In R. v. Pawlicki, the court determined that possession of a firearm is determined by accessibility rather than the exact distance between the defendant and the firearm. In R. v. Callender, the court dismissed an appeal, determining that the concept of employment could be interpreted broadly to include self-employment. In R. v. Reid, it was determined that reckless driving included heedlessness of a risk as well as failure to respond to a known risk. In R. v. Grafton, the judge's request for a police officer to be called as a witness was determined to be wrong, although judges do have the power to call witnesses and have occasionally used it. Notes