Edmonton (Police Service) v. McKee

canada, canadian, case law, court opinion, canlii, csc-scc, 2026scc24, 2026 scc 24 (canlii), 2026, scc, 24, (canlii), 41110, 2026, evidence, disclosure, police misconduct information, administratively expunged disciplinary finding, whether expunged misconduct records remain first party disclosure, r. v. stinchcombe, r. v. mcneil, r. v. o’connor framework selection, expungement cannot convert first party disclosure into third party production, appeal dismissed, evidence, relevance, serious misconduct, ferguson five, what qualifies as relevant information of police misconduct, relevance is a low, utility, based threshold, not “obvious relevance”, “serious misconduct” defined by relationship to relevance, “ferguson five” reformulated, non, exhaustive, disclosure guidance confirmed, statutory interpretation, regulation, police service regulation, alta. reg. 356/1990, s. 22, meaning of “destroyed”, whether s. 22 governs criminal disclosure obligations, provision limited to disciplinary, related proceedings respecting police officers, “destroyed” not permanent erasure for all purposes, interpretation rejecting bar on criminal disclosure upheld, procedure, criminal disclosure process, police and crown roles, duty to inquire, whether police may be the final arbiter of relevance, police role limited to triage, transmission, and notice of withheld material, crown determines relevance and operationalizes privacy safeguards, crown duty to make reasonable inquiries once on notice confirmed, appeal dismissed with costs payable by appellant on a solicitor, client basis