MétaCan
Menu
Back to cohort
Record W4409674518 · doi:10.3138/cjwl-05-x

Left Wanting: A Case Comment on <i>R. v Kirkpatrick</i>

2025· article· en· W4409674518 on OpenAlexaboutno aff
Lauren Grammer

Bibliographic record

VenueCanadian Journal of Women and the Law/Revue Femmes et Droit · 2025
Typearticle
Languageen
FieldSocial Sciences
TopicCriminal Law and Evidence
Canadian institutionsnot available
Fundersnot available
KeywordsPhilosophy

Abstract

fetched live from OpenAlex

This article examines the Supreme Court of Canada’s decision in R. v Kirkpatrick, a pivotal case where the court grappled with answering the tired, yet age old, question: what is consent. Here, the accused surreptitiously removed a condom before sexual intercourse despite the sex being conditioned on his condom use. In its decision, the majority sidestepped a harmful precedent set in R. v Hutchinson, which placed condom use under the fraud provision of the newly adopted consent test from the same case. While the majority’s decision was welcome, I criticize the Court for not going far enough. The majority failed to reverse the Hutchinson precedent, failed to denounce the fraud provision as an illegitimate marker of consent, and failed to grapple with the realities of sex. The majority missed the notion that, when a person removes a condom during sex, they have changed the sexual act and thus require fresh consent, regardless of whether there was an agreement beforehand. While the majority’s decision is a step in the right direction in sexual assault cases, it was not the leap forward that women need to feel fully protected by the law.

Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.

How this classification was reachedexpand

Full frame machine prediction

Teacher imitation

Not calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.

metaresearch head score (Codex)0.009
metaresearch head score (Gemma)0.024
Version: metacan-v3-hybrid-931329e0061cValidation status: machine_predicted_unvalidated
Candidate categoriesnone
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Not applicable · Consensus signal: Not applicable
GenreCandidate signal: Commentary · Consensus signal: Commentary
Teacher disagreement score0.177
Threshold uncertainty score0.355

Distilled classifier scores by category (both heads)

CategoryCodexGemma
Metaresearch0.0090.024
Meta-epidemiology (narrow)0.0010.001
Meta-epidemiology (broad)0.0010.002
Bibliometrics0.0010.002
Science and technology studies0.0320.015
Scholarly communication0.0100.005
Open science0.0070.005
Research integrity0.0450.060
Insufficient payload (model declined to judge)0.0050.001

Machine scores (provisional)

The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.

Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.

Opus teacher head0.031
GPT teacher head0.295
Teacher spread0.264 · how far apart the two teachers sit on this one work
Validation statusscore_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it

Classification

machine, unvalidated

Machine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.

The models applied no category: nothing in the taxonomy fit this work.
Study designNot applicable
Domainnot available
GenreCommentary

How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".

Quick stats

Citations0
Published2025
Admission routes1
Has abstractyes

Explore more

Same venueCanadian Journal of Women and the Law/Revue Femmes et DroitSame topicCriminal Law and EvidenceFrench-language works237,207