262, Mr. Beauchamp states: “… Nor am I interested in cooking up a spurious defence. I won’t lose my soul to win an acquittal.”
Insensitive comments made by counsel in litigation
One of many examples is found at page 34 when Arthur asked if the victim of the rape had been badly mauled. The senior lawyer shrugged, “Nah, just raped. Minor bruises…” Indeed, the author can be fairly criticized for referencing “violent rape” on several occasions as rape is always a violent crime. For example, we read at page 80: “Our only proof that the rape was violent …” There is no other characterization that is fit on the foundation that there are other offences that address the infliction of injuries, the resort to a weapon, etc.
Jury charge – request for further instructions’
The danger is that you might raise a minor objection that will only undermine the jury’s desire to get on with their duty. See page 283.
Jury selection – former military personnel
Mr. Deverell suggests by means of his main character that “… old soldiers tended to ally themselves with the Crown…” See page 98.
Jury selection – good hearted people
Further, the author states at page 98: “… people of good heart often give off an aura of empathy.”
Leading question, example of
The Long-Shot Trial includes this passage, from page 135: “Crown And while you were busy with that, did you hear a gunshot?” “Defence: Objection … Leading.” “Crown I will rephrase. Did you hear a loud noise?” From my perspective, the prosecutor was still leading in that the witness was lead to the area of a noise as opposed to invited to describe the events. More to the point, by suggesting at first “a gunshot” and then “a loud noise”, the witness was invited to focus on a single noise when the defence was going to focus on the likelihood of two shots being fired quite close to each other.
Consider also page 200: “Defence She also told you about a previous assault –” “Crown Objection. Leading.” “Defence Sorry. Did she mention any previous physical incidents …”
Logic in your step-by-step summation
We read at page 281 that the Crown stumbled when it attacked the defence theory by suggesting that the allegation of rape was spurious – leading the Court to ask what was the motive to kill if there was no sexual assault? Each part of the bridge must be linked or there is a danger of a fatal fall.
Media baiting – to be avoided
“I’d ignored a rule of the profession – don’t bait the media …” See page 156. It applies to all sides.
Memory issues
Arthur states to his wife to explain his failure to buy her a Valentine's Day gift, “… the occasion slipped my famously absent mind…” See page 13.
Later, and page 18, we read “who retains a mind lucid enough to recall a capital murder trial in 1966, with his twists and riddles and sworn secrets?”
We read at page 20 that Arthur Beauchamp will not need to tax his memory as he has access to the trial transcripts from the hearing 56 years earlier. Mr. Deverell wrote that Arthur will not need to command my memory to speak, to use a Nabokovian allusion…” be that as it may come up, the writer points out that the conversations that Arthur recalls about his assignment of this murder trial is “as best remembered”. See page 25. Refer as well to page 86: “[This book] will not lack for accuracy: every spoken word is in these five volumes, including my squabbles with the judge.”
One of the frequent elements of controversy in this book surrounds Arthur’s efforts to assist his client’s memory. For example, we read at page 78:
“Do you remember what you said on the phone to the police?”
“I said ‘I shot Mr. Trudd, and I think he's dead.’”
“You actually said, ‘I think I shot Mr. trod in he's dead’. So you actually weren't sure you shot him.
She shook her head. Then, softly, “I know I did.”
Finally, it is noteworthy that page 91 includes this technique to refresh one’s memory: “… started scribbling an aide-memoire of our conversation.” The conversation had just taken place so that this would be as contemporary as he could achieve, short of writing his notes as he conversed with a witness. A prosecutor would have a police officer record information in many instances, but not invariably.
A further issue surrounds a memory that suddenly improves. As we read at page 210, “… her ‘moment of remembrance’ … was indeed like fog receding, as if from a sudden summer breeze.” Later, on the same page, there is mention of a flashback.
Money talks
We read at page 60: “When you are serving the richest f…er in town, he doesn’t come to you, you go to him.” All that is perfectly reasonable, but the lawyer cannot sell his or her integrity.
“No problem” hints at problems
We read at page 16 that his infamous island handyman, Robert Stonewell, alias “Stoney” (in part due to his state of intoxication due to substances) would often say on taking up any task “No problem”. This mantra would be recited whenever he was reminded about delinquent or incomplete work. Crown counsel needs to be surrounded by competent and dedicated and clear-minded collaborators, not by those who say, “No problem.”
Note taking – the issue of comparing notes
One witness testified at page 137 that not only did he hear the defendant state, “I shot him”, but he made a note and testified further that his partner heard the same words and made the same note. Mr. Deverell did not suggest that this was a faulty practice as Mr. Beauchamp did not take issue. The officer is quoted at page 139 as verifying with his partner as to the accuracy of a late entry.
