Worst Offenders File

Dennis Galiatsatos

Posted by on July 09, 2026

Judicial Profile: Court of Québec judge whose most controversial rulings include a Bill 96 / language-rights decision later overturned by the Quebec Court of Appeal, a firearms-sentencing decision successfully appealed after he rejected a joint sentence recommendation, and a widely publicized free-expression ruling declaring that giving the middle finger is protected expression.

Note: This profile concerns public controversy over judicial decisions and their consequences. It does not allege judicial misconduct. Criticism is attributed to public officials, legal commentators, civil-liberties organizations, professional regulators, polling, media reports, or affected parties where available.

Overview

Name The Honourable Dennis Galiatsatos

The 2018 Quebec appointment notice identifies him as Dionisios Galiatsatos.
Court Court of Québec, Montréal

Appointed primarily to the Criminal and Penal Division in Montréal.
Law School McGill University, BCL/LLB, 2004
Date First Appointed August 15, 2018 — appointed judge of the Court of Québec.
Date Appointed to Current Role August 15, 2018 — appointed to his current role as a judge of the Court of Québec.
Appointed By Premier: Philippe Couillard, Quebec Liberal government.

Quebec Minister of Justice and Attorney General: Stéphanie Vallée, who announced the appointment on August 15, 2018.

Prime Minister / federal Minister of Justice: Not applicable. The Court of Québec is a provincially appointed court, so this appointment was made by the Government of Quebec, not by the federal government.

Appointment context: The appointment was made shortly before the 2018 Quebec provincial election was called and was part of a group of judicial appointments announced by Quebec’s justice minister.
Previous Legal Career Before his judicial appointment, Dennis Galiatsatos was a prosecutor with the Directeur des poursuites criminelles et pénales. The Quebec appointment notice says he began his career at the City of Montreal’s criminal and penal prosecutions division and, since 2009, had acted as a prosecutor with the DPCP. A McGill alumni profile described him before his judicial appointment as a Crown prosecutor on a special-cases trial team and alternate for an appeals team in Montréal, with experience in criminal prosecutions and appeal files before the Quebec Court of Appeal, Superior Court, and Supreme Court of Canada.

Summary of Controversy

Justice Galiatsatos has attracted controversy for both the substance and style of several decisions. His most significant legal controversy is R. c. Pryde, where he raised on his own initiative the constitutionality and applicability of a Bill 96 amendment requiring French translations of certain English-language judgments to be attached “immediately and without delay.” He declared the requirement inoperative in criminal proceedings. The Quebec Court of Appeal later overturned the decision, holding that he had exceeded the limits of his jurisdiction and that the procedure followed was flawed.

A second controversy is R. c. Baptiste, a firearms sentencing case in which Justice Galiatsatos rejected a joint 16-month sentence recommendation and imposed 32 months. The Quebec Court of Appeal intervened, finding that the parties should have been given notice of his concerns before he departed from the joint submission, and that he erred in applying the sentencing range.

His best-known public ruling is R. c. Epstein, where he acquitted a Montreal-area man charged after a neighbourhood dispute and wrote that giving someone the middle finger is protected expression. The decision was widely reported internationally. Supporters saw it as a colourful defence of free expression and a rejection of over-criminalizing petty neighbourhood disputes. Critics saw the style and length of the reasons as needlessly theatrical and argued that the case became a media spectacle.

Most Controversial Rulings

R. c. Pryde, 2024 QCCQ 1794

Subheadline: A Bill 96 language-law ruling that was overturned after the Quebec Court of Appeal found the judge went beyond the limits of his jurisdiction.

Case Summary: The case involved an accused who elected to have her criminal trial in English. Shortly before trial, amendments to section 10 of Quebec’s Charter of the French Language were set to come into force, requiring a French version to be attached “immediately and without delay” to certain English-language written judgments. Justice Galiatsatos raised the issue himself, required submissions from the Attorneys General of Quebec and Canada, and ruled that the immediate-translation requirement was inoperative in criminal proceedings because it conflicted with federal criminal procedure and language rights under the Criminal Code.

What the Court Decided: Justice Galiatsatos concluded that the Quebec provision would delay the delivery of English-language criminal judgments because translation and quality-control work could take weeks or months. He found that this created an asymmetry between English-speaking and French-speaking accused persons and frustrated the purpose of the Criminal Code language-rights provisions. He declared the requirement to attach a French translation “immediately and without delay” inoperative in criminal proceedings.

Consequences for Victims or Society: This was not a crime-victim sentencing case. Its consequences concerned language rights, accused persons’ access to criminal verdicts, Quebec’s French-language policy, the authority of provincial-court judges, and the limits of judicial initiative. The ruling affected the public debate over Bill 96 and raised the question of whether Quebec can require immediate French translations of English-language judgments without delaying criminal verdicts for English-speaking accused persons.

Why the Ruling Was Controversial: Critics argued that the judge created and resolved a constitutional controversy that the accused herself had not asked him to decide. The Quebec Court of Appeal later held that initiating, conducting, and resolving the debate unilaterally and in anticipation went far beyond the limits of his jurisdiction. The Court of Appeal also criticized the procedure as relying on hypotheticals and lacking the benefit of a proper factual and procedural record. French-language-rights advocates described the ruling as judicial activism against Quebec’s language charter, while supporters argued that the decision protected English-speaking accused persons from delayed verdicts.

