Michael A. Johnston's article "The Ghost in the Machine: Alcohol, a Car, a Risk, and R. v. Boudreault" has been published in the Criminal Law Quarterly (at 60 Crim LQ 414 (2013-2014)):
"The Supreme Court's recent decision in R. v. Boudreault afforded the Court an opportunity to clarify the area of care and control, as set out in s. 253(1)(a) and (b) of the Criminal Code ("Code"). While the Court confirmed that a risk of danger is an essential element of de facto care and control, it failed to address more foundational problems; this essay addresses those issues."
