A victim impact statement is the one moment in a criminal case that belongs to the people left behind. Everything before it, the charge, the evidence, the plea or the verdict, is the business of police, lawyers and juries. Then, in the short interval between guilt and punishment, a mother or a son or a sister is allowed to stand and say what the death has cost. Courts in Canada and the United States have spent decades deciding how much weight those words may carry. The answer, in case after case, has been less than the families hoped and more than the defendants would have liked.
The serial murder cases below span three decades and two countries. In some of them the families spoke to a judge who had no real choice to make. In one, the families decided the sentence before anyone took the stand. In two others, appellate courts were asked whether the statements had gone too far.
When Bruce McArthur pleaded guilty on January 29, 2019, to eight counts of first-degree murder, the sentence was fixed by law at life imprisonment. The only open question was parole. Under the law then in force, Justice John McMahon of the Ontario Superior Court could order the parole ineligibility periods to run one after another. The Crown asked for exactly that, a total of 50 years. McArthur’s lawyer, James Miglin, asked for 25, citing his client’s age.
About 30 victim impact statements were filed, and relatives, friends and community groups spoke over the first days of the hearing. The brother of Skandaraj Navaratnam said the family had lost Skanda’s financial support, had paid to bring him back to them, and that their mother, who was ill, still did not know the truth. The former wife of Abdulbasir Faizi said his death had left her emotionally and physically unable to manage daily life, and that their daughters were struggling. The wife of Soroush Mahmudi sat in the gallery while an assistant Crown attorney read her statement aloud: she had fainted on learning he had been murdered, had been unable to work since, and depended on social assistance and food banks. The daughter of Dean Lisowick told the court she had never had a relationship with her father and now had to explain to her own children how he died. A sister of Andrew Kinsman described him as an extraordinary, caring man and urged people to be kind. A brother said he now looked at strangers differently.
Some statements spoke for more than one family. One, filed on behalf of Toronto’s South Asian and Middle Eastern LGBTQ community, warned that if one killer had been among them there could be others. The executive director of the Alliance for South Asian AIDS Prevention told the court that men McArthur had bought drinks for or chatted with online now felt mortified and anxious.
McArthur said nothing when given the chance to address the court.
On February 8, 2019, McMahon imposed life on each count, concurrent, with no parole eligibility for 25 years. He called the murders "pure evil." He also declined the Crown’s request. A longer term, he said, would be largely symbolic, and there was "a fine line between retribution and vengeance." He gave weight to the guilty plea, which had spared the families a long trial, and to McArthur’s age. McArthur would be 91 before he could apply for parole, CBC News reported, and the judge said release was very unlikely. He acknowledged what the statements had described, saying the crimes had left Toronto’s LGBTQ community afraid and distrustful, and he called that community strong and resilient.
The families had told him what had been taken. They had not moved him to the longer term. "It’s not enough for the families, it’s not enough for the lives lost," a friend of three of the men said outside court.
Five years later, a judge in Manitoba heard the same kind of grief with even less room to answer it. In 2022 the Supreme Court of Canada struck down the law that had let parole ineligibility periods be stacked for multiple murders. When Chief Justice Glenn Joyal of the Court of King’s Bench came to sentence Jeremy Skibicki for the first-degree murders of Morgan Harris, Marcedes Myran, Rebecca Contois and a fourth woman then known only as Buffalo Woman, the four 25-year periods had to run together. Crown prosecutors said Skibicki could apply for parole at 60.
The hearing on August 28, 2024, heard 14 victim impact statements, CTV News reported. Morgan Harris’s youngest daughter spoke of trauma, anxiety and depression, and of facing them without her mother. Rebecca Contois’s oldest sister said no words could capture her pain or rage. A statement from another sister, read by their brother, said the women’s lives mattered and that they were not garbage. Marcedes Myran’s grandmother said the sentence was not enough and that she would never speak his name; Myran’s sister said a life sentence would never be enough. Grand Chief Cathy Merrick of the Assembly of Manitoba Chiefs said the killings had left a deep scar on First Nations people. Sandra DeLaronde of the advocacy group Giganawenimaanaanig read a community impact statement about Indigenous women’s fears for their safety and their distrust of authorities, police among them.
