The Report of the Royal Commission on the Donald Marshall Jr. prosecution had recommended that the issue of compensation for Marshall be revisited. On March 22, 1990 an Order-in-Council was passed appointing Gregory T. Evans, Chief Justice of the Ontario High Court, as a commission of one to examine the adequacy of compensation paid to Donald Marshall Jr., in light of what the Royal Commission on the Donald Marshall Jr., Prosecution found to be factors contributing to this wrongful conviction and continued incarceration. W. Wylie Spicer was appointed Commission Counsel. Hearings were held early in April 1990 and the Commission reported its findings on July 5, 1990.