If this opinion indicates that it is “FOR PUBLICATION,” it is subject to 

revision until final publication in the Michigan Appeals Reports.

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S T A T E O F M I C H I G A N

C O U R T O F A P P E A L S

PEOPLE OF THE STATE OF MICHIGAN,

Plaintiff-Appellee,

UNPUBLISHED

May 30, 2024

v No. 362790

Lenawee Circuit Court

VICTOR PEREZ RUIZ, LC No. 2021-020379-FC

Defendant-Appellant.

Before: GARRETT, P.J., and SERVITTO and REDFORD, JJ.

PER CURIAM.

Defendant appeals as of right his jury trial convictions of first-degree criminal sexual 

conduct (CSC-I) (victim under 13 and defendant over 17), MCL 750.520b(1)(a) and (2)(b); and 

second-degree criminal sexual conduct (CSC-II) (victim under 13 and defendant over 17), MCL 

750.520c(1)(a). Defendant was sentenced to 25 to 40 years’ imprisonment for CSC-I and 38 to 

180 months’ imprisonment for CSC-II. We affirm defendant’s convictions and sentence.

I. BACKGROUND

On April 3, 2019, defendant babysat his step grandchildren, EC and LS, at his home. EC

was eight years old at the time. Defendant took the children to Walmart and bought them each a 

gift. When they returned from the store, LS went to play video games. Defendant told EC to go 

to the bedroom of his wife, Marcia. In the bedroom, defendant rubbed EC’s vagina with his penis 

and performed cunnilingus on her. After the first incident, EC followed defendant’s request to 

shower. EC watched television before defendant took her in the basement, outside of the bedroom 

of defendant’s son, Anthony Ruiz. Defendant repeated the same acts on EC in the basement. After 

the second incident, EC washed up and they ate lunch. Later, the children’s mother, Lisa, came 

and took the children home.

Defendant denied both incidents and testified that Anthony was home all day, and they 

both even watched EC draw and paint pictures. Anthony confirmed the testimony and further 

testified that he never saw defendant assault EC. EC and LS both testified that they did not see 

Anthony that day. EC testified that Anthony slept in his room in the basement all day. LS himself

spent most of the day sitting at the dining room table playing video games with his headphones on 
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talking to players online. Defendant testified that Lisa came at 3:00 p.m., leaving no time for the 

incidents to occur, but EC testified that Lisa came a couple hours after the second incident.

On appeal, defendant argues that trial counsel was ineffective for failing to offer evidence 

to bolster defendant’s credibility and aid in his defense, eliciting damaging testimony during crossexamination, and misstating the burden of proof during his opening statement. He argues that he

was prejudiced by the cumulative effect of these errors. Further, he argues that the trial court 

erroneously instructed the jury, and trial counsel was ineffective for failing to object to the error. 

Finally, defendant argues that his mandatory minimum sentence of 25 years’ imprisonment was 

unconstitutional.

II. INEFFECTIVE ASSISTANCE OF COUNSEL

Defendant contends that his trial counsel was ineffective for (1) failing to admit evidence 

in support of the defense strategy, (2) eliciting damaging and improper credibility testimony, and 

(3) stating the wrong burden of proof to the jury.1 Defendant contends that but for trial counsel’s 

cumulative errors, there was a reasonable probability of a different outcome at trial. We disagree. 

For the reasons we will discuss below, we do not find counsel was deficient regarding evidence 

and trial strategy about witness credibility. We do conclude, however, counsel did misstate the 

law in his opening statement regarding the burden of proof, and was deficient in this regard; but 

this mistake was corrected multiple times by defense counsel and the court, and as a result did not 

impact the case.

A. STANDARD OF REVIEW

“A claim of ineffective assistance of counsel presents a mixed question of fact and 

constitutional law.” People v Isrow, 339 Mich App 522, 531; 984 NW2d 528 (2021) (quotation 

marks and citation omitted). This Court reviews the trial court’s findings of fact for clear error, 

while it reviews questions of law de novo. People v Trakhtenberg, 493 Mich 38, 47; 826 NW2d 

136 (2012). “Clear error occurs if the reviewing court is left with a definite and firm conviction 

that the trial court made a mistake.” People v Johnson, 502 Mich 541, 565; 918 NW2d 676 (2018) 

(quotation marks and citation omitted).

