elected leader. He returned to office in the 2004 federal election as the Liberals were reduced to a minority government, and was retained as Justice Critic in the parliament that followed. On January 25, 2005, Toews pleaded guilty to the charge of exceeding his personal campaign expense limits in the 1999 provincial election. He claimed that the overspending resulted from a miscommunication between his campaign and the provincial party as to how some expenses were to be accounted. There were some calls for him to resign as Justice Critic, but nothing came of this. Toews received a $500 fine, and the charge remained on his record. A Winnipeg Free Press poll taken in late December 2005 showed Toews as the most popular choice to replace Stuart Murray as leader of the Manitoba Progressive Conservatives. He declined to contest the position, and was returned without difficulty in the 2006 Canadian federal election. Policy views As Justice Critic from 2001 to 2005, Toews frequently accused the Liberal government of being unfocused on crime issues. He supported the Chrétien government's decision to create a national sex offender registry in 2002, but criticized the government for not making the bill retroactive to include the names of previously convicted offenders. The non-retroactive approach followed the model of previous legislation in the United Kingdom. Toews criticized some Supreme Court decisions, and on one occasion accused former Chief Justice Antonio Lamer of overseeing a "frenzy of constitutional experimentation". He also called for official reviews of judicial appointments, arguing that the policy views of judges should be known before they take office. In September 2004, he delivered a speech to the National Pro-Life Conference entitled "Abuse of the Charter by the Supreme Court". In this speech, Toews criticized judicial implementation of the Charter of Rights and Freedoms, suggested that judges were implementing social policy, and called on his audience to build organizations to challenge the courts. Toews spoke favourably of the Charter of Rights and Freedoms on its twentieth anniversary in 2002, describing it as "a powerful check on the power of government to unreasonably intrude on our rights and freedoms". He also called for governments to demonstrate more willingness to use the Charter's Notwithstanding Clause to overrule court decisions. Toews specifically argued that the clause should have been used to overturn a court decision that he claimed weakened Canada's child pornography laws. (The Liberal government brought forward