The early release program for federal prisoners known as mandatory supervision has come under heavy fire as the public has learned of sex offenders and violent criminals repeating their crimes after conditional release. While the number of such offences is only a very small proportion of the total committed. it is not in significant. In response to the strong criticisms directed at the National Parole Board for releasing eventual recidivists, the Board, in September 1982, began to issue suspension warrants to block the release on mandatory supervision of potential dangerous offenders. Invoking Section 10(1)(e) of the Parole Act, the Board has “gated” (i.e. revoked release under MS at the penitentiary gate) prisoners who are suspected of being unable to settle back into society.
[The term “gating” was coined by William Outerbridge, Chair of the National Parole Board. It refers to the immediate revocation of release directly after the inmate formally embarks on mandatory supervision.]
About ten of 1,000 inmates released on MS have already been “gated” in the past six months (Vancouver Province, Feb.23, 1983) although the policy is now being challenged by some prisoners on the grounds that it is an unreasonable reading of those sections of the Parole Act said to justify it, and that it violates s.9 of the Charter of Rights which prohibits arbitrary detention or imprisonment. In recent weeks, the Ontario Court of Appeal has held that there is no lawful authority for gating. The Federal Court of Canada has ruled to the contrary, upholding the practice. The Federal Government has now referred the issue to the Supreme Court of Canada for a determinative ruling. In the interim, the National Parole Board has announced that, except in Ontario, it intends to continue to re-jail dangerous offenders until the legality of the controversial procedure is determined by the high court. The Solicitor General has indicated that if the Supreme Court of Canada rules against the re-arrest policy, he will seek an amendment to the Parole Act legislation which establishes the legality of gating.
The problems are complicated and troublesome. The Solicitor General has already prepared changes to the mandatory supervision program which are now being considered by the Standing Senate Committee on Legal and Constitutional Affairs (Bill S-32, to amend the Penitentiary Act and the Parole Act).
Since many of the matters arising in this controversy pertain to civil rights issues, any legislative changes that may come about are of concern to the BCCLA. The following is a brief discussion of the history of MS legislation, the main issues in contention, and the BCCLA recommendations for changes in the administration of the program.
In 1953, the Fateux Report (Committee of Inquiry into the Remission Service) recommended the enactment of legislation to create a National Parole Board. On February 15, 1959, the Parole Act was proclaimed, transferring the authority to grant conditional release to an independent Board with members appointed by the Governor-in-Council. To prepare cases for Board consideration and supervise parolees in the community, a National Parole Service was established, responsible to the Chairman of the Parole Board until 1973. The Parole Service became the responsibility of the Commissioner of Corrections in 1977. This marked the legal integration of the formerly separate Parole and Penitentiary Services under the auspices of the Correctional Service of Canada (CSC). The Parole Board is now an agency within the Department of the Solicitor General, which also includes Correctional Services Canada and the RCMP.
The Parole Service has grown markedly since 1959 when it began with 45 employees on the Board plus 44 in the Parole Service. In 1970 it expanded to 386 employees, a five million dollar budget, and paroled 2,785 federal prisoners. In 1979, it grew to 223 employees on the Board, plus 800 in the Parole Service; its budget was 33 million, yet it paroled fewer federal prisoners in that year than in 1970 (1,616).
The prime objective of parole is to enable the inmate to undergo a gradual release program with supervision in the community. (An unstated residual objective has been to reduce and even out disparities in sentencing.) The ideal sequence of discharge into the community is one that takes the inmate through temporary absences, day parole and then to full parole. The latter may be attained when the inmate has served at least one-third of his detention warrant.
The cost of supervising a prisoner on parole in 1980 was estimated to be approximately $2,000, compared to roughly $40,000 for a prisoner in maximum security, $22,669 for medium security, and $18,421 in minimum security; therefore, without taking ancillary costs into account, every prisoner released on parole saves the taxpayer up to $33,823 yearly. For the period 1974-79, a full 75% of nearly 9,000 parolees completed or are in the process of completing their parole time without incident. Of those sent back to jail, about half were guilty only of violating the technical terms of their parole (i.e., they committed no new statutory crime).
In view of these figures, defenders of parole argue that the great majority of those released early from prison adapt successfully to society, and that early release saves Canadian taxpayers millions of dollars in prison expenditures. Under existing laws, prisoners who do not qualify for parole must be released on mandatory supervision after serving two-thirds of their sentence, provided that the remission credits that they earn in prison (15 days “good time” for every month served) are not lost through serious misconduct or failure to work.