Crown prosecutor Chris Vanderhooft said sentencing hearings often treat victims as "but a footnote," and that this one would not. His argument was aimed past the courtroom. He asked any future parole board to look beyond Skibicki’s gentle manner and recognize the danger he posed.
Joyal imposed four concurrent life terms with no parole eligibility for 25 years. He said plainly that the law had tied his hands: "the only available sentence that I can impose today will regrettably not adequately reflect the gravity of these offences." He described the women as having been "preyed upon and targeted by a white supremacist." Then he did what a judge in his position could do. He said he hoped a future parole panel would weigh the evidence, his reasons and the families' statements with care.
That was the clearest admission in any of these cases that a statement might shape a sentence, and the judge placed it decades in the future. Asked whether he had anything to say, Skibicki said, "No." The next day Premier Wab Kinew said future parole hearings should take account of the harm done to the families.
One family had not been in the room. On March 26, 2025, the Winnipeg Police Service announced that the fourth victim was Ashlee Christine Shingoose, 30, of St. Theresa Point Anisininew Nation. Because she had not been identified at sentencing, her relatives had never been able to address the court.
At the Crown’s request, the Court of King’s Bench agreed to a special hearing, which it called "unique but necessary," so that her family would have the same opportunity as the others. Courts do not usually accept victim impact statements once sentence has been passed, and the court described the circumstances as exceptional. Marc Kruse, director of Indigenous legal learning and services at the University of Manitoba’s law school, said the hearing allowed "the record to be complete." Andrew Flavelle Martin, a law professor at Dalhousie University, questioned whether the court had the authority to hear the statements without a change to the Criminal Code.
Nothing said on August 15, 2025, could alter the sentence, and everyone in the courtroom knew it. Skibicki was not required to attend and did not. His lawyer said his absence was not meant as disrespect. Shingoose’s father told Joyal that the family had been "screaming into silence" while she remained unidentified, and said he wished he could have confronted the man who killed her. Her mother said the pain was overwhelming. The statements went into a record that, by the judge’s own reasoning a year earlier, a parole board would one day read.
Robert William Pickton was convicted on December 9, 2007, of six counts of second-degree murder, for the deaths of Sereena Abotsway, Mona Wilson, Andrea Joesbury, Brenda Ann Wolfe, Georgina Faith Papin and Marnie Frey. For second-degree murder the life sentence is automatic, but the judge sets the parole ineligibility period, up to 25 years. That gave Justice James Williams of the B.C. Supreme Court a real decision.
Pickton did not address the court. Crown counsel Mike Petrie read from the victim impact statements himself; CTV reported 15 of them and the CBC 18. Sereena Abotsway’s foster brother wrote that his sister "consumes my thoughts every day of my life." Andrea Joesbury’s mother wrote that she had lived a hellish life since her daughter’s death and felt "trapped." Petrie struggled at moments to go on.
On December 11, 2007, Williams set parole ineligibility at the maximum of 25 years. Most second-degree murder cases do not exceed 20, he said, but this one was unique. "Mr. Pickton’s conduct was murderous and repeatedly so," he said. "What happened to them was senseless and despicable." How much of that reasoning rested on the statements, and how much on the facts the jury had accepted, has not been reported. Georgina Papin’s sister cried out when the sentence was read and said afterward that justice had finally been served. "It’s a good day for us," said Marnie Frey’s father. Wally Oppal, who would later lead the province’s inquiry into the missing women, said it would be difficult to conclude that Pickton would "ever see the light of day again."
He did not. Pickton died in hospital on May 31, 2024, after an assault by another inmate at Port-Cartier Institution in Quebec. When that inmate, Martin Charest, pleaded guilty to first-degree murder on September 25, 2025, the prosecutor told the court that no victim impact statements would be made on Pickton’s behalf. A brother had not wanted to speak.
In Louisiana, the families of Ronald Dominique’s victims did something no statement in a courtroom could do. They chose the sentence.
