Failure to stop after an accident resulting in bodily harm

R. v. Mannette

Sentence and the Crown's position

Crown asked15 months conditional sentence1
Judge imposed15 months conditional sentence, then 12 months probation; 3-year driving prohibition1

A conditional sentence is served in the community, usually under house arrest. It counts as no custody here.

What the law allows

Maximum14 years
Crown asked15 months conditional sentence
Judge imposed15 months conditional sentence
Defence asked15 months conditional sentence
For failure to stop after an accident resulting in bodily harm (CC 320.16(2)), the Criminal Code currently allows up to 14 years when the Crown proceeds by indictment, with no mandatory minimum. The sentence imposed is 9% of the maximum. Read the section.

John Walter Mannette pleaded guilty to failing to stop after a September 2023 collision on Highway 207 in West Chezzetcook in which he crossed the centre line and struck a motorcycle, seriously injuring both riders; he had consumed alcohol beforehand. The Crown and defence jointly recommended a 15-month conditional sentence followed by 12 months of probation. Justice Bodurtha accepted the joint recommendation, noting that Mr. Mannette returned to the scene and reported himself to police, and also imposed a three-year driving prohibition.

In the judge's words

While Mr. Mannette’s offending conduct is serious and merits strong condemnation, the proposed sentence reflects the gravity of the offence and Mr. Mannette’s degree of responsibility.

1

The record

Prior convictions
3 prior convictions1
At the time of the offence
Not stated1
Defence asked for
15 months conditional sentence1
Appeal
Not yet checked
Counsel
Crown: Madeline Smillie-Sharp
Defence: Steven Degen

Sources

  1. R. v. Mannette, 2025 NSSC 292 Court decision, CanLII, August 18, 2025[2] The Crown and Defence are jointly recommending a sentence of fifteen months’ custody to be served in the community under a Conditional Sentence Order, followed by a period of twelve months probation.[2] The Crown and Defence are jointly recommending a sentence of fifteen months’ custody to be served in the community under a Conditional Sentence Order, followed by a period of twelve months probation.[1] On May 27, 2025, Mr. Mannette pled guilty to a single count of failure to stop after an accident in which bodily harm resulted, contrary to section 320.16(2) of the Criminal Code.[12] Mr. Mannette has a prior criminal record. The record consists of three dated convictions for impaired driving.[34] … While Mr. Mannette’s offending conduct is serious and merits strong condemnation, the proposed sentence reflects the gravity of the offence and Mr. Mannette’s degree of responsibility.[41] Accordingly, I accept the joint recommendation and sentence Mr. Mannette as follows: … fifteen months’ custody to be served in the community under a Conditional Sentence Order; … followed by a period of twelve months’ probation.
  2. R. v. Mannette, 2025 NSSC 292 Court decision, Courts of Nova Scotia

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