Prior to 1970, before MS was introduced, prisoners who earned remission (S-24 of the Penitentiary Act) were simply discharged at the point at which they had served two-thirds of their sentence. There were no stipulations that they report to a parole officer and no conditions that they were lawfully required to observe. Release was absolute, not conditional. The rationale for earned remission was that it was necessary to enforce work discipline (given the poor pay incentives). and to assure general order in the institution (since misconduct would result in a loss of remission credits).
In 1970, section 15 of the Parole Act was enacted which requires that inmates be supervised during the remaining one-third of their sentence outside the penitentiary. The inmate was now deemed to be completing his sentence outside prison under observation, and penitentiary inmates who were not released on parole were now required, by law, to serve in the community, under supervision, the time accumulated by statutory or earned remission.
In 1977, statutory remission, the automatic granting to an inmate of one-quarter of his sentence off, subject to divestiture for various types of misbehaviour, was abolished (S.C. 1976-’77 c.53 s.40). At the same time, the amount of remission an inmate could earn was increased from 15 to 30 days for every month served. Since 1970, then, prisoners have been entitled to be released but were then subject to the supervision and control of the Parole Board and could be returned to prison if they violated the conditions imposed by the Board. The justification for the change in the law leading to the establishment of mandatory supervision in 1970 was stated to be the protection of the public. The change was designed to ensure that, at least during the last third of their sentence, prisoners who had been denied a regular parole and who were therefore deemed to be the worst risks for reoffending, would be subject to parole supervision in the community. Restrictions imposed by the Board would presumably help to protect the public from a possible return to crime by the releasee; moreover, it was believed that the released individual could benefit from supervision until the date of warrant expiry:
… if a person selected for parole requires counselling and supervision, those persons who are not so selected need such counselling and supervision even more. (Report, 1974:26)
With respect to these two objectives, however, the rationale for mandatory supervision embodies a patent contradiction: that as an extension of the concept of parole, the releasee is entitled to humane assistance in order to force or facilitate his social integration; and that correctional authorities are entitled to keep watch over individuals in order to inform the police and prevent crimes. Minimizing this inconsistency, parole officers argue that mandatory supervision is less oppressive and less costly than prison, and that about 40% of those released on mandatory supervision get through it without returning to prison. Both support and control, therefore, are provided after release. Thus, it is argued that mandatory supervision functions as both a safety valve in instances where early parole has been denied to individuals, and as a reassurance to the public that those offenders not considered suitable for parole will be watched.
In the first 10 years of operation of the program, from 1970 to the end of 1979, a total of 18,410 inmates were released on MS, for an average of approximately 2,500 per year. Over that period, the administration of the program has given rise to two major interrelated problems: what has become known as the “revolving door” syndrome; and the problem of release of dangerous offenders.
The former problem refers to the phenomenon of rapid, and sometimes, successive re-release of inmates whose mandatory supervision has been revoked or interrupted. Prisoners may be released on mandatory supervision two or three times within the period of a given sentence, even when release conditions have been violated or new offences committed. This is particularly exasperating to law enforcement personnel.
The second problem stemming from the legal requirement to release offenders at the two-thirds point of their sentence (provided that they have not previously been labelled dangerous offenders by the courts) blocks consideration of the threat to public safety posed by the release.
In fact, there is no unambiguous legal authority to hold a prisoner (without his consent) who has entered his remission period, and there is no discretion to be exercised over his release by the National Parole Board, save to the extent that terms and conditions may be attached to his period of supervision. Mechanisms for controlling the violent or dangerous offender (such as the indeterminate “dangerous offender” court sentence pursuant to s.688 of the Criminal Code, or provincial mental health statutes authorizing commitment) are not available to parole authorities when an inmate is released on mandatory supervision.
Recent actions taken by the Solicitor-General and the National Parole Board authorities constitute attempts to resolve these difficulties. Bill S-32 currently under consideration by the Standing Senate Committee amends s.21 of the Parole Act to forbid release on MS after one revocation. The inmate is required to return to his original place of confinement and serve the remainder of his sentence (less time already spent on MS) before he is entitled to be released again. Any further possibility of release during the period of sentence would be through the mechanism of ordinary parole. Thus, the inmate is not permitted to earn any more remission until the original sentence for which he was first incarcerated has expired, and he forfeits any remission standing to his credit at the point of revocation. The intent of the Bill, then, is to tighten up MS by locking the revolving door shut and forcing the inmate to serve the balance of his sentence subject to the discretionary criteria employed by the National Parole Board in assessing grounds for conditional discharge. In sum, inmates who previously were much less under the jurisdiction of the Board because of the “automatic” nature of release, would now be directly under the Board’s discretionary control. MS releasees who are returned to prison for committing another offence or violating conditions of release would have to convince the Parole Board to release them a second time.