Dominique faced a capital prosecution in Terrebonne Parish. Assistant District Attorney Mark Rhodes, the lead prosecutor, said he told the families he was confident of a guilty verdict on all eight counts, but that a death penalty case could be tied up in appeals for 12 to 15 years or more. District Attorney Joseph Waitz said appeals typically took at least 12 years and would take longer with so many killings. The families wanted the case finished so they could begin to heal, Rhodes said. They asked for life sentences, and the state agreed.
On September 23, 2008, at the courthouse in Houma, Dominique pleaded guilty to eight counts of first degree murder, for the deaths of Michael Barnett, Kurt Cunningham, Chris Deville, Alonzo Hogan, Leon Lirette, Nicholas Pellegrin, Wayne Smith and August Watkins. He gave up his right to a jury trial and to an appeal. The state did not pursue death. Asked whether he wanted to make a statement, he said no.
Almost 30 relatives were in the courtroom, and seven gave victim impact statements. Because the outcome was settled, the statements could not move the sentence in either direction. They were addressed as much to Dominique as to Judge Randall Bethancourt. Kurt Cunningham’s brother said he would miss him for the rest of his life, then turned to the defendant: "I hope hell finds you fast." Alonzo Hogan’s sister said her brother did not deserve to die, "not like this," and then told the court that she forgave Dominique and that his punishment was not hers to decide. A letter from Wayne Smith’s mother was read aloud; she wrote that she never got to say goodbye. Nicholas Pellegrin’s sister said the family never got to tell him they loved him.
Bethancourt imposed eight consecutive life terms and read the eight names as he did. In the documentary Bayou Blue, Rhodes later said that death would have been less traumatic for Dominique, who was afraid of prison. In December 2008, in Thibodaux, Dominique pleaded guilty to the second degree murder of Christopher Sutterfield, which carries life in Louisiana. Sutterfield’s family was in court and chose not to give a statement at all.
Years afterward the families were not of one mind about what they had chosen. Chris Deville’s father told The Houma Times in 2010 that people who do wrong should pay for it. Wayne Smith’s grandmother said she supported a sentence under which Dominique would suffer.
In the United States the question of how far a statement may go reached the Supreme Court in Payne v. Tennessee, which allowed juries and judges in capital cases to hear about the victim and the effect of the death on the family. It did not open the door to everything, and the Supreme Court of Ohio drew the line in the case of John Fautenberry.
Fautenberry, a former long-haul truck driver, confessed to killing five people in four states between November 1990 and March 1991. In Ohio he was tried for the aggravated murder of Joseph Daron Jr., 46, a father of two young children who had offered him a ride. He waived a jury, and on July 23, 1992, a three-judge panel accepted his no contest pleas and convicted him on all five counts.
At the sentencing hearing Fautenberry gave an unsworn statement, expressed sorrow for what he had become, and asked for a life sentence so that he could work with abused children. The panel also received victim impact statements from Daron’s family, from Daron’s employer and from the arresting officer. Each of them asked that Fautenberry receive the maximum sentence. On September 14, 1992, the panel unanimously sentenced him to death.
On July 5, 1995, the Supreme Court of Ohio took up the statements as its main finding of error. Evidence about the victim and his family’s loss was permitted under Payne, Justice Resnick wrote for the court. The recommendations about what sentence to impose went beyond what Payne allowed. Admitting them was error. It was not reversible error, the court held, because nothing showed that the panel had relied on them. A footnote observed that an Ohio law that took effect in October 1994 gave a victim the right to make a sentencing recommendation, but did not extend that right to family and friends.
The court then weighed the case for itself, held that the aggravating circumstances outweighed the mitigating factors beyond a reasonable doubt, and affirmed. The statements that asked for death were improper, and the death sentence stood anyway. Fautenberry was executed at Lucasville on July 14, 2009. He was 45.
A similar question came before the Supreme Court of California in the case of Gerald Parker, a former Marine convicted in 1998 of six counts of first degree murder for killings in Orange County in 1978 and 1979. The victims were Sandra Fry, 17; Kimberly Rawlins, 21; Marolyn Carleton, 31; Debora Kennedy, 24; Debra Senior, 17; and Chantal, the full-term unborn daughter of a woman who survived. At the penalty phase relatives of each of the five women and girls described their losses. Parker testified that he was sorry and accepted responsibility for the families' pain. The jury returned a verdict of death, and on January 21, 1999, Superior Court Judge Frank Briseno sentenced him to death.