Both the United States and Michigan Constitutions guarantee a defendant the right to 

effective assistance of counsel. US Const, Am VI; Const 1963, art 1, § 20. In order to obtain a 

new trial, a defendant must establish that “(1) counsel’s performance fell below an objective 

standard of reasonableness and (2) but for counsel’s deficient performance, there is a reasonable 

probability that the outcome would have been different.” Trakhtenberg, 493 Mich at 51. “The 

inquiry into whether counsel’s performance was reasonable is an objective one and requires the 

 

1 Defendant moved both this Court and the trial court for an evidentiary hearing to consider each 

of the asserted errors, which both courts denied. People v Ruiz, unpublished order of the Court of 

Appeals, entered November 15, 2023 (Docket No. 362790). Because no evidentiary hearing was

held below, our review is limited to mistakes that are apparent on the record. People v Gioglio

(On Remand), 296 Mich App 12, 20; 815 NW2d 589 (2012), vacated not in relevant part 493 Mich 

864 (2012).
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reviewing court to determine whether, in light of all the circumstances, the identified acts or 

omissions were outside the wide range of professionally competent assistance.” People v Vaughn, 

491 Mich 642, 670; 821 NW2d 288 (2012) (quotation marks and citation omitted). “A reasonable 

probability is a probability sufficient to undermine confidence in the outcome.” Strickland v 

Washington, 466 US 668, 694; 104 S Ct 2052; 80 L Ed 2d 674 (1984). “Effective assistance of 

counsel is presumed, and the defendant bears a heavy burden of proving otherwise.” People v 

Eisen, 296 Mich App 326, 329; 820 NW2d 229 (2012) (quotation marks and citation omitted). 

We will not substitute our own judgment for that of counsel or use the benefit of hindsight in 

assessing trial counsel’s competence. People v Unger, 278 Mich App 210, 242-243; 749 NW2d 

272 (2008). Counsel is not ineffective for failing to raise meritless or futile objections. Eisen, 296 

Mich App at 329.

B. EVIDENCE DEFENDANT ARGUES SHOULD HAVE BEEN OFFERED AT TRIAL

Defendant first argues that trial counsel’s performance was deficient because he failed to 

move for the admission of a Walmart receipt showing that defendant purchased EC and LS gifts 

worth a total of $46.07 at 1:44 p.m. on the day of the incident. On appeal, defendant asserts that 

the receipt would have helped corroborate his testimony that there was not enough time after he 

took the children to the store, picked up lunch, and ate lunch with them for defendant to sexually 

assault EC before Lisa arrived to pick the children up.

At trial, EC testified defendant took her and LS to Walmart and defendant assaulted her 

twice after they returned from the store. A couple hours after the incidents, her mother arrived to 

pick them up. Both EC and her brother testified they stayed all day at defendant’s house. In 

contrast, defendant testified that they left Walmart at approximately 1:45 p.m., picked up food, 

and ate at the house, all before Lisa arrived before 3:00 p.m., leaving no time for either incident to 

occur.

Trial counsel’s strategy included eliciting testimony from defendant that there was not time

for the incidents to occur. The timestamp on the Walmart receipt had limited value in relation to 

this strategy. No one contested the time that defendant went to Walmart. More importantly,

testimony conflicted regarding the time that EC’s mother came to pick up the children. Because 

of the conflicting testimony, no witness established a definitive timeline of the day. Admission of 

the receipt showing that defendant purchased the gifts at 1:44 p.m. would not show that there was 

no time for defendant to assault EC before her mother arrived. Accordingly, trial counsel’s 

decision not to admit the receipt did not fall below an objective standard of reasonableness. See 

Vaughn, 491 Mich at 670.

Defendant also asserts that the receipt was necessary to rebut the assertion that defendant 

bought EC an expensive gift in exchange for her silence. At trial, EC testified that defendant 

bought her a “Game Boy” and EC’s father testified that defendant bought EC a $120 gift in 

exchange for her silence. Although corroborative, the receipt was unnecessary to rebut the 

testimony that defendant bought EC an expensive gift to buy her silence. EC called the gift a 

“Game Boy” in her testimony, but she did not testify how much the gift cost. EC’s father, who 

was not present the day of the incident, was the only witness to testify that defendant bought an 

expensive gift. His testimony was rebutted by Anthony’s testimony that defendant bought a cheap 

“mini game” “rip off” and defendant’s testimony that he had a receipt showing that he bought EC 
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a $20 handheld game and LS a $20 to $25 gaming gift card. Trial counsel’s decision to elicit this 

evidence through testimony was a matter of trial strategy. Given the strong presumption that trial

counsel’s decisions are the result of sound trial strategy, we cannot conclude that trial counsel’s 

decision not to offer the receipt as evidence fell below an objective standard of reasonableness. 