With respect to the detaining of prisoners statutorily due for release under MS but who are presumed to be dangerous and likely to commit subsequent offences of a violent nature, the parole authorities have seen fit to re-interpret Section 10(1)(e) of the Parole Act in order to justify a policy of “gating”. If the Federal Courts do not support this reading, the Solicitor-General has vowed to introduce further amendments to the Act that would make this policy law.
The criticisms of mandatory supervision come from many quarters. (Information regarding mandatory supervision is based on a review of 60 letters from prisoners at federal prisons across Canada, on official government documents, and on interviews with prison activists, lawyers, correctional administrators and Parole Board and Parole Service officials.) From the inmates’ point of view, it is clear that releasees on mandatory supervision are “non-voluntary” clients, and that they are unfairly subject to supervision on the remission time that was lawfully earned. Furthermore, the procedure places enormous discretionary powers in the hands of the parole officers who recommend special restrictions to the Board and who may suspend release and recommend revocation of mandatory supervision to the Board. A suspension is usually, though not always, recommended when a release condition is violated, when there are reasonable grounds to believe that a continuation of the release will entail a risk to the public, or when there are reasonable grounds to believe that an offence is likely to be committed. Application of any of these criteria involve considerable interpretation and judgement. Should the parole officer decide to suspend mandatory supervision, the individual is returned to custody. The parole officer then decides whether to cancel the suspension or recommend revocation to the Parole Board. If he does the latter, a post-suspension hearing takes place to review the suspension. The decision of the Parole Board is final and non-accountable to the courts. The inmate and any “assistant” he chooses may attend the hearings and make a presentation, but only following initial presentations of staff of Correctional Service of Canada at which the inmate and his assistant cannot be present.
In objecting to this entire scenario, inmates strongly resent the “double jeopardy” aspect of supervision where they are forced to observe burdensome technical restrictions which, in many instances, they unavoidably violate in pursuit of what they take to be their own better interests (e.g., getting married, buying a car, taking out credit, or visiting a friend). Thus, it appears to many inmates that mandatory supervision is designed in order to ensure the individual’s return to prison, and that mandatory supervision releasees are treated more harshly than parolees—an impression powerfully reinforced by the practice of gating:
Since the parole board started attempting to gate prisoners, inmates approaching the date of MS have grown wary, concerned that they might be next on the board’s hit list. Where was the incentive for good conduct during a period of imprisonment? Should such feelings prevail (after all, if the parole board tried gating, what next?), and become wide spread among federal prison populations, our penitentiaries will undoubtedly be in for some serious upheavals in the coming months. (Forum, The Whig-Standard, Kingston, Ontario, January 31, 1983)
The police take a jaundiced view of mandatory supervision, since they are usually the ones left to deal with whatever new violations are committed The Canadian Association of Chiefs of Police, for example, has proposed that earned remission (and thus mandatory supervision) be abolished entirely, and that inmates should serve the whole of their sentence, subject only to the possibility of parole (Canadian Association of Chiefs of Police, 1977).
Parole officers, while generally supportive of the extension of services to MS releasees, find supervision difficult and unpleasant because of the hostility and resentment of MS releasees. Penitentiary authorities dislike the program since they must live with the returns—the revoked offenders who are further embittered re-incarceration (although the “earned remission” concept is much less problematic since, detached from MS, it provides a clear incentive for inmates to avoid trouble in prison and thereby contributes to the protection of prison staff). Prison auditors are sceptical since they perceive mandatory supervision as adding to the costs of both imprisonment (500 per year returned to prison) and to support staff (parole). Indeed, between 1970-80 over 250 million dollars has been spent bringing mandatory supervision releasees back to prison for mere technical violations.
In general, the Parole Board is seen by those outside the correctional system as an unauthorized agent of punishment, exercising tyrannical extra-judicial authority, and this perception has been reinforced by its revoking powers with respect to mandatory supervision. Advocates of parole also criticize mandatory supervision on the grounds that the availability of mandatory supervision reduces opportunities for genuine parole and accounts for the declining number of parolees in recent years.
