A CJC panel said comments by Quebec judge Francois Huot were 'influenced by human emotions'
A Canadian Judicial Council panel declined to sanction a Quebec judge who told a convicted murderer he was “completely devoid of morality” and “sexually depraved,” stating that while the comments were inappropriate, judges should still have the freedom “to express themselves without being held to an impossible standard of weighing every word.”
Superior Court of Quebec Justice Francois Huot made the comments at issue in February 2024 when he presided over the highly publicized trial of Marc-André Grenon. At the trial, Grenon was found guilty of murdering and sexually assaulting a 19-year-old student in 2000.
Following the conviction but before sentencing, Huot told Grenon he was “spineless, cowardly, craven.”
The judge said, “You have spent 22 years of your life living free and waking up every morning as if nothing had happened. How were you able to look at yourself in the mirror every morning while Guylaine [Potvin] lay six feet underground because of your moral, your sexual depravity and your killer instinct?”
Huot asked Grenon how he could dare to look at the victim’s family.
“I feel only disgust and contempt for your actions on April 28, 2000,” Huot said. “You are completely devoid of morality, you are sexually depraved, a murderer, you make me sick.”
Following the trial, Sylvie Champagne, a director at the Barreau du Quebec, filed a complaint against Huot with the CJC. Champagne alleged Huot did not treat Grenon “with courtesy and respect,” contrary to his obligations under the CJC’s Ethical Principles for Judges.
As part of the CJC’s review process, Huot provided letters outlining his version of the events. The judge admitted his conduct was inappropriate and apologized if his comments discredited the Superior Court of Quebec or the administration of justice.
Huot said the trial was emotionally taxing and left him shocked by Grenon’s behaviour. The judge added that he had hoped that his comments – which he did not prepare in advance – would provide comfort to the victim’s family. However, he acknowledged that he could have achieved this with a more respectful tone.
The CJC also invited Superior Court of Quebec associate chief justice Catherine La Rosa to weigh in. La Rosa confirmed that Huot had apologized for his conduct and noted that since Grenon’s trial, Huot has presided over other trials in accordance with the law.
In one letter, La Rosa noted that Huot has “impressive legal experience in the field of criminal law” and has presided over many criminal hearings. The associate chief justice said she believed Huot did not make his comments with malicious intent, was sincerely sorry, and would not engage in such conduct again.
In its decision, the review panel said the Ethical Principles for Judges, which outlines ethical obligations for judicial officers, “represent an ideal” and offer advice “rather than prescribing a code of conduct.”
The panel said Huot’s behaviour did not meet the high ethical standards set out in the Ethical Principles for Judges and could qualify as punishable misconduct if taken in isolation.
However, the panel said assessing the context surrounding the conduct was also important. The panel’s members accepted Huot’s “explanation that his actions were influenced by human emotions – a reaction that can be understood, given the circumstances,” the decision said.
“While his reprimands of the accused were inappropriate, it is important to recognize that emotions can run high in the courtroom and that judges must retain some degree of freedom to express themselves without being held to an impossible standard of weighing every word,” the panel said.
Given the circumstances of his comments, Huot’s sincere apology, and his acknowledgement of his error, the panel said it was “not satisfied that his conduct constitutes judicial misconduct that warrants formal sanctions.”
Huot could not be reached for comment. In a statement, a spokesperson for the Superior Court of Quebec said it acknowledged the CJC’s decision but declined to comment on the matter.
The Barreau du Quebec and Grenon’s counsel in the criminal case also declined to comment.
