R. v. Schmidt

canada, canadian, case law, court opinion, canlii, ykca, 2025ykca13, 2025 ykca 13 (canlii), 2025, ykca, 13, (canlii), 24-yu919, 2025, criminal procedure, appointment of counsel, financial means test, appellant applied for counsel under s. 684 of the criminal code to assist in an appeal, whether appellant demonstrated insufficient financial means to retain counsel, appellant failed to provide adequate financial information, including disposable income and efforts to save for legal costs, application dismissed for failure to meet the financial means test, criminal code, r.s.c. 1985, c. c, 46, s. 684, rights and freedoms, right to legal assistance, financial ineligibility for legal aid, appellant denied legal aid due to financial ineligibility, whether appellant’s financial circumstances justified state, funded counsel under s. 684 of the criminal code, appellant’s income, expenses, and debts analyzed, insufficient evidence to establish lack of financial means, canadian charter of rights and freedoms, s. 10(b), evidence, interests of justice, merits of appeal, appellant argued errors in the summary conviction appeal judge’s findings, including improper substitution of facts and misapplication of the reasonable suspicion test, crown conceded merits threshold met but opposed appointment of counsel, factors considered included complexity of the case, appellant’s competency, and lack of risk of imprisonment, application dismissed as financial means test not satisfied, criminal code, r.s.c. 1985, c. c, 46, s. 684