The automatic appeal took 18 years. On June 5, 2017, the state Supreme Court held that the victim impact testimony had been properly admitted, with one exception: a remark that Debra Senior’s father had died of a broken heart. The court held that remark improper and the error harmless. It affirmed the judgment in its entirety, and the U.S. Supreme Court denied review on February 20, 2018. In the court’s reckoning a single sentence about a grieving father had crossed the line, and the death verdict did not depend on it.
In Sean Vincent Gillis’s case the statements went to a jury that had the power to choose between life and death, and the jury could not agree.
Gillis had already pleaded guilty on August 20, 2007, to the second degree murder of Joyce Williams in West Baton Rouge Parish, the day before jury selection was to begin. That plea carried a mandatory life term. Joyce Williams’s sister spoke with him face to face and said she was thankful he had changed his plea, because she now had to raise her sister’s nine-year-old daughter alone and the girl would be spared a long trial.
In July 2008 an East Baton Rouge Parish jury convicted him of the first degree murder of Donna Bennett Johnston, 43, after deliberating for less than three and a half hours. Prosecutors asked for death. Relatives gave victim impact statements. Johnston’s son told the jury that four years later the family still had not been able to get a proper headstone for her, and that he had tried not to look at Gillis because he was there "for my mother." The daughter of Johnnie Mae Williams, another woman Gillis had confessed to killing, testified that she had looked at him and asked him why. He shrugged and apologized, she said. "I don’t feel that he’s sorry," she told the jury. "He’s just sorry he’s here."
The defense called his mother, who described raising him alone. Defense lawyer Kerry Cuccia said the aim was to give the jury "a true picture of the person" rather than a "small snap shot" of his crimes. Just before 6 p.m. on the Thursday after the verdict the jurors told the judge they were "hopelessly deadlocked," and Gillis received life. Jurors later told WAFB that four of them had voted against death on the first ballot: two who said they would never vote for death and two who were wavering.
"What finally happened in the penalty phase of this case is the jury was introduced to Sean Gillis," Cuccia said. The sister of one of the women saw it differently. Gillis "has taken too many lives to just walk free," she said, and life in prison still felt like freedom to the families, because he could visit his relatives, talk and laugh while theirs were gone.
Elizabeth Wettlaufer pleaded guilty on June 1, 2017, before Justice Bruce Thomas in Woodstock, Ontario, to eight counts of first-degree murder, four of attempted murder and two of aggravated assault. The victims had been in her care as a nurse in long-term care facilities and, in one case, in a private residence in Ingersoll. When the judge asked whether she had meant to kill each victim, she answered, "Yes, your honour."
The Crown and the defence had agreed on a joint submission, and the murder sentences were fixed by law in any event. The hearing on June 26, 2017, was therefore less about what punishment she would receive than about what the families needed to say. Many spoke of grief and anger. Many also spoke of guilt, for having placed a parent in a care facility or for having missed the signs. A close friend of Maurice Granat, 84, said he had been a father figure to her, and that after learning how he died she became so depressed that she lost her job. The daughter of Gladys Millard, 87, said it broke her heart to learn what had been done to her mother. In the Silcox family, relatives said the case had turned siblings against one another.
The one living victim among the 14 people in the case told the court that she was still afraid to sleep at night, and that she had worried Wettlaufer would get out and finish what she had started.
Wettlaufer apologized briefly. She said "sorry" was far too small a word. Justice Thomas accepted the joint submission: life with no parole eligibility for 25 years on each murder count, ten years on each attempted murder count and seven years on each aggravated assault count, all concurrent. He rejected the phrase "angel of mercy" and described her instead as a figure of death who had passed over her victims. The statements did not change a day of the sentence. What they drew from the judge was something else. He told the families they could not blame themselves.
