R v Rumbles

Decided: 2026-10-16. Docket: CA50526. Citation: 2026 BCCA 410 (CanLII). Criminal and statutory offences — Dangerous operation causing death — Criminal Code, s. 320.13(3) — Whether trial judge erred in actus reus analysis by failing to address manner of driving — Concession that actus reus made out as of erratic driving — Curative proviso, Criminal Code, s. 686(1)(b)(iii) applied despite legal error — Appeal dismissed | Procedure — Appeal — Standard of review — Credibility and reliability — Whether trial judge reversed the burden of proof or relied on speculation — Palpable and overriding error threshold, R v Kruk and R v G.F. — Functional and contextual reading of reasons — No error of law or palpable and overriding error — Appeal dismissed | Evidence — Expert opinion — Weight — Endocrinol