See id.

Next, defendant argues that trial counsel performed deficiently because he failed to admit 

text messages wherein EC allegedly texted Marcia to request to go to her and defendant’s house 

nine days after the incident. Defendant asserts that these text messages would cast doubt on EC’s 

testimony because she wanted to go to her perpetrator’s house within days of the incident. At trial, 

trial counsel attempted, but failed to admit the text message through EC. Trial counsel asked EC 

if she sent defendant the text message. After reviewing the text message, EC still did not remember 

sending it. Trial counsel asked EC to read the contents of the text message aloud, but the trial 

court sustained an objection from the prosecution for lack of foundation. Without the proper 

foundation, evidence cannot be admitted. See People v McDade, 301 Mich App 343, 353; 836 

NW2d 266 (2013); MRE 901. Defendant does not assert that the trial court erroneously sustained 

the objection. The failure to admit the text message was not a result of trial counsel’s deficient 

performance, but because EC did not remember the text message. Further, trial counsel could not

alternatively admit the text message through defendant. Although unclear who the text message 

was sent to, the text message was likely sent to Marcia and not defendant because a text included 

in the screenshot tells the recipient to share a phone number with defendant. We reject defendant’s 

claim that trial counsel was ineffective for failing to admit evidence through no fault of his own.

Defendant contends that trial counsel was ineffective for his decision not to seek admission 

of a video depicting the layout of defendant’s house. Defendant specifically claims that, by 

demonstrating how close to the bedroom and basement doors LS sat, the video showed that LS 

could not have missed seeing defendant take EC through either door to the locations where the 

assaults occurred. At trial, LS testified that he sat where he could see the kitchen, living room, 

and the two doors. However, he also testified that he was not paying attention because he was 

wearing headphones and playing video games. Contrary to defendant’s assertion, the video would 

not contradict LS’s testimony. LS did not testify that he could not have possibly seen defendant 

take EC through the doors from where he sat, but that he was not paying attention to what EC or 

defendant did at the time. Trial counsel’s performance did not fall below an objective standard of 

reasonableness for failing to admit the video. See Vaughn, 491 Mich at 670.

Final in defendant’s assertion of evidentiary errors, defendant argues that trial counsel was 

ineffective when he did not admit EC’s artwork from the day of the incident. Defendant contends 

that the artwork corroborated Anthony’s testimony that he was in the home that day and watched 

EC draw, but saw nothing indicative of an assault. At trial, Anthony and defendant both testified

that Anthony was in the house and saw EC drawing and painting. In contrast, both EC and LS 

testified that they did not see Anthony that day. Neither EC nor LS testified that EC made artwork 

that day. “When credibility is a dominant consideration in ascertaining guilt or innocence, other 

independent evidence apart from the testimony of the defendant and the victim is particularly vital 

to the fact-finding process.” People v Brown, 506 Mich 440, 453; 958 NW2d 60 (2020). Although 

credibility was a dominant consideration in this case, admission of the artwork would not 

corroborate Anthony’s testimony or discredit EC’s and LS’s testimony. Anthony did not describe 

the pictures he allegedly observed EC making. Nothing in Anthony’s testimony demonstrated that 
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he saw EC drawing and painting these particular pictures on that particular day. Accordingly, even 

if the jury accepted that EC made the artwork, the jury had no basis to accept that the artwork was 

made the day of the incident. Admission of these pictures would not demonstrate that EC lied 

about seeing Anthony that day and had little corroborative benefit. Therefore, defendant has not 

overcome the presumption that trial counsel reasonably determined that the artwork would not aid 

his defense strategy.

Defendant also argues that trial counsel’s performance was deficient because he asked 

EC’s parents, Troy and Lisa, about EC’s truthfulness at trial, to which they stated that she was 

always truthful, thereby bolstering her credibility. While it is correct trial counsel asked EC’s 

parents about her truthfulness, it is apparent that trial counsel did not seek to bolster her credibility. 

