misfortune." This was viewed as a "serious and fundamental error" by the Royal Commission report. Anne Derrick, Q.C., well-known social justice advocate lawyer, worked as Marshall's counsel, and Order of Canada recipient Clayton Ruby was co-counsel for Marshall, along with Anne Derrick, during the 1989 Royal Commission on Marshall's prosecution. The Crown Attorney's failure to provide full disclosure (contradictory and coerced statements by witnesses, because they believed the evidence not provided had no bearing in the case) brought about changes in the Canadian rules of evidence regarding disclosure. The prosecution must provide full disclosure without determination on what may be useful to the defence (that is the defence's duty to decide). Compensation and aftermath A separate Royal Commission in 1990, headed by Justice Gregory T. Evans, concluded in June that year to increase Marshall’s compensation from $270,000 to a lifetime pension of $1.5 million. His conviction resulted in changes to the Evidence Act in Canada which was amended so that any evidence obtained must be presented to the defence on disclosure. Prior to this case, Crown Attorneys had discretion to present what they determined to be pertinent to a case. After 1983, the C.A. must provide all evidence with no determination on its usefulness. The rationale of the law is that it is more appropriate for the defense to determine what may or may not assist an accused. In response, a Royal Commission was formed to investigate what had caused the miscarriage of justice; this led to an influential case on judicial independence in Canada, Mackeigan v. Hickman. Fishing rights battle Subsequently, Marshall reached prominence as the primary petitioner in the landmark Supreme Court of Canada case R. v. Marshall [1999] 3 SCR 456 regarding treaty rights allowing Aboriginal people to catch and sell fish under the relevant treaties. The treaty right was established, and Marshall was acquitted. Subsequent arrests In January 2006, Marshall faced charges of attempted murder, uttering death threats and dangerous driving following a New Year's Eve party in which Marshall was accused of attacking a man with a vehicle. The charges were dropped after both men agreed to participate in a restorative justice meeting. In 2008, Marshall faced charges of assault against his wife, uttering threats against his wife and her ex-husband and breach of an undertaking. Death Marshall died 6 August 2009, in Sydney, Nova Scotia, from complications of a 2003 lung transplant. Legacy The