Russell Williams, who had commanded Canadian Forces Base Trenton, pleaded guilty on October 18, 2010, before Justice Robert F. Scott of the Ontario Superior Court in Belleville to all 88 counts against him, among them the first-degree murders of Cpl. Marie-France Comeau, 38, and Jessica Lloyd, 27. The life sentence and the 25-year parole bar were automatic.
Relatives and friends of Jessica Lloyd read their statements with Williams in the courtroom. "Because of him I can never hold my daughter Jessica in my arms again, hug her and tell her that I love her," her mother said. One aunt spoke of the future the family had imagined: "We all planned on seeing Jessica get married and have beautiful babies." Another said only, "We all miss Jess terribly." Throughout the hearing her mother sat holding a framed photograph of her daughter.
Williams spoke before sentence was passed. He said he was "indescribably ashamed," apologized to the families of the two women he had killed, and said, "I shall spend the rest of my life knowing that I ended two vibrant, innocent and cherished lives." Letters of apology to some of the families were read in court.
The Crown attorney, Lee Burgess, called him "simply one of the worst offenders in Canadian history." He did not seek a dangerous offender designation, calling it superfluous. The full record of the case would be before any parole board, Burgess said, and in his view that board "will keep him behind bars forever." Defence lawyer Michael Edelson raised no objection to the proposed sentence and pointed to the guilty pleas, which had spared the families a long trial.
On October 21, 2010, Scott imposed two concurrent life terms with no parole eligibility for 25 years, with concurrent terms on the remaining counts. He said he believed the apology was sincere and stressed that parole eligibility after 25 years was no guarantee of release. "The depths of depravity demonstrated by Russell Williams have no equal," he said. He also ordered that some seized material be kept for any future parole board. Here, as in Winnipeg, the court looked ahead to a hearing that had not yet been scheduled and to the people who would read the file. Outside the courthouse Jessica Lloyd’s brother said the sentence gave the family closure. "As long as he dies in jail, I’m happy," he said. "We just want to be normal again."
No sentencing in these cases gave the victims more room than the one for Joseph James DeAngelo, and in none was the sentence more firmly settled before they spoke.
The prosecution was enormous. Prosecutors said the discovery ran to more than 1.3 million pages and that a trial could take up to ten years. California had a moratorium on executions, the pandemic had disrupted the courts, and the defendant, the survivors and many witnesses were old. After consulting victims and families, the district attorneys of six counties accepted a plea. On June 29, 2020, in a ballroom at California State University, Sacramento, DeAngelo pleaded guilty before Superior Court Judge Michael Bowman to 13 counts of first-degree murder and 13 counts of kidnapping to commit robbery, and admitted scores of uncharged crimes. The death penalty was off the table. He would serve life without parole.
The victims' hearings ran for three days in the same ballroom in the week of August 17, 2020. Survivors, their husbands and children, and relatives of the murdered spoke with no limit on time or content. DeAngelo sat masked, without visible response; the Santa Barbara Independent reported that over the first two days he stared at the wall in front of him. Some survivors asked the judge to send him to the toughest prison in the state. The husband of one survivor said he wanted DeAngelo to suffer for the rest of his life.
The relatives of the murdered spoke on August 20. The daughter of Claude Snelling, who was killed in Visalia in 1975, called her father her hero. "I am so thankful that he will at least spend the rest of his miserable life in prison," she said. The daughter of Lyman Smith took the opposite view of the same outcome. "Joe spending the rest of his life in prison is not justice," she said, and she described his "legacy of sadism, cruelty, moral and physical depravity." She told the court, United Press International reported, that she had been treated as a suspect for two days after the killings and had lived with the shame for decades. Cheri Domingo’s daughter, who was 15 when her mother was killed, said, "Today the devil loses and justice wins." Keith Harrington’s brother told the court that DNA databases might have stopped the killer before he moved on to murder. Janelle Cruz’s sister said, "I hope he rots."