Civil libertarians complain of the arbitrary nature of many of the revocations from MS, the oppressive nature of the supervision, the undermining of the benefits that accrue from earned remission, and more recently, the explicit violations of the Charter of Rights and Freedomscontained in MS regulations. On the issue of earned remission McCabe comments:
In the pre-mandatory supervision era, if parole was not granted, remission both reduced the time served. in prison and the time that the offender was accountable to the court’s sentence. With the introduction of mandatory supervision, remission lost that utility and merely established the precise date on which surveillance and control was shifted from the prison setting to the community… on balance, the losses outweighed the gains. (McCabe: 1981).
The Solicitor-General has responded to this assessment:
Inmates especially feel that MS is fundamentally unfair in forcing them to serve, under supervision in the community and subject to revocation, those remission credits which they have earned for acceptable behaviour in the penitentiary. But earned remission is not a form of “amnesty” which is unconditionally awarded. The conditions are well-known to all concerned. (Kaplan: 1981)
In spite of the controversial nature of the program, and the rather wide array of detractors, mandatory supervision has remained more or less intact (with some amendments in 1977). McCabe notes the following essential facts:
…since the introduction of MS, both the number and the proportion of releases from penitentiary by parole has declined, while both the numbers and proportions of MS releases has risen… since 1974, releases by MS have comprised over 50% of each year’s releases… With respect to penitentiary admissions, in recent years MS violators, have comprised about 20% of the admissions while parole violators have comprised about 7%. In hard terms of parole, during the seven fiscal years 1974-80, 5,712 inmates, or an average of 816 per year have been re-admitted as MS violators. (1981: 9)
Out of the myriad pros and cons regarding mandatory supervision, some deeper contradictions emerge. The public sees mandatory supervision as parole, rather than as earned remission; consequently, they judge release criteria erroneously. A program supposedly designed to support and aid released prisoner has been turned into a police surveillance mechanism. The counselling assistance rendered is usually to no avail, since the main requirements of releases are jobs and homes, neither of which is obtainable in most instances. The “failures” are widely bruited, but the positive cases are rarely advertised since the “successes” prefer not to be observed. The difficulty for the parole officer in generating enthusiasm for a release plan is compounded by the fact that the MS “parolee” has no choice about accepting the conditions that are imposed (except to waive MS and stay in prison until warrant expiry). The same correctional system which denied the inmate a parole, is now supervising the MS period of release and is therefore inclined to find cause to have the inmate returned to jail; and since the MS release had been previously rejected for parole, his mood is often uncooperative, which increases the probability of violations and revocation.
While many recommendations have been proposed, ranging from abolishment of mandatory supervision to the scrapping of earned remission, no proposal has been satisfactory to all parties. Reporting on this confusion, the Solicitor-General’s joint committee arrived at no solution to the Mandatory Supervision problem:
The available options for Mandatory Supervision would appear to be either ineffective or at odds with each other in responding to all concerns: or would entail unreasonably high costs (in various areas including financial) in comparison with the expected benefit; or would simply be organizationally or politically impossible. Moreover, some of the concerns are literally insoluble, a by-product of criminal justice. (Solicitor General: 1981)
The most paradoxical feature of the MS controversy is that the imposition of conduct restraints through mandatory supervision, along with the lack of supportive services in the community to facilitate rehabilitation, ensures that many of the releasees will return to prison, which then justified continued institutional control. While struggling to avoid a return to prison, the releasee faces conditions which violate due process and fundamental justice, but which he must nevertheless endure, given the non-judicial status of the Parole Board. He may utilize the benefits of his “earned remission” only through accepting participation in a non-voluntary program of release. He is forced to agree to conditions which, if violated, would lead to suspension and possible revocation of mandatory supervison. He has little or no say regarding the specification of these conditions. Unspecified evaluative procedures are used by the parole officer for determining whether violations of the stipulated conditions have occurred. (The potential for blackmailing individuals in order to wrest information from them in this situation is obvious.) And the nature of the revocation hearing poses limits to informed participation and provides no mechanism of appeal. In all of this there is a degree of carceral power (now exercised beyond the prison institution) that is arbitrary and oppressive, but presently within the bounds of administrative discretion.
