Law360 Canada ( July 17, 2026, 9:33 AM EDT) -- Appeal by appellant from convictions for historical sexual abuse. The complainant alleged that the appellant, her uncle, sexually abused her between 1993 and 2002, beginning when she was nine years old. The complainant testified in detail to repeated abuse, including incidents at the appellant’s home and during outings. She explained that she had no memory of the abuse until 2017, attributing this to suppressed or recovered memory. The appellant denied the allegations and testified that he treated the complainant similarly to his other nieces and nephews. The Crown relied in part on corroborative evidence from a witness who identified the appellant and confirmed aspects of the complainant’s account. Prior to trial, a recording in which the appellant apologized to the complainant was ruled admissible, while an email containing prior consistent statements was excluded. The appellant appealed on several grounds relating to the jury charge, including the application of the R v W.(D.) (W.(D.)) framework, the treatment of recovered memory evidence, and the adequacy of the eyewitness identification instruction. He also sought to admit fresh evidence consisting of a juror’s post‑verdict Facebook message expressing sympathy for the complainant and a note from the foreperson suggesting deliberations had begun before the jury charge was complete, arguing these raised a reasonable apprehension of bias. The Crown opposed the appeal and argued that the jury instructions were proper and that the fresh evidence did not rebut the presumption of juror impartiality....