On August 21, 2020, before sentence was passed, DeAngelo rose from his wheelchair and took off his mask. "I’ve listened to all your statements, each one of them, and I’m truly sorry to everyone I’ve hurt," he said, according to ABC News. Bowman then imposed the agreed sentence: 11 consecutive terms of life without parole for the murders, a further consecutive life term for the kidnappings and eight years for weapon enhancements. Orange County District Attorney Todd Spitzer said he believed DeAngelo had deserved death. Sacramento County District Attorney Anne Marie Schubert told the survivors, "The greatest revenge is to live your lives."
Read together, these hearings mark out how little a victim impact statement can do to a sentence once the law has fixed it, and how much it can do around the edges. In Canada, where first-degree murder carries an automatic life term, the statements in the McArthur, Skibicki, Wettlaufer and Williams cases could at most bear on parole. McMahon heard them and declined to stack the periods. Joyal could not have stacked them if he wished and said so. In both cases, and in Belleville, the judge’s words pointed toward a parole board that would one day open the file, and in Winnipeg the court reopened its own doors to make sure one family’s words would be in it.
In the American capital cases the statements carried real legal risk, and the appellate courts treated them with caution. Ohio’s highest court held that the requests for death made to Fautenberry’s sentencing panel should never have been admitted, and affirmed anyway. California’s held one sentence about a grieving father improper, and affirmed anyway. In Baton Rouge the statements went to twelve jurors who could not agree, and life followed.
The families who came nearest to deciding a sentence did so before they spoke at all. In Houma the relatives of Ronald Dominique’s victims asked for life so that the case would end, and the state gave it to them. In Sacramento the six district attorneys consulted survivors and families before accepting the plea. By the time those families stood up in court, the punishment was settled, and what they said was addressed to the man in front of them, to the judge, and to one another. Hogan’s sister told a Louisiana court that the punishment was not hers to decide. In a sense, she described every hearing on this list.
• July 23, 1992: John Fautenberry convicted on no contest pleas in Hamilton County, Ohio.
• September 14, 1992: A three-judge panel sentences Fautenberry to death after receiving victim impact statements that asked for the maximum sentence.
• July 5, 1995: The Supreme Court of Ohio holds the sentencing recommendations improper under Payne v. Tennessee but not reversible, and affirms.
• January 21, 1999: Gerald Parker sentenced to death in Orange County, California.
• August 20, 2007: Sean Vincent Gillis pleads guilty to second degree murder in West Baton Rouge Parish and receives a mandatory life term.
• December 9, 2007: Robert William Pickton convicted of six counts of second-degree murder in New Westminster, British Columbia.
• December 11, 2007: Pickton sentenced to life with parole ineligibility set at the 25-year maximum after victim impact statements were read by the Crown.
• July 2008: Gillis convicted of first degree murder in East Baton Rouge Parish; the jury deadlocks on death and he receives life.
• September 23, 2008: Ronald Dominique pleads guilty in Houma to eight counts of first degree murder; eight consecutive life terms, the death penalty dropped at the families' request.
• December 2008: Dominique pleads guilty in Thibodaux to second degree murder; the victim’s family declines to give a statement.
• July 14, 2009: Fautenberry executed at Lucasville, Ohio.
• October 21, 2010: Russell Williams sentenced in Belleville, Ontario, to two concurrent life terms.
• June 5, 2017: The Supreme Court of California affirms Parker’s death sentence, holding one victim impact remark improper but harmless.
• June 26, 2017: Elizabeth Wettlaufer sentenced in Woodstock, Ontario, on a joint submission.
• February 8, 2019: Bruce McArthur sentenced in Toronto to life with no parole eligibility for 25 years; the judge declines the Crown’s request for 50.
• August 21, 2020: Joseph James DeAngelo sentenced in Sacramento after three days of victims' hearings.
• May 31, 2024: Pickton dies in hospital in Quebec.
• August 28, 2024: Jeremy Skibicki sentenced in Winnipeg to four concurrent life terms after 14 victim impact statements.
• March 26, 2025: Winnipeg police identify the fourth victim as Ashlee Christine Shingoose.
• August 15, 2025: Special post-sentence hearing for the Shingoose family before Chief Justice Joyal.
• September 25, 2025: The inmate who killed Pickton pleads guilty to first-degree murder; no statements are made on Pickton’s behalf.