R v Gargas, 2013 ABCA 245 involved in a scheme to smuggle drugs into the Edmonton Remand Centre. An envelope containing 1 gram of morphine, 3 grams of alprazolam, and 4.4 grams of methamphetamine was intercepted. The drugs were secreted in documents purporting to be from a lawyer to an inmate. The Court holds:
 The sentencing judge was correct to treat the smuggling of drugs into a correctional institution as being aggravating. As commented in S. Armstrong, A. Sabbadini, A. Boni, S. Coroza, Sentencing Drug Offenders, 2012 Thomas Reuters Canada Limited, smuggling and distribution of controlled substances into a correctional facility is a particularly serious form of drug trafficking. It compromises the integrity of the facility, the safety of inmates and guards is endangered, and the principle of rehabilitation is undermined. Here the conduct was planned and cunning, and involved an attempted abuse of solicitor and client privilege.