Images in Judgments

Law books tend to lack pictures. As do legal memos, factums . . . and judgments. Though a picture is said to sub for a thousand words, it’s not traditional for legal workers to speed things along that way. And neither is it easy, or possible, perhaps, to come up with images that capture the sort of conceptual thinking that law involves. Yet every now and then the image tells the tale, or, at least, an important part of the story, finding its way into judgments.

Some time ago we featured one such judgment, that by U.S. Justice Posner, whose aim was censure and mockery. I recently learned of another opinion using an image, this time simply to make certain facts and terms clear.

In Moreira et al v. Ontario Lottery and Gaming Corp. et al 2012 ONSC 2304 three gamblers sued an Ontario casino because of what they saw as a problem with the way the roulette wheel was operated. Justice Belobaba found it useful to include an annotated photograph of such a wheel as an appendix to the judgment, which, if nothing else, adds a bit of, well, colour to the matter.

Click on image to enlarge

(Not that it wasn’t colourful enough without that: the three plaintiffs had spent more than two million dollars playing roulette “betting an average of $1000 per spin.” This in a game about which the “Wizard of Odds” says:

If you are looking for a easy to understand and slow paced table game, and are willing to sacrifice on the house edge [5.26%], then you may like roulette. If you want something more stimulating or with a decent return I would suggest looking at other games.)

The house won again, as it happens.


  1. I just encountered a related issue last week. Reed v Town of Lincoln (1974) 6 OR (2d) 291 has a map attached to the print decision, but the map isn’t included in any electronic version.

  2. An early judge in the Northwest Territories commissioned a series of carvings based on cases that he adjudicated, mostly murders and a couple of what we today would call ‘assisted suicide’ cases. They are still on display from time to time. You can see them at this link:

  3. There is of course Chief Justice Sonny Nemetz’s famous judgment in the infamous fly cartoon case, Vander Zalm v. Times Publishers. This is one instance where the Canlii decision lacks the cartoon itself, which I recall was included in the conventional sources, (1980) 109 DLR (3d) 531 and [1980] 4 WWR 259. For those who may have got rid of their print law reports here is what the cartoon looked like:

    vander zalm

  4. A former Oz Federal Court Chief Justice has evoked images of “cold porridge” when calling for
    judges to write summaries of their judgments in a journalistic style. Maybe there is the opportunity for journalists, publishers, bloggers and law firm marketing departments to jazz up the more notable judgments including providing the missing images.

  5. Lyonette Louis-Jacques

    Love this topic! :-) Here’s another one (hat tip to the CanLII folks who gave me the heads-up on this wonderful use of images in judgments):

    Robinson c. Films Cinar inc., 2009 QCCS 3793 (CanLII)
    (the images start before paragraph 506/footnote 336; I can see the similarities in the images used for Les Aventures de Robinson Curiosité and Robinson Sucroë, but love how they are different)

  6. A couple of years ago, I posted a couple of examples of illustrated judgments on Slaw. Last year, I prepared a short paper on the topic. For those interested, the paper can be found at The paper gives some information about the growth of the phenomenon in Canada in the recent years.


  7. Daniel, I’m sorry I had forgotten that you did indeed do a column on this: