3, 2003 SCC 38, is a leading Supreme Court of Canada decision where the Court affirmed the limits to which private citizens may undertake an arrest, as well as the limits of private individuals in the use of force to protect property.

This case holds particular importance as the prevalence of private security has become increasingly popular across Canada.

Daniel Asante-Mensah was a "scooper," a type of Toronto taxi driver that picks up fares from the Pearson International Airport without the proper permit authorized under the Ontario Trespass to Property Act.

The Supreme Court, in a unanimous decision, held that the inspector had properly arrested Asante-Mensah.

In reference to R. v. Whitfield, the Court held that a citizen's arrest at common law allows for a use of "reasonable force".