for being cruel and unusual punishment. Writing for a 6–3 majority, Chief Justice McLachlin stated that criminal punishments need to reflect the seriousness of the crime. As a result, the Court held that the mandatory minimums are inconsistent with section 12 of the Charter and are therefore declared of no force of effect under section 52 of the Constitution Act, 1982. Dissenting, Moldaver held that the mandatory minimum sentencing provisions do not violate section 12 of the Charter. He argued that the illegal firearm possession provisions are hybrid offences and therefore only carry the mandatory minimum sentence if the Crown proceeds by indictment, instead of by summary conviction. He stated that the nature of the hybrid offence acts a "safety valve", which ensures that the least serious offenders will not face three years in prison. Therefore, Moldaver argued the focus should be on the constitutionality of the Crown's election to proceed by indictment rather than summarily, not the law itself. He concluded that an accused party will not be unjustly punished, based solely on the Crown's election, because if the Crown proceeds improperly and it leads to a "grossly disproportionate" sentence, there are remedies for an accused under section 24(1) of the Charter. Retirement Michael Moldaver's final sitting day on the Supreme Court was May 19, 2022. His retirement was effective September 1, 2022. Involvement within the legal community Moldaver has maintained an active role within the legal community. During his career as a trial lawyer, he was a one-time co-chair of the Canadian Bar Association, a director of the Criminal Lawyers' Association and the Advocates' Society, and a co-chair of the University of Toronto Academic Tribunal, Discipline Subsection. In addition, he co-chaired the 1989 and 1990 Advocacy Symposiums. Throughout his professional life, Moldaver has contributed to legal education. From 1975 to 1995, he taught criminal law classes at Osgoode Hall Law School and the University of Toronto. Though he no longer teaches at either university, he continues to sponsor awards at the University of Toronto. Moldaver has volunteered as a guest judge on final panels for various national law school moot competitions. Amongst others, he sat on the final panel of the 2014 Wilson Moot and the 2016 Davies Corporate/Securities Moot. Apart from post-secondary education, Moldaver has contributed to continuing legal education programs for lawyers and the judiciary. He has frequently taught and spoken at numerous educational programs. Some