Note taking – the issue of late entries
Page 138 illustrates the correct practice of making a late entry note in your notebook if you recall some information that you earlier had not remembered when you made a first entry. I suggest that you write down the time you made the first of your notes, and the time of your second notes by way of additions.
Note taking – the issue of their absence
Defence counsel make “hay”, so to speak, by their absence but it seems to me that prosecutors do not spend enough time pointing out to defence witnesses and defendants how little they noted down at the relevant time. See page 182 for a defence question in preparation for trial of a person who took no notes.
Oath of a religious nature
Pages 134-135 set out the judge’s terrible reaction to the former practice of a police officer kissing the Bible prior to testifying. Not a practice that is common today but was during my first years as a law student. By way of contrast, page 215 illustrates the situation of a jury member being visibly upset when a witness refuses to take a religious oath, leading to a solemn affirmation. One hopes this is no longer the case.
Opening statements to the judge or jury
“Lazy counsel neglect the opening. Wise counsel exploit it. Make your opening sing.” See page 199.
Passage of time in recalling events
Generally, it is hardly surprising that versions of events would differ slightly if a half-century has elapsed between event and recall. See page 37. The author added at page 39: “Memories of even steely minds tend to rust over the years, like carving tools left out in the weather.”
Police conclusions are sound
A first example is the police view that if the deceased had two lengthy marriages without issue, it is highly suspicious that he then impregenageted the victim. See page 53.
Police prevented from speaking to defendant due to police policy
It is obvious that the police may be told by a detainee or arrestee that they wish to avail themselves of their right to silence and not respond to questions. A different scenario arises when the police at the scene, or at the station, are directed by their superiors to not interview the person taken into custody and to wait for others to start the questioning. This is what we read at pages 144-145. The defence will be glad to point out that had they asked their client right away what happened, after giving rights to counsel in full, their client would have gladly provided a full account setting out the helpful circumstances that might have justified their actions. To not interview promptly leads to difficulties for the defendant such as increased fatigue and a confused state of mind, though you must prepare questions in a logical way, of course. Look at the question in this manner: British police shows and movies often include the warning: “If you fail to answer our questions now and later reveal information that would have been helpful to our investigation, the judge or jury may take a negative view of your statement.” In other words, if you were acting in self-defence, why not tell the police that important information upon arrest?
In the final analysis, the police ought not to bring about this scenario: “[Defence] The accused seemed willing to talk, and that opportunity was missed.” [Page 145]
Police testimony
The author described the phrase spoken by a young police officer in these terms: “Spoken with the strained syntax learned from police training manuals.” Whether Mr. Deverell is correct or not, police are in the habit of saying “I exited my vehicle” and “We attended at” a precise address. For my part, it has never bothered me as testifying is a difficult task and focusing attention on the manner of testimony and not on the value of the words spoken seems counter productive.
In addition, Mr. Deverell points out at page 254 that certain police officers become so confident after testifying over a few years that they appear totally at ease in the courtroom. That can backfire and a careful Crown counsel will not allow appearances to play too important a role as they look for support for all important statements of fact.
Pride in your work
Page 26 records that Arthur was “… weary of representing narcotics dealers and shakedown artists - there was no pride in that and little glory.”
Pro bono work
In his early years in practice, Arthur indulged in what “… his firm considered a bad habit: working pro bono for the poor.} Refer to page 14.
Prosecutor’s duty to object
The judge is quoted at page 196 as follows: “Mr. Santorini, may I remind you the Crown has an obligation to object when defence counsel abuses his right to cross-examine.”
Prosecutor’s mantra
Mr. Beauchamp remarked at page 147 that a very senior counsel told him: “Always stand your ground if your cause is just, and never suck up [to the judge].” On the one hand, this advice applies to both counsel, of course, and I never failed to see the advantage of putting the judge on my side by flattery, on the other.
Publicity grabbing blowhards
Defence counsel and, to a lesser extent, prosecutors must ensure that they are not “headline grabbing blowhards” who fail to put their obligation to their client and to the administration of justice ahead of publicity. See page 29.
Rapport with judge, counsel’s
“A thin-skinned judge may forgive your insults but never your lectures”. See page 176.
Regional “factual realities” that Crowns must be mindful of
Mr. Deverell informs us of this situation at page 63 when he quoted local police about gun safety being lax in the North in 1966: “They considered that not unusual; gun safety protocols were often breached in the north.”
Rehearsed testimony
Both Crown and defence counsel must be wary of rehearsed testimony. As we read at page 101: “That speech sounded hollow, rehearsed. I wondered if the vendors, the sisters, had coached him …”
Reputation evidence - sometimes well deserved
Page 25 references a senior partner known as “Mister Hands” because he continuously seeking to brush up against the buttocks and breasts of the female staff. The author then references information at page 53 that the deceased “… Had a history of abusive behavior when in his cups…”
Rhetorical question out by defence
This is seen at page 132, and the Court took it upon itself to intervene and remonstrate with defence counsel. If the Court is going to be aggressive with your colleague in ensuring that limits are respected, you may wish to play a more detached role in front of the jury.