Instead, trial counsel elicited Troy’s and Lisa’s testimony to reveal their bias. When trial counsel 

asked Troy and Lisa if EC ever lied, both adamantly affirmed that EC “never” lied. Troy said this 

after he just testified that EC initially lied to him twice when he asked her about the incident. Both 

Troy and Lisa’s adamant testimony that EC, a young child, never lied in her life, demonstrated

their bias and hurt their credibility. Trial counsel’s elicitation of this testimony was reasonable 

trial strategy.

C. STATEMENTS BY DEFENSE COUNSEL REGARDING BURDEN OF PROOF

Defendant argues that trial counsel’s performance was deficient because he misstated the 

burden of proof, leading the jury to believe that one party or the other had to be believed beyond 

a reasonable doubt. During opening statements, trial counsel stated the following when 

acknowledging that witness testimony alone was enough to convict defendant:

[T]he prosecutor is absolutely right, when they say, hey, on a case like this, you 

don’t need any corroboration. The witness’ [sic] testimony or the victim’s 

testimony is enough. You don’t need to have anything other than testimony to 

convict. That’s absolutely true.

But that also applies for the [d]efendant. You don’t need anything other 

than the [d]efendant’s testimony either. This case will come down to who you 

believe beyond a reasonable doubt. [emphasis added.]

The burden of proof rests solely on the prosecution. See People v Posey, 512 Mich 317, 323; 1 

NW3d 101 (2023) (“For a jury to find a defendant guilty of a charged crime, the prosecution must 

demonstrate that the defendant is guilty of every element of a crime beyond a reasonable doubt.”) 

In context, trial counsel attempted to explain to the jurors that they can believe defendant’s 

testimony without corroboration as well. However, the manner in which trial counsel expressed 

this point implied that the jury had to either believe the prosecution’s witnesses beyond a 

reasonable doubt, or the defense’s witnesses beyond a reasonable doubt. Consequently, trial 

counsel implied a shift of the burden to both the prosecution and defense that was not reasonable 

trial strategy. Therefore, trial counsel performed deficiently when he misrepresented the burden 

of proof.

Although trial counsel’s performance was deficient, defendant cannot establish that but for 

this deficiency, a reasonable probability existed that the outcome of the trial would be different. 
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Trial counsel misstated the law briefly during his opening statement. This misstatement was 

corrected numerous times. Both before and after opening statements, the trial court instructed the 

jury on the proper burden of proof. The prosecution also correctly stated the burden of proof 

during opening statements. During closing arguments, both parties correctly stated the burden of 

proof. Then, the trial court instructed the jury on the correct burden of proof for a third time before 

jury deliberations. “[J]urors are presumed to follow their instructions.” Unger, 278 Mich App 

at 235. Any confusion from trial counsel’s brief misstatement of the law was cured by the trial 

court’s correct instruction. Accordingly, defendant cannot establish prejudice.

Finally, defendant argues that trial counsel’s errors cumulatively undermined the outcome 

of this case and denied him a fair trial. “[T]he cumulative effect of several errors can constitute 

sufficient prejudice to warrant reversal where the prejudice of any one error would not.” People v 

LeBlanc, 465 Mich 575, 591; 640 NW2d 246 (2002). Because trial counsel’s performance 

contained only one nonprejudicial deficiency, there was no cumulative error that would warrant a 

new trial.

III. INSTRUCTIONAL ERROR OR INEFFECTIVE ASSISTANCE

Defendant argues that he was denied due process because the trial court read an erroneous 

instruction for CSC-I. Alternatively, defendant argues that trial counsel was ineffective for failing 

to object to the jury instruction. Review of the purported erroneous instruction is waived. Trial 

counsel was not ineffective for failing to object to the instruction.

A. STANDARD OF REVIEW

Trial counsel’s “affirmative expression of satisfaction with the trial court’s jury instruction 

waive[s] any error” with the jury instructions. People v Chapo, 283 Mich App 360, 372-373; 770 

NW2d 68 (2009). “When the trial court asks whether a party has any objections to the jury 

instructions and the party responds negatively, it is an affirmative approval of the trial court’s 

instructions.” People v Miller, 326 Mich App 719, 726; 929 NW2d 821 (2019). Trial counsel 

waived appellate review when he twice affirmed his satisfaction with the instructions. Trial

counsel’s waiver extinguished any error, leaving no error to review. Chapo, 283 Mich App at 372-

373.

