r v vaillancourt, [1987] 2 s.c.r. 636, is a landmark case from the supreme court of canada on the constitutionality of the criminal code concept of "constructive murder". the court ruled that crimes with significant "stigma" attached, such as murder, require proof of the mens rea element of "subjective foresight of death", and therefore the provision of the criminal code for constructive murder was unconstitutional.