Retraction of a statement or giving the impression that it is true
Arthur's wife Margaret states to him, “If you don't demand a retraction, I'm going to believe it's true.” See page 18. Counsel must be wary when ross-examining defendants who did not protest against suggestions by the police as the common law right to silence is always engaged.
Reviewing your past actions and seeking to improve
Consider what we read at page 64 of Arthur’s attempt to review his work in this case in which his client, charged with murdering her rapist, was quite young and vulnerable to suggestion:” I blush in shame over [my] social awkwardness, [my] pushy interview techniques. I was practically cross-examining my client, and offering not a thimble of empathy.”
Further, as we read at page 66, defence counsel opined: “I realize much later that my good intentions in shielding her from anguish were misplaced. My mistake was to defer a key agenda item - probing for a detailed recounting of the deceased acts of abuse and rape and her reactions to them. I didn't have the heart, or the courage, or the skill and maturity, to properly frame intimate questions about acts of violence to her body.” Mr. Beauchamp added: “Bluntly, I was too inhibited, too awkward, to enslaved by the Victorian politesse drilled into me by my uptight parents.”
Rotary Club and other service groups
Mr. Deverell often refers to lawyers and other persons as being civic minded Rotarians, etc., as we note at page 87 of The Long-Shot Trial.
Sly lawyer
Page 29 points out that some defendants wish to retain a “… sly lawyer as opposed to an honest one maybe someone who wouldn't be bothered by the bribing of jurors.” Such stereotypes may be entertaining in novels such as these, but no serious Crown will repeat such slanders without quite firm proof. Also, this comment found that page 34: “Our shrink-for-hire was in buying that [Autonomous behaviour]. He'd be a bad witness, he's too honest.”
Trial preparation the same for jury trials for both complainant and defendant
In the case of both Crown and defence counsel, trial preparation is described at page 65 for the proposed witnesses including the defendant: “… carefully explaining… how our Criminal Court system works, how a jury is selected, the roles of judge and opposing counsel, entering a plea, taking an oath, testifying, the presumption of innocence, the onus of proof, reasonable doubt.” The author goes on to point out that the defendant was an intelligent woman and if she didn't grasp all these concepts immediately, she did so after further clarification.
Page 66 reports that the young Arthur spent a couple of hours preparing his client through the witness stand, giving her list of questions she might be asked, preparing her for the ordeal of cross examination. That said, counsel was wary of having her testify as she was “too guileless, too sincere.” Later, at page 222, Arthur stated: “During previous visits, I had avoided over-rehearsing Angelina [the defendant] for the witness stand – too much, and her testimony might seem scripted …” Indeed, at page 223, his tone has shifted: “I was blatantly coaching her, pushing her to create false memories. That is not what a principled barrister does…”
Truth
The author states: “… be not afraid of the truth…” at page 18.
Youthful errors due to immaturity
I doubt that anyone would disagree with what Mr. Deverell wrote at page 97 about a young man: “… a bit of a rebel, a militant, but it's part of being young.”
[1] ECW Press, Toronto, 2024. I have written an earlier book review in respect to the title, Sing a Worried Song, by Mr. Deverell, posted in Mack’s Criminal Law blog – May 27, 2015 ( http://dallas-mack-4x7v.squarespace.com/law-blog/2015/5/27/book-review-sing-a-worried-song) More recently, readers of Mr. Mack’s Criminal Blog may read “Police Investigations 101 Lessons for Prosecutors from William Deverell’s Kill All the Lawyers”, February 28, 2026.
[2] I would love if Mr. Deverell wrote a further “historical novel” and described the Attorney-General of Canada ordering a new trial for that defendant, allowing Arthur to write that first great wrong in his career.
[3] Demeanour Evidence on Trial: A Legal and Literary Criticism, Gilles Renaud, Sandstone Academic Press, Melbourne, Australia, 2008, and certain of my articles: “Evidence of Demeanour: Some Instruction Found in the Early Works of Georges Simenon”, (Winter 1998), 21(4) Prov. Judges J. 5-23. [http://www.trussel.com/maig/demeanour.htm]; “Demeanour Evidence: Guidance from the Tax Court of Canada”, Alan D. Gold Collection of Criminal Law Articles, ADGN/RP-294, May 4, 2020; “Demeanour Evidence and ‘Eyelid Turns’: Guidance from the Manitoba Court of Appeal and Anthony Trollope”, Alan D. Gold Collection of Criminal Law Articles, ADGN/RP-293, April 27, 2020.