B. CSC-I JURY INSTRUCTION

Alternatively, defendant asserts that trial counsel was ineffective for failing to object to the 

jury instruction. Defendant contends that the trial court erred regarding the penetration element of 

CSC-I when it instructed the jury as follows:

The [d]efendant is charged with the crime of first degree criminal sexual 

conduct. To prove this charge, the prosecutor must prove each of the following 

elements beyond a reasonable doubt. First, that the [d]efendant engaged in a sexual 

act that involved touching of [EC’s] genital organs with the defendant’s mouth or 

tongue.
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Defendant contends that the instruction failed to distinguish CSC-I from lesser offenses that only 

require touching for sexual gratification. We disagree.

We review this unpreserved claim of ineffective assistance of counsel for error apparent 

on the record. People v Spaulding, 332 Mich App 638, 656; 957 NW2d 843 (2020). Criminal 

defendants have “the right to have a properly instructed jury consider the evidence against him.” 

People v Mills, 450 Mich 61, 80; 537 NW2d 909 (1995), mod 450 Mich 1212 (1995); see also US 

Const, Ams VI, XIV; Const 1963, art 1, § 20. “Jury instructions are to be read as a whole rather 

than extracted piecemeal to establish error.” People v Kurr, 253 Mich App 317, 327; 654 NW2d 

651 (2002). There is no error when the instructions “fairly presented the issues to be tried and 

sufficiently protected the defendant’s rights.” People v McFall, 224 Mich App 403, 412-413; 569 

NW2d 828 (1997) (quotation marks and citation omitted).

To convict defendant of CSC-I, the jury had to find that defendant engaged in sexual 

penetration with a person under 13 years of age. People v Duenaz, 306 Mich App 85, 106; 854 

NW2d 531 (2014). “Sexual penetration” is defined as “sexual intercourse, cunnilingus, fellatio, 

anal intercourse, or any other intrusion, however slight, of any part of a person’s body or of any 

object into the genital or anal openings of another person’s body . . . .” MCL 750.520a(r). 

Although the trial court did not use the words “sexual penetration,” the instruction given described 

the only way, with the facts presented in this case, that the jury could find that defendant sexually 

penetrated the victim’s genital opening—by performing cunnilingus. Both the CSC statute and 

caselaw recognize cunnilingus as a form of sexual penetration regardless of whether entry of the 

vaginal canal occurs. MCL 750.520a(r); People v Legg, 197 Mich App 131, 132-133; 494 NW2d 

797 (1992). It is irrelevant that the trial court did not use the word “cunnilingus” because the 

instructions described the specific act that the jury needed to convict defendant of CSC-I under a 

theory of cunnilingus—a sexual act that involved touching of the victim’s genital organs with the 

defendant’s mouth or tongue. Legg, 197 Mich App at 133 (defining cunnilingus as “the placing 

of the mouth of a person upon the external genital organs of the female . . . .”) (quotation marks 

and citation omitted). Accordingly, the trial court did not err when it instructed the jury regarding

CSC-I. Because we conclude that the trial court properly instructed the jury, an objection to this 

instruction would have been futile. Eisen, 296 Mich App at 329.

IV. MANDATORY SENTENCING

Finally, defendant argues that the trial court’s application of the 25-year mandatory 

minimum sentence was cruel or unusual both facially and as applied to him. We disagree.

A. STANDARD OF REVIEW

Because defendant did not preserve this claim by raising the issue in the trial court, we 

review it for plain error affecting his substantial rights. People v Burkett, 337 Mich App 631, 635; 

976 NW2d 864 (2021). However, the constitutionality of a statute is a question of law that we 

review de novo. Id.
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B. CRUEL AND UNUSUAL PUNISHMENT REVIEW

The Eighth Amendment of the United States Constitution prohibits “cruel and unusual 

punishment.” US Const, Am VIII. The Michigan Constitution more broadly prohibits “cruel or 

unusual punishment.” Const 1963, art 1, § 16; People v Taylor, 510 Mich 112, 124 n 9; 987 NW2d 

132 (2022). When assessing whether a punishment is cruel or unusual, this Court assesses the four 

following factors: (1) the harshness of the penalty compared to the gravity of the offense, (2) the 

penalty imposed for the offense compared to penalties imposed for other offenses in Michigan, (3) 

the penalty imposed for the offense in Michigan compared to the penalty imposed for the same 

offense in other states, and (4) whether the penalty imposed advances the goal of rehabilitation. 

