Prolonged Sexual Abuse of Children: The R. v. D. (D.) Sentencing Range
In its 2002 decision, the Court of Appeal for Ontario substantially raised the sentences imposed on adults who sexually assault children on multiple occasions. In R. v. D. (D.), 2002 CanLII 44915 (ONCA), the Court of Appeal for Ontario held that adult offenders in a position of trust who sexually abuse children on a regular and persistent basis over substantial periods of time can expect to receive mid to upper single digit penitentiary terms. In that case, the offender had been convicted of eleven sexual offences involving four boys as a result of conduct spanning seven years. The appeal court upheld the nine-year sentence imposed by the trial judge, noting that this sentence fell at the lower end of the appropriate range. Since that time, R. v. D. (D.) (sometimes referred to by lawyers as “Double D”) has become a jurisprudential touchstone for Ontario courts sentencing adults who have repeatedly sexually abused children. Some points to kee...