R. v. Geddes, 2014 ONCA 838:
 In R. v. Summers,  S.C.J. No. 26, the Court held that the loss of early release alone will generally be a sufficient basis on which to award enhanced credit of 1.5:1. As a result, the Crown now concedes that the appellant's entire period of pre-sentence custody amounting to 537 days should be credited at the rate of 1.5:1 and that the appellant should receive 806 days credit for pre-sentence custody as requested.