Christopher Wirth and Edward Marrocco published “Penner’s Paradox Continued” in the March 2014 edition of the Canadian Journal of Administrative Law and Practice. This commentary discusses the renewed debate on the appropriate standard of proof applicable to non-criminal and administrative tribunal matters subsequent to the Supreme Court of Canada’s decision in Penner v. Niagara Regional Police Services Board, 2013 SCC 19. To read the article, click here.