In R. v. Nnane (Ont CA, 2024) the Ontario Court of Appeal dismissed a first degree murder appeal.
Here the court considered the doctrine of functus officio, here in a jury trial context:
[82] The appellant sought a mistrial and, in the alternative, asked the court to conduct a juror inquiry to create a record for consideration on appeal. Relying on R. v. Henderson (2004), 2004 CanLII 33343 (ON CA), 191 O.A.C. 201 (C.A.), the trial judge concluded that she was functus after the jury rendered its verdict and that neither of two narrow exceptions applied: there was no indication that the verdict recorded was not the one reached by the jury, nor did the appellant raise the defence of entrapment. The trial judge determined, further, that it would not be appropriate to conduct an inquiry for the purpose of establishing an appeal record, as nothing in the letter amounted to or suggested exposure to extrinsic information or outside sources.
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