IQALUIT - Dr. Christopher Milroy, the forensic pathologist at Ottawa Hospital who performed the autopsy on Elisapee Michael testified Tuesday the cause of her death was head injury, and the pattern of bruising on the brain and skull fracture were characteristic of someone who had fallen on the back of the head.

She had a blood clot under the thick membrane surrounding the brain and bleeding in the frontal lobe.

Milroy added the surgery in Ottawa her family decided not to authorize - which the surgeon told them had a 50/50 chance of being successful and a less than 50 per cent survival rate - would not have saved her life at that point.

On Wednesday before the lawyers began their final submissions, the court heard from RCMP Sgt. Peter Pilgrim, who in 2009 was the operations non-commissioned officer in Iqaluit.

Pilgrim was responsible for screening the guards, ensuring they were trained and had read the required manuals.

While Michael spent time in RCMP cells, she was under the supervision of three guards in total, one guard on each shift.

Wheildon asked Pilgrim if the three guards had signed the Iqaluit cell block operations manual. It turned out only one guard had signed it.

Pilgrim was then asked if any of the guards had attended a session on how to assess a prisoner's responsiveness.

"I've never heard of it before," he said.

The manual and the session include the four Rs - rousability, response to questions, response to commands and remember. A tour of the cells revealed a poster with the four Rs was on the wall next to the door of the cell block.

"The guards never assessed responsiveness in 14 hours," Wheildon said.

The court heard there is no specific amount of time guards have to be trained for before they report for duty. This was confirmed by guard Jonathan Dailey who worked the 1 a.m. to 9 a.m. shift on Aug. 9.

He said the training mainly consisted of on-the-job shadowing.

That night when Michael was in the cells, he checked on her and the other prisoners to see if she was still breathing. If there was no response he said he kicked or banged on the door.

Dailey said he was unsure if there was a policy on guard work and does not remember reading it.

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