Suggested Supreme Court of Canada Cases:

You can choose between writing your own "case comment" or "judgment"  on cases that been granted leave to appeal but that have not been heard yet or your own "case comment" on recent decisions by the Supreme Court.  The cases listed hear are a suggested selection.  If you would prefer to write on another case, including cases from other courts, please contact the instructor:

CASE 1
 Attorney General of Canada v. Stephen Joseph Harper (Alta.) (Civil) (By Leave)

      The application for leave to appeal from the judgment of the Court of Appeal of Alberta (Calgary), Number 01-00389, dated December 16, 2002, is granted with costs to the applicant in any event of the cause.

 

NATURE OF THE CASE
Canadian Charter of Rights and Freedoms - Civil - Civil rights - Elections - Elector bringing action for declaration that ss. 323(1) and (3), 350-60, and 362 violated ss. 2(b), 2(d) and 3 of the Charter and were of no force and effect pursuant to s. 52 of the Constitution Act, 1982 - Whether third party advertising spending limits in the Canada Elections Act 2000 violated the Respondent's Charter right to freedom of expression - Balance to be struck between political expression and integrity of the electoral process - Standard of proof required under s. 1 of the Charter - Canada Elections Act, S.C. 2000, c. 9

 

PROCEDURAL HISTORY
June 29, 2001
Court of Queen's Bench of Alberta
(Cairns J.)
 
Respondent's request to declare sections 350 and 351 of the Canada Elections Act in violation of the Charter granted; sections 350 and 351 declared of no force and effect
December 16, 2002
Court of Appeal of Alberta
(Berger [dissenting], Paperny and Ritter JJ.A.)
 
Appeal dismissed, Cross-appeal allowed: ss. 323, 350-57, and 362 declared to be of no force or effect

CASE 2

House of Commons and The Honourable Gilbert Parent v. Satnam Vaid and Canadian Human Rights Commission (FC) (Civil) (By Leave)
 

      The application for leave to appeal from the judgment of the Federal Court of Appeal, Number A-1-02, dated November 28, 2002, is granted with costs to the applicants in any event of the cause.

 

NATURE OF THE CASE

Administrative law - Jurisdiction - Parliamentary privilege - Whether judicial and administrative tribunals are limited to determining the categories of privileges over which the legislative branch has exclusive jurisdiction, or whether they may also scrutinize each individual exercise of parliamentary privilege - Whether the power to appoint and manage staff is a category of parliamentary privilege - If the power to appoint and manage staff is a category of parliamentary privilege, whether claims of discrimination reduce the scope of that category permitting review of the Applicants actions - Whether Parliament, by enacting the Parliamentary Employment and Staff Relations Act, R.S.C. 1985, c. 33 (2nd Supp.), waived its privilege over employment matters relating to the categories of employees covered by that Act.

 

PROCEDURAL HISTORY
April 25, 2001 Canadian Human Rights Tribunal
(Mactavish, Chairperson [dissenting] and Roberts and Tomar, Members)
Applicants declared to be subject to the Canadian Human Rights Act, R.S.C. 1985, c. H-6
 

December 4, 2001  Federal Court of Canada

(Tremblay-Lamer J.)
Applicants application for judicial review dismissed

 

November 28, 2002 Federal Court of Appeal
(Linden, Létourneau and Rothstein [concurring in the result] JJ.A.)
Appeal dismissed

 

CASE 3

Her Majesty the Queen v. Walter Tessling (Ont.) (Criminal) (By Leave)
 

      The application for leave to appeal from the judgment of the Court of Appeal for Ontario, Number C36111, dated January 27, 2003, is granted.

 

NATURE OF THE CASE

Canadian Charter - Criminal - Criminal Law - Search and Seizure - Evidence - Use of FLIR technology to photograph heat emanating from residence of accused - