Manslaughter with a firearm, Possession of a loaded prohibited or restricted firearm

R. v. Steenbergen

  • On release at the time

Sentence and the Crown's position

Crown asked4 years in custody1
Judge imposed4 years for manslaughter with a firearm (mandatory minimum), with 9 months and 6 months concurrent on two firearm possession counts1

What the law allows

MaximumLife imprisonment
Crown asked4 years in custody
Judge imposed4 years in custody
Defence asked4 years in custody
Minimum4 years
For manslaughter with a firearm (CC 236(a)), the Criminal Code currently allows up to life imprisonment, with a mandatory minimum of 4 years. Life is drawn at 25 years for scale. Read the section.

Adam Steenbergen pleaded guilty to manslaughter with a firearm and two counts of possessing a restricted or prohibited firearm without authorization, after fatally shooting a friend who was wearing a bulletproof vest while the two were intoxicated. Crown and defence jointly sought the mandatory minimum of four years. Justice Duncan accepted the joint submission and imposed four years, with concurrent terms of 9 months and 6 months on the firearm counts, finding his moral blameworthiness low but the death the product of breathtaking recklessness.

In the judge's words

The circumstances before me are not precisely analogous to either of these authorities, but they illustrate how ordinary people can become enmeshed in horrifying, life-ending situations that fall far short of intentional homicide but must still be met with society's condemnation.

1

The record

Prior convictions
0 prior convictions1
At the time of the offence
On bail1
Defence asked for
4 years in custody1
Mandatory minimum
Applied1
Appeal
Not yet checked
Counsel
Crown: J. Gillings, G. Liu
Defence: N. Brooks

Sources

  1. R. v. Steenbergen, 2026 BCSC 876 Court decision, CanLII, May 8, 2026[4] Manslaughter with a firearm carries a mandatory minimum sentence of four years imprisonment. Crown and defence jointly submit that I impose the mandatory minimum sentence, along with concurrent sentences for the two firearms possession offences.[4] Manslaughter with a firearm carries a mandatory minimum sentence of four years imprisonment. Crown and defence jointly submit that I impose the mandatory minimum sentence, along with concurrent sentences for the two firearms possession offences.[46] For the offence on Count 1 of the indictment, manslaughter, I sentence you to the mandatory minimum sentence of four years.[29] Adam Steenbergen was 33 years of age when he committed the offences before the court.[43] The aggravating circumstances are the use of a firearm; the fact that Mr. Steenbergen was not authorized or licenced to be in possession of any type of firearm and was subject to an undertaking dated September 25, 2022 prohibiting him from possession of weapons as defined in the Code, including firearms[42] The mitigating circumstances in Mr. Steenbergen's case are his guilty plea, the lack of a criminal record, and his genuine and heartfelt expressions of remorse.[41] The circumstances before me are not precisely analogous to either of these authorities, but they illustrate how ordinary people can become enmeshed in horrifying, life-ending situations that fall far short of intentional homicide but must still be met with society's condemnation.[46] For the offence on Count 1 of the indictment, manslaughter, I sentence you to the mandatory minimum sentence of four years. … [47] For the offence on Count 3, I sentence you to 9 months imprisonment, concurrent with Count 1. … [48] For the offence on Count 4, I sentence you to 6 months imprisonment, concurrent with all other counts.
  2. R. v. Steenbergen, 2026 BCSC 876 Court decision, Courts of British Columbia

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