Following the Supreme Court's decision in "R. v. Pham", lower courts extended its applicability to other collateral consequences. For example, courts have held that stigma or the loss of employment following a conviction to be collateral consequences that can be taken into account during sentencing. The British Columbia Court of Appeal also ruled that a "lifetime ban...from income and disability assistance as a result of conviction..." is a collateral consequence and that a more lenient sentence may be imposed to avoid such a consequence.