R. v. Smith

Decided: 2026-09-25. Docket: CAC 547332. Citation: 2026 NSCA 68 (CanLII). Procedure — Criminal appeal — Appointment of counsel — Criminal Code, s. 684(1) — Motion for state funded counsel on appeal from convictions — Two-part test applied, sufficient means and interests of justice — Consideration of complexity, self-representation limits, and fairness — Section 684 motion granted | Procedure — Criminal appeal — Financial eligibility — Criminal Code, s. 684(1) — Whether appellant has not sufficient means to obtain private counsel — Affidavit evidence and cross-examination on income, debts, judgments, and access to credit — Effect of Mareva injunction and banking termination on ability to retain counsel — Sufficient means not established by Crown objection — Motion granted | Procedure — Crim