No, not a "you've been speeding" type of citation. I mean the first time a court case has ever cited to or quoted my work. In R. v. Poncelet, 2008 BCSC 202, the British Columbia Supreme Court said:
"48 Academic commentary has also been critical of the Audet analysis. Assistant Professor Jeremy Patrick of the University of Detroit Mercy School of Law, in his article titled "Sexual Exploitation and the Criminal Code" (2006), 43 Alta. L. Rev. 1057, discussed the gap in the jurisprudence, which has defined the terms "a position of authority" and "relationship of dependency" but has been unable to achieve any satisfactory articulation of what constitutes "a position of trust".
49 In particular, Professor Patrick criticizes the three factors identified in Audet. He states the age difference between the parties is not particularly relevant to whether or not a relationship of trust actually existed, "unless we are to presume that young persons are more likely to trust older people than people nearer their own age", and this factor "raises the spectre that mere moral disapprobation of sexual relationships between persons of very different ages ... could lead to a conviction" (at ¶18). He questions the meaning of the evolution of the relationship factor, which he describes as so vague that it simply introduces confusion rather than clarity to the analysis. For example, he states, if the accused had sex with the young person shortly after meeting her, "is that more or less exploitative than sex after a long friendship or romance?" Finally, he states, the status of the accused in relation to the complainant is such a vague factor that it adds nothing to the determination of whether the accused was in a position of trust, and is "[a]' factor' that is simply a restatement of the original question [and it] is not likely to help clarify a difficult legal issue".
50 Professor Patrick concludes by stating at ¶19:
In the absence of significant amendments ... judges must try to craft a definition of trust that carries out Parliament's goal in preventing exploitation while not creating an overbroad definition that, in effect, raises the age of consent to 18 or simply duplicates "authority" or "dependency".
51 This review of some of the jurisprudence and academic discussion on the issue outlines the challenges facing trial judges who must apply the Audet test in determining if circumstances, particularly in those cases outside the presumptive or inherent trust relationships, fall into the category of "a position of trust". This case is an example of such a challenge."
I expect fame and fortune to quickly follow this monumental event.