case. The group raised a number of potential implications of the decision, including: the prospect that criminalizing a failure to disclose one's HIV status will deter sexually active persons from getting tested for HIV in the first place, the potential of a negative impact on doctor-patient relationships if the courts open the door to a doctor being subpoenaed to testify as to the defendant's HIV status, lulling sexually active persons into a "false sense of security" that they need not practice safer sex since criminal law, rather than their own sexual behaviour, protects them from HIV risk. The court also did not rule that any burden of proof exists whether the accused even knew how to protect their sexual partners. While practising safer sex is considered a valid defense, no burden of proof exists whether the HIV-positive partner had ever actually been educated in safer sex practices. Generally, legal analysts and HIV educators viewed the decision as "the wrong tool for the job", suggesting that it was an attempt to use criminal law to resolve what is, first and foremost, a public health matter. In a similar American case, Stephen Gendin, a vice-president of Poz, commented that Other cases The first Canadian citizen ever charged with failing to disclose his HIV status to a sexual partner was Charles Ssenyonga, a Ugandan immigrant living in London, Ontario, who was charged with aggravated assault stemming from three sexual encounters in the late 1980s. However, Ssenyonga died in 1993 before a verdict was rendered in his case. Harold Williams of Newfoundland was charged with aggravated assault, and common nuisance in a controversial 2003 decision, which overturned a 2000 sentencing. While Williams knowingly had frequent unprotected sex with a partner, and she became HIV positive, he received a relatively light charge as the Crown could not provide evidence that she was previously HIV negative. However, the impact of this decision was mitigated as Williams was separately sentenced to five years imprisonment for having unprotected sex with two other women without disclosing his HIV positive status. Ray Mercer, a 28-year-old man from Upper Island Cove, Newfoundland and Labrador, was charged with criminal negligence causing bodily harm in 1991 after potentially infecting up to 14 women. (He was charged after Ssenyonga, but went to trial earlier.) He was sentenced in 1992 to two-and-a-half years in prison; on a Crown appeal, Mercer's sentence was increased to 11