unless the accused took sufficient steps to ascertain consent. Here, the accused did not make any attempt to ensure that the accused had consent when he moved from a massage to sexual touching. She also castigated McClung J's opinion severely, arguing that it reposed on myths and stereotypes about women and sexual assault. Aftermath In response to L'Heureux-Dubé's criticism, McClung wrote a letter to the National Post criticizing her and claiming she let her personal beliefs get in the way of her judgment. He also made the comment that her judgments contributed to a rise in male suicides in Quebec. He soon published an apology for the comment, saying he was unaware that L'Heureux-Dubé's husband had committed suicide. See also List of Supreme Court of Canada cases (Lamer Court) R v JA External links Supreme Court of Canada cases 1999 in Canadian case law Rape in Canada Canadian criminal case law