Forsaken Twice

What Robert Pickton, Christopher Dunlop, and a law called PCEPA have in common.

Jun 18, 2026

A judge in Calgary said something this past summer that I haven’t been able to stop thinking about.

Christopher Dunlop killed Judy Maerz in 2023. Stabbed her 79 times, set her on fire, left her in a park. It was the second time he’d done this - he’d already served 13 years for manslaughter after strangling Laura Furlan in 2009, in the same park. Both women did street-level sex work in Calgary.

Justice Colin Feasby, sentencing Dunlop in July 2025, said the quiet part out loud: that Dunlop’s choice of victim “may have been more about his belief that his chances of getting caught were lessened” than anything else. That he may have been betting police wouldn’t look too hard for a sex worker.

“Mr. Dunlop’s possible calculation that there would not be a robust investigation of the death of a street sex worker in the present case was proved wrong” the judge said.

I want to sit with that sentence, because it’s doing two things at once. It’s a credit to Calgary police, who clearly did investigate Maerz’s death seriously. And it’s an admission - from the bench - that a man calculated his victim’s worthlessness in the eyes of the system, and that this calculation was a reasonable enough bet that a judge felt the need to specifically say it didn’t pay off this time.

That’s the sentence that should make all of us uncomfortable. Not because it was wrong. Because it implies he had reason to think it might be right.

This is not a new story. It’s the same story, again.

If you know one name connected to violence against sex workers in Canada, it’s probably Robert Pickton. Convicted in 2007 of six murders, with the DNA or remains of 33 women found on his pig farm in Port Coquitlam. Most of his victims were marginalized, many were Indigenous, many did street-level sex work in Vancouver’s Downtown Eastside. He told an undercover officer he’d killed 49.

British Columbia eventually held an inquiry into how this happened - how dozens of women could go missing over more than a decade before anyone treated it as the emergency it was. Commissioner Wally Oppal’s report landed in 2012, and its conclusion is one of the bluntest things I’ve ever read in an official government document: these women were “forsaken twice - once by society at large and again by the police.”

Oppal found a fragmented, finger-pointing relationship between the Vancouver Police and the RCMP, poor follow-up on missing person reports, and what he called (more gently than I would) “faulty stereotyping of street-involved women.” His central recommendation - a single, unified regional police force for Greater Vancouver to end the jurisdictional chaos - was never implemented.

It’s not just Pickton. John Martin Crawford murdered Indigenous women in Saskatoon through the 1980s and 90s with barely a ripple of urgency. Cody Legebokoff killed four women in Prince George between 2009 and 2010 - caught essentially by a routine traffic stop, not because anyone was actively looking for the women he’d taken. At his sentencing, the judge condemned the fact that funding for the task force investigating violence along BC’s Highway of Tears had been slashed by 84 percent in the years leading up to his arrest.

Different decades. Different cities. Same underlying pattern: women whose deaths weren’t urgent enough, until it was too late to matter.

Here’s the part I think gets missed.

Most people assume sex work in Canada is illegal. It isn’t - not exactly. Since 2014, under a law called PCEPA (the Protection of Communities and Exploited Persons Act), selling sexual services is technically legal. The person doing the work is immune from prosecution for that specific act.

Buuuut almost everything around her isn’t.

Buying sex is illegal. Advertising is illegal. So is most third-party involvement - meaning a driver, a security person, someone managing bookings, can all be charged with receiving a “material benefit” from her work, even if they’re just helping her stay safe.

If you’re thinking, “well that sounds like a strange legal architecture”, you’re not wrong. It’s the kind of law that lets politicians say sex work is decriminalized while writing nearly everyone who could make that work safer right back into criminal exposure.

This isn’t an accident of bad drafting. It’s a deliberate model - sometimes called the Nordic model - built on the theory that criminalizing demand will reduce exploitation while protecting the people selling. Whether you find that theory persuasive in principle is a fair debate. What I want to talk about is what’s actually happened since 2014, because we now have over a decade of evidence, and it’s not looking too good.

The Supreme Court already told us what happens when sex workers can’t protect themselves.

In 2013, before PCEPA existed, the Supreme Court struck down Canada’s previous prostitution laws in a case called Bedford (you’ve probably heard of it…). The Court was unanimous, and it didn’t mince words. The old “bawdy-house” law - which banned working from a fixed indoor location - meant women couldn’t work somewhere safe. The Court wrote that a law preventing street-based sex workers from going somewhere like a safe house, “while a suspected serial killer prowls the streets, is a law that has lost sight of its purpose.” The living-on-the-avails law was so broad it caught legitimate drivers and bodyguards alongside actual exploiters. And the communicating law stopped women from screening clients for signs of violence or intoxication before getting into a car with them.

The Court’s reasoning was simple: these laws didn’t stop sex work. They just made it more dangerous. Take away a woman’s ability to scope out who she’s about to be alone with, take away her ability to work somewhere with eyes around, and you haven’t protected her. You’ve isolated her.

