The Role of Motive in Sexual Assault Trials

Author:

Benedet Janine1

Affiliation:

1. Allard School of Law at the University of British Columbia

Abstract

In sexual assault cases, the motive of the complainant has traditionally been heavily scrutinized, based on sexist beliefs that women are likely to bring false complaints of rape based on motives of revenge, fantasy, and shame. Recent sexual assault cases have demonstrated the persistence of these beliefs even after the formal rules that validated them were abolished. At the same time, attempts by the Crown to show an absence of motive to lie have faced a high bar. Consistent with the general rule that motive is not required to prove mens rea, the accused’s motives have mostly escaped scrutiny. However, the recent high-profile case of R. v Barton shows the dangers of allowing the accused to rely on his alleged lack of motive to sexually assault the complainant. This article examines how both evidence of motive and absence of motive have been applied to the complainant and the accused in sexual assault cases. Caution is necessary when considering motive in relation to the complainant because of the direct connection with rape myths. Reliance on an accused’s absence of motive should also be discouraged as the reasons men rape cannot be reduced to a personal vendetta towards any one victim.

Publisher

University of Toronto Press Inc. (UTPress)

Subject

Law,Sociology and Political Science,Gender Studies

Reference77 articles.

1. R v Lewis, [1979] 2 SCR 821 [Lewis]. There are some offences in theCriminal Code, RSC 1985, c C-46, with explicit elements that can be described as speaking to the accused’s “motive.” These can include offences that require proof that the accused acted for a particular purpose. For example, the offence of possessing incendiary material for the purpose of committing arson (section 436.1) or inviting a young person to touch their own body or the body of another person for a sexual purpose (section 152) can be said to build an element of motive into the definition of the offence, although it could be argued that “purpose” does not always coincide with motive (for example, the motive for planning the arson may be financial, for revenge, and so on).

2. SeeR v Buzzanga and Durocher, 25 OR (2d) 705.

3. Lewis,supranote 1.

4. InLewis,supranote 1, the accused admitted that he mailed a package containing a bomb to a young couple. The bomb exploded, killing them both. Lewis claimed he was a dupe of the young woman’s father, who objected to her marriage. The Crown tried to show that Lewis benefited financially from his involvement in order to prove that he was aware of what he was mailing.

5. In total, 87 percent of sexual assaults reported to police involved an attacker who was known to the victim. See Cristine Rotenberg, “Police-reported Sexual Assaults in Canada, 2009 to 2014: A Statistical Profile” (3 October 2017),Statistics Canada This figure likely overstates the percentage of stranger sexual assaults because (1) such cases are more likely to be reported to police and (2) it involves victims that are fifteen years of age or older, and child sexual abuse is rarely committed by a stranger.

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