The threat to civil liberties poses by the current policy and practices under mandatory supervision arises in all four major areas of concern to those interested in safe-guarding the delicate balance between valid community claims and the enjoyment of maximally tolerable personal liberty: basic moral rights and freedoms; freedom from discrimination; due process of law; and freedom from infringements of rights by administrative decision-making.
a) basic moral rights and freedoms
The fundamental freedom of association, the democratic rights which ensure personal mobility, and the legal rights which further ensure free movement, as well as the right not to be arbitrarily detained or imprisoned, are all constitutionally guaranteed under provisions of the Canadian Charter of Rights and Freedoms. All of these are violated by the imposition of geographic restrictions on releasees and by the current practice of gating. While it is true that the rights guaranteed by the Charter are subject to whatever limits are justifiably demonstrable in a free and democratic society, prison authorities presently only have to show fair procedure and do not demonstrably justify their rules and regulations vis-a-vis rights and freedoms.
b) freedom from discrimination
The technical conditions which may be imposed on the freedom of the releasee by the Board are inherently discriminatory since two people can be returned to prison for vastly different lengths of time for a violation of the same condition. Moreover, since the releasee can be returned to prison without having committed a criminal offence, technical violations serve as grounds for recommittal that would not be applicable against the ordinary citizen.
c) due process of law
Under MS, remission can be revoked on grounds of suspicion that the releasee may commit a crime. The charges are seldom precise, the accused rarely knows what the charges are, the evidence is often confidential with no opportunity for the accused to question it, and there is no right of appeal to another body. This is frequently tantamount to allowing a parole officer to enforce his idea of social integration on a person who is not committing a crime.
The arbitrary denial of earned remission by a Board not bound, as are the courts, to fundamental democratic principles as the right to cross-examination and the right to legal counsel, is conspicuous in the instances of gating, which threaten to become more numerous. Gating is inconsistent with the procedures established in the Criminal Code for identifying and sentencing dangerous offenders. These procedures require a judicial hearing at which the accused is entitled to legal representation. The determination of dangerousnessismeasured against specific legislative criteria supported by evidence which is subject to cross-examination. The Parole Board, on the other hand, makes its determination behind closed doors with no hearing, measured against no criteria except its own conception of danger, supported by any evidence it deems acceptable.
d) administrative decision-making
Revoking MS on grounds of technical violations, as well as refusing automatic discharge on grounds of “dangerousness”, both represent unreasonable uses of power and illustrate the actions of a government agency trying to curtail the basic right to not be arbitrarily detained.
Possible moves toward rectifying some of the above violations and/or reducing dissonance in the criminal justice system have included the following:
l. Abolish earned remission
Remission of sentence has, to a greater or lesser degree, been a feature of Canadian prison law since 1868. It was originally viewed as a method of rewarding an inmate’s good conduct and attitude with a specific number of days off sentence. Since then, its nature has changed somewhat from being a system of incentive and reward, to being a method of maintaining order and control in prisons and of controlling the size of prison populations. It now functions primarily as an incentive for prisoners to contribute to the orderly operation of the prison. As such it contributes to the protection of prison staff. Although abolishing earned remission would remove all of the problems associated with mandatory supervision, it would also intensify problems within prison institutions and exacerbate problems in the manageability of prison populations. The incentive of earned remission is probably the major social control device (short of outright coercion) available to prison administrators. It is not surprising, therefore, that prison guards generally express disfavour toward schemes which would curtail or abolish parole, mandatory supervision, and earned remission. The impact of such proposals would be most severe on long-term offenders who predominate in medium and maximum security penitentiaries.
2. Abolish mandatory supervision
Again, the administrative problems associated with mandatory supervision would disappear if this proposal were adopted, as prisoners released into the community at the statutory period of earned remission would be returned to custody only in the event of a new criminal offence. The chief disadvantage is that the releasee would not be required to obtain counselling assistance at least through the period that would carry him to warrant expiry. It is widely believed, however, that supervision has very little effect on recidivism (i.e., it does not significantly deter released inmates from engaging in criminal activity); therefore, it is argued that the millions of dollars presently spent on the ineffectual supervision of all conditionally released prisoners would be better spent on efforts which attempt to identify prisoners who are “dangerous” and who require extended incarceration. Again, the main snag in this proposal is that in cutting out supervision, the interest of the community in seeing that such supervision is offered and received goes neglected.