Public Reaction: The ruling triggered political and legal reaction in Quebec. Quebec Justice Minister Simon Jolin-Barrette suggested the government would appeal, and later reaction from Quebec officials welcomed the Court of Appeal’s reversal. Droits collectifs Québec, a French-language-rights group, welcomed the appeal result and characterized the original ruling as an activist refusal to respect the French language charter. Legal commentary from major law firms described the case as unusual because the constitutional issue was raised by the judge himself rather than by the accused.

Counterpoint / Supportive View: Supporters of the original ruling argued that the justice system should not impose practical delays on accused persons who choose to be tried in English. On this view, a verdict that is ready in English should not be delayed by a mandatory translation process, especially in criminal matters where delay can affect accused persons, victims, witnesses, and the public.

Appeal History: The Quebec Court of Appeal overturned the ruling. In reasons released August 8, 2025, the Court of Appeal held that Justice Galiatsatos could not raise and resolve the constitutional question as he did and that the procedure followed was flawed. The appeal was allowed.

R. c. Baptiste, 2020 QCCQ 1813

Subheadline: A firearms sentencing decision where the judge doubled a joint sentence recommendation before the Quebec Court of Appeal intervened.

Case Summary: Nicolas Baptiste was convicted of seven offences connected to unauthorized possession of several firearms. At sentencing, the parties jointly proposed a 16-month sentence. Justice Galiatsatos rejected the proposed sentence and imposed a total sentence of 32 months.

What the Court Decided: Justice Galiatsatos imposed a sentence twice as long as the joint submission. The decision addressed firearms offences, sentencing ranges, joint submissions, and the seriousness of unauthorized gun possession. He also rejected proposed COVID-related reductions in sentence based on pandemic jail conditions.

Consequences for Victims or Society: This case did not involve a named individual shooting victim in the reviewed summaries, but it involved firearms offences, which courts treat as serious public-safety crimes. The societal consequences concerned gun sentencing, confidence in joint submissions, the duty of judges to alert parties before departing from a joint recommendation, and the fairness of sentencing procedures.

Why the Ruling Was Controversial: The ruling was controversial because both parties had jointly proposed 16 months, yet Justice Galiatsatos imposed 32 months. On appeal, the parties argued that he had failed to disclose his concerns about the joint recommendation before rejecting it. They also argued that he misinterpreted the nature of the offences and wrongly applied the relevant sentencing range. The Quebec Court of Appeal agreed that appellate intervention was required.

Public Reaction: The case received legal commentary because it dealt with when judges may reject joint submissions and how they must notify counsel of concerns before doing so. It has also been discussed in scholarship on whether courts should consider harsh prison conditions, including COVID-era incarceration conditions, when imposing sentence.

Counterpoint / Supportive View: Supporters of a tougher sentence could argue that unauthorized firearm offences carry serious public-safety risks and that judges should not simply rubber-stamp sentencing deals if they believe the proposed sentence would not adequately denounce gun crime. The appellate criticism, however, focused on procedure and sentencing principles: when a judge has serious concerns about a joint submission, the parties must be told and given a chance to respond.

Appeal History: The Quebec Court of Appeal allowed the appeal in Baptiste c. R., 2021 QCCA 1064. The Court of Appeal held that Justice Galiatsatos should have advised the parties of his concerns before rejecting the joint recommendation and found errors in his sentencing analysis.

R. c. Epstein, 2023 QCCQ 630

Subheadline: The internationally reported “middle finger” ruling that turned a neighbourhood dispute into a free-expression headline.

Case Summary: R. c. Epstein involved a dispute between neighbours in suburban Montréal. The accused, a school teacher and father, was charged with criminal harassment and uttering threats after conflict with neighbours. The case included allegations about staring, walking near the neighbour’s home, disputes over children playing outside, and the accused giving the middle finger.

What the Court Decided: Justice Galiatsatos acquitted the accused. He held that there was no evidence the accused watched, followed, monitored, or repeatedly communicated with the complainants in a way that met the criminal-harassment standard. He also wrote that giving someone the middle finger is protected expression and does not, by itself, create criminal liability.

Consequences for Victims or Society: This case did not involve a finding of criminal victimization; the accused was acquitted. The broader societal consequences concerned the boundary between rude speech and crime, the use of police and courts in neighbourhood disputes, and the role of judges in writing colourful decisions that attract media attention. The decision was cited in public discussion as a reminder that offensive gestures and insults are not automatically criminal.

Why the Ruling Was Controversial: Supporters praised the ruling as a common-sense rejection of criminalizing trivial neighbour disputes and as a defence of freedom of expression. Critics argued that the reasons were unusually colourful, theatrical, and media-friendly for a criminal judgment. Some critics also argued that the case’s public fame came less from a difficult legal issue than from the judge’s vivid phrasing.

Public Reaction: The decision was covered by Canadian Lawyer, Global News, NPR-affiliated outlets, The Guardian, and other media. The most widely reported line was that giving someone the finger is “God-given” and Charter-protected expression. Legal-news coverage described the case as a dispute between neighbours that ultimately came down to credibility and whether unpleasant conduct crossed the line into criminal harassment or threats.

Counterpoint / Supportive View: The strongest defence of the ruling is that criminal law should not be used to punish rude gestures, insults, or ordinary neighbourhood hostility unless the Crown proves the elements of a criminal offence beyond a reasonable doubt. On this view, the decision protected free expression and prevented a petty dispute from producing an unjust criminal conviction.

Appeal History: No appellate reversal of R. c. Epstein was located in the reviewed sources. The ruling remains best known for its public and media reaction rather than for a later appellate rebuke.

Sources