R. v Rowsell

canada, canadian, case law, court opinion, canlii, nlca, 2026nlca32, 2026 nlca 32 (canlii), 2026, nlca, 32, (canlii), 202501h0055, 2026, procedure, court, appointed counsel, criminal code, s. 684, rule 45, court of appeal criminal rules, 2025, discretionary assignment of counsel payable by attorney general, interests of justice framework and overlap with jurisprudence, relevance of applicant’s means, legal aid, seriousness, and ability to present, application dismissed, procedure, court, appointed counsel, financial means, criminal code, s. 684(1) “sufficient means”, whether applicant provided necessary information to ascertain ability to retain a lawyer, assertion of inability to pay and prior legal aid representation considered, court not satisfied but declines to decide solely on means, application dismissed, procedure, leave to appeal sentence, merits screening, whether there are serious issues to be tried on demonstrably unfit sentence or error in principle, no automatic right to appeal sentence, leave required, deference to sentencing judge absent error in principle or demonstrably unfit sentence, serious issues not ruled out at early stage, application dismissed, procedure, self, represented appeals, procedural complexity, whether applicant can adequately present case and court decide without counsel, added steps for leave to appeal and ineffective assistance ground identified, case management and court of appeal legal assistance clinic noted, applicant found able to communicate views and proceed with court assistance, application dismissed, professional responsibility, ineffective assistance of counsel, appellate procedure, whether ineffective assistance could justify appellate intervention if incompetence and miscarriage of justice with prejudice established, need for notice to counsel and opportunity to respond, possible requirement to assess additional evidence identified, grounds treated as raising serious issues, application dismissed