3. Modify mandatory supervision
The Solicitor General has proposed amendments to the present legislation affecting mandatory supervision policy (Bill S-32) which are now under Senate consideration. The gist of the proposed changes is that they forbid further releases on MS after one revocation. Earned remission credits are forfeited and cannot be recouped during the time served for a given offence. Prisoners who recidivate while on MS would have to convince the Parole Board to release them second time. The argument against such modifications is that they represent little more than attempts to suit the administrative convenience of civil servants (i.e., end the revolving-door syndrome) and to improve the image of the Parole Board (seen as protecting the public), yet offer nothing substantive that would address the rehabilitation of inmates or materially affect public welfare. Granting parole authorities further discriminatory powers over early release on MS does not allow them to prevent the eventual release of violence-prone inmates whose inclination to commit crimes may be fuelled by the heavy-handed tactics of Parole Boards so empowered. Appearing before the Senate Legal Affairs Committee deliberating over Bill S-32, the Criminal Lawyers Association has argued against piecemeal modifications of the sort proposed by the Solicitor-General. Tinkering with only one element of the integrated prison and parole systems they note, creates tensions and problems elsewhere that may outweigh the ostensible advantages of such moves as tightening the rules of mandatory supervision (Vancouver Sun, March 4, 1983).
It is the position of this Association that none of the above alternatives are satisfactory in that they do not adequately address the problem of ensuring public safety through inmate rehabilitation in the community to which he returns; nor, in the case where MS is retained or modifications introduced, are the civil liberties of prisoners and releasees adequately safeguarded. Keeping these criteria in mind, we make the following specific recommendations towards a revamping of the existing program:
1. That the post-release counselling functions of MS be enhanced and rationalized by the following changes:
a) supervision to be performed by voluntary agencies, particularly the John Howard and Elizabeth Fry Societies, with subsidies allocated for the purchase of necessary resources and personnel. Counselling under this aegis would effect a clean separation of the counselling from the surveillance function, providing minimally requisite grounds for trust and possible remediation between the counsellor and the releasee.
b) That no technical restrictions or conditions be imposed other than the requirement that the releasee establish a regular visiting pattern. A return to custody could result only from breaching this requirement or from the commission of a new criminal offence. This change would greatly reduce the possibilities for coercive or discriminatory action on the part of the servicing agency and largely preclude contravention of the releasee’s constitutional rights. Since surveillance is now a dubious area of legality and not even an admitted function of the type of conditional release involved in mandatory supervision, the loss of this capability must be regarded as a necessary and acceptable sacrifice.
c) That inmates who obtain a parole release shift to the “relaxed” strictures obtained under mandatory supervision at the two-thirds point of their sentence so that they are not required to observe constraints greater than those which apply to MS releasees.
d) That the term and name of the program, mandatory supervision, be changed to “re-integration counselling” in order to reflect the more defined objectives and limited authority of the role of the voluntary agencies.
2. That amendments to the dangerous offender legislation (s. 688 of the Criminal Code) be introduced that would facilitate judicial intervention and control at the anterior stage of offender processing (i.e. sentencing), mindful that prediction devices regarding “dangerousness” cannot as yet effectively identify individuals within this population who are likely to commit violent offences (Hackler and Gauld, 1981), and that over-reliance on individualistic conceptions of “dangerousness” masks the collective origins of violence ((Pfohl, 1979). The dangers of abuse implicit in this modification are less repugnant and more remediable than the current retroactive adjustment to the spectre of “dangerousness” explicit in the policy of gating with all its attendant violations of civil liberties.
3. That in view of the above recommended changes, the conditional release status of a releasee convicted of a criminal offence while still within the period of warrant expiry be revoked with forfeiture of remission credits. Releasees returned to custody would be required to apply to the Parole Board for a re-crediting of remission time or for a conditional release under parole.
|Canadian, 1977||Canadian Association of Chiefs of Police, “Resolutions adopted at the 72nd Annual Conference, August 26, 1977,” Canadian Police Chief, vol. 66, no. 4, p. 72.|
|Hackler, 1981||Hackler, Jim and Laurel Gauld, “Parole and the Violent Offender,” Canadian Journal of Criminology, vol. 23, no. 4, pp. 407-13.|
|Kaplan, 1981||Kaplan, Robert, Letter from the Solicitor General, April 16, 1981.|
|McCabe, 1981||McCabe, M.F., “Position Paper: Mandatory Supervision and Parole”, Department of Sociology, Queen’s University (unpublished paper).|
|Pfohl, 1979||Pfohl, Stephen J., “Deciding on Dangerousness: Predictions of Violence as Social Control”, Crime and Social Justice, No. 11, pp. 28-40.|
|Report, 1974||Report of Standing Committee on Legal and Constitutional Affairs, Parole in Canada, Ottawa, Information Canada.|
|Solicitor, 1981||Solicitor General’s Study of Conditional release, Report of the Working Group, Solicitor General, Canada.|