PCEPA was Parliament’s response to that ruling. Here’s my honest take, nearly twelve years later: it built almost the same trap but just with a different coat of paint.

A Vancouver-based research team that has tracked nearly 900 sex workers since 2010 found that after PCEPA came into force, access to health services dropped by 41% and access to sex-worker-led community services dropped by roughly 1/5, compared to before the law. A five-city Canadian study found that 31% of sex workers said they couldn't call 911 in a genuine safety emergency, for fear that calling police would expose them, a colleague, or someone helping them to criminal liability. And in a separate analysis of the same five cities, researchers found that being unable to screen a client - because communicating to do so is itself criminalized - was linked to a significantly higher rate of workplace violence.

I want to be precise about what that means in practice, because the abstraction can let people look away from it. It means a woman who is being followed, or who senses something is wrong with the person she’s about to meet, has to weigh that danger against the very real possibility that calling for help puts someone else - a driver, a friend doing check-ins, the person managing her bookings - at risk of prosecution. It means the safest move, legally, is often silence.

That is the exact dynamic the Supreme Court said was unconstitutional in Bedford. We just built a new version of it.

The legal fight over this isn’t finished.

A coalition called the Canadian Alliance for Sex Work Law Reform challenged PCEPA directly, arguing it recreates the Bedford harms. In 2023, the Ontario Superior Court dismissed that challenge. The Alliance appealed, and that appeal is still working its way through the courts.

In the meantime, the Supreme Court ruled this past summer on a related but narrower question - R v Kloubakov - and upheld the material-benefit and procuring offences. But it’s worth knowing the case the Court actually had in front of it involved a trafficking operation, not sex workers asking to be allowed to hire a driver for safety. Sex worker advocacy groups weren’t even granted standing to weigh in. The Court itself said the bigger question - whether the law as a whole violates the right to security of the person - is still open, and pointed specifically to the pending Alliance case as the right place to settle it.

So as of right now, in 2026, we don’t have a final answer. We have a law that multiple peer-reviewed studies say makes reporting violence and screening clients harder, sitting next to a constitutional question nobody has fully resolved.

There’s a version of this conversation already happening south of the border, and it’s instructive.

Rex Heuermann was sentenced this past June for murdering seven women near Long Island’s Gilgo Beach - most of them sex workers - over a span of nearly two decades. The case went cold for years. Melissa Broudo, a lawyer who has represented sex workers in New York since before the first of those murders, put the failure plainly when Heuermann finally pleaded guilty:

“There were sex workers who may have had information that could have led to an arrest much sooner, but they could not come forward without risking arrest themselves. Without immunity from prostitution charges, coming forward simply wasn’t a safe option, and as a result, critical information remained out of reach.”

Read that again with Christopher Dunlop in mind. With Laura Furlan in mind - killed in 2009, with Dunlop walking around Calgary for 13 years of incarceration and then release before he killed again. I don’t know whether anyone had information that could have stopped what happened to Judy Maerz. I don’t think anyone in Canada has actually asked that question publicly, which is itself worth noting. New York passed a law in late 2025 granting limited immunity specifically so that sex workers who witness or survive violence can come forward. Canada has nothing equivalent. We have the opposite - a law that keeps the people most likely to know something, see something, or survive something, structurally afraid to say anything at all.

I don’t think this is a complicated moral question, even though it gets treated like one.

Whatever you believe about sex work - whether you think it should be more restricted, more accepted, fully decriminalized, or something else entirely - I think most people can agree on this much: a woman should be able to call the police when she’s in danger without that call exposing her, or someone helping her, to prosecution. A woman should be able to ask a question before getting into a stranger’s car. A woman’s death should be investigated with exactly the same seriousness as anyone else’s, by default, not as a pleasant surprise to the man who killed her.

Pickton’s victims were forsaken twice. Once by a society that had already decided they didn’t matter much, and once by police forces too fragmented and too indifferent to find them in time.

Christopher Dunlop bet on a version of that same indifference fourteen years apart, in the same city, in the same park. This time, a Calgary courtroom said the bet didn’t pay off.

I’d like to live somewhere that doesn’t require betting on whether a system will fail you in order to know what protection is supposed to look like in the first place.

If you’re navigating any of this - whether you’ve experienced violence, witnessed something you’re unsure how to report, or you’re trying to understand what your options actually are within a system that wasn’t built with you in mind - you don’t have to figure it out by yourself, and you don’t have to have already decided what you want to do. That’s exactly the kind of conversation I’m here for, no judgment, no pressure, and no assumptions about what you “should” do next.

Sources and further reading:

Note: the connection I’m drawing between the Dunlop case specifically and Canada’s sex work laws is my own analysis - I’m not aware of any Canadian advocacy organization that has publicly made this exact link. I think it’s worth making.

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