People v Bullock, 440 Mich 15, 30, 33-34; 485 NW2d 866 (1992).

Defendant presents both a facial and an as-applied challenge to the constitutionality of 

MCL 750.520b(2)(b). “A facial challenge attacks the statute itself and requires the challenger to 

establish that no set of circumstances exists under which the [a]ct would be valid.” People v 

Johnson, 336 Mich App 688, 695; 971 NW2d 692 (2021) (quotation marks and citation omitted; 

alteration in original). Whereas “[a]n as-applied constitutional challenge is based upon the 

particular facts surrounding defendant’s conviction and sentence.” People v Adamowicz (On 

Second Remand), ___ Mich App ___, ___; ___ NW3d ___ (2023) (Docket No. 330612); slip op 

at 9 n 10.

First, defendant’s facial challenge is foreclosed by binding precedent. A conviction of

CSC-I under MCL 750.520b(2)(b) is subject to a mandatory minimum of 25 years’ imprisonment. 

In People v Benton, 294 Mich App 191, 204-207; 817 NW2d 599 (2011), after addressing the 

Bullock factors, we held that the 25-year mandatory minimum sentence in MCL 750.520b(2)(b) 

was not cruel or unusual. Defendant concedes that Benton is controlling Michigan caselaw. MCR 

7.215(C)(2). Because published caselaw holds that the 25-year mandatory minimum sentence 

under MCL 750.520b(2)(b) is not facially cruel or unusual, we conclude that defendant did not 

demonstrate plain error affecting his substantial rights.

Second, defendant’s as-applied challenge to his sentence fails because he did not present 

unusual circumstances to overcome the presumption of proportionality. “Legislatively mandated 

sentences are presumptively proportional and presumptively valid.” Burkett, 337 Mich App at 637

(quotation marks and citation omitted). “[A] proportionate sentence is not cruel or unusual.” 

People v Bowling, 299 Mich App 552, 558; 830 NW2d 800 (2013). “In order to overcome the 

presumption that the sentence is proportionate, a defendant must present unusual circumstances 

that would render the presumptively proportionate sentence disproportionate.” Burkett, 337 Mich 

App at 637 (quotation marks and citation omitted).

Defendant argues that his sentence was disproportionate because of his age and lack of 

prior criminal history. Defendant does not address the Bullock factors or indicate how his age and 

lack of prior criminal history relate to these factors in his analysis. A defendant may not simply 

“announce a position or assert an error and then leave it up to this Court to discover and rationalize 

the basis for his claims, or unravel and elaborate for him his arguments, and then search for 

authority either to sustain or reject his position.” People v Kevorkian, 248 Mich App 373, 389; 

936 NW2d 291 (2001). Accordingly, we only address whether defendant raised sufficiently 

unusual circumstances to overcome the presumption of proportionality.
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Defendant cites journals indicating that the statistical likelihood that someone would 

molest a child peaks between ages 30 and 40, and decreases to nearly zero after age 70—the age 

defendant will be after serving only 10 years of his 25-year-minimum sentence.2 The seriousness 

of the offense is not lessened by defendant’s age at the time of the offense. This Court has 

explained that a “defendant’s age is insufficient to overcome the presumption of proportionality.” 

People v Purdle, ___ Mich App ___, ___; ___ NW3d ___ (2024) (Docket No. 353821); slip op 

at 6. Defendant’s lack of criminal history is also insufficient to overcome the presumption that his 

legislatively-mandated sentence was proportional. People v Daniel, 207 Mich App 47, 54; 523 

NW2d 830 (1994). Accordingly, no unusual circumstances overcome the presumption of 

proportionality in this case.

Affirmed.

/s/ Kristina Robinson Garrett 

/s/ Deborah A. Servitto 

/s/ James Robert Redford 

 

2 See e.g., Hanson, Age and Sexual Recidivism: A Comparison of Rapists and Child Molesters, 

Dep’t of the Solicitor General Canada (2001), available at 

<https://www.publicsafety.gc.ca/cnt/rsrcs/pblctns/sxl-rcdvsm-cmprsn/sxl-rcdvsm-cmprsneng.pdf> (accessed April 12, 2024).