He was just a teenage boy, running for his life from gang rivals who brutally beat and killed him despite his posing no threat to them.
And Manitoba justice officials say it's this feature of Paris Bruce's senseless death that's among the central reasons the courts should hand down life prison sentences for two men who admit taking part in his fatal beating.
"This is as close to murder as it can get," Crown attorney Brent Davidson told judge Brian Corrin on Wednesday.
"It is hard to imagine a more serious assault leading to his death," Davidson said.
Warner Flett, 26, and Michael Guimond, 35, appeared for a sentencing hearing in provincial court on Wednesday.
Both men are members of the Indian Posse street gang and previously pleaded guilty to manslaughter.
They also conceded Bruce's killing was to further the interests of the notoriously violent and feared gang.
Bruce, 16, was chased, knocked down and attacked by IP members on Sept. 4, 2012.
Bruce fell victim to a plot hatched by rival MOB Squad gang leader Joshua Jeffs to try to take over an IP-controlled crack house on Redwood Avenue.
"He was used by other individuals to further their own criminal means," Davidson said. "Paris Bruce was a child in all senses of the word."
On his third trip to the home, Bruce was confronted by Guimond at the door. Bruce and another teen tossed bits of wood and a brick at him, causing an injury.
Between five and seven IP members -- including Flett and Guimond -- chased after Bruce, catching up with him in a nearby back lane.
Guimond admits to striking Bruce a few times, while Flett admits kicking him, including once in the head, an agreed statement of facts says.
Bruce was assaulted further in a backyard and then on the side of an Aberdeen Avenue home. It remains unclear who attacked him in these locations.
Bruce's injuries were severe, Davidson said. A few days after he was found and rushed to hospital, he was taken off life-support.
He suffered 29 external injuries, had nine areas of brain trauma and had been stabbed with two different knives, he told court.
"This was a savage group beating administered by a gang of offenders," said Davidson.
"Paris Bruce was running away... this 16-year-old child posed this group absolutely no danger," he added. "He ran for his life."
Four other IP members charged in Bruce's killing walked free after the Crown came to a plea arrangement with Flett and Guimond on specific facts of their involvement.
Davidson spent considerable time carefully detailing the criminal histories of each of the killers to support his life-sentence bid.
Flett's record is "horrendous," and the facts behind his convictions demonstrate a proclivity for violence, he said.
"Mr. Flett beats people when they're down. Mr. Flett beats people when they're already being beaten," said Davidson.
Guimond has been implicated in the past in gang-related violence "eerily similar" to what Bruce faced, Corrin was told.
"How many people have to die... before we recognize the harm and risk to the citizens of Winnipeg?" Davidson asked Corrin.
"How can we trust him with anything less than lifetime supervision?"
Offenders who get life sentences are subject to public monitoring by corrections officials for their entire lives if and when they're paroled from prison.
Lawyer Sarah Inness urged Corrin to focus on the fact Flett pleaded guilty, requesting a sentence no longer than seven years for his role.
She noted Flett's relative youth, his remorse for what happened to Bruce and the fact he had been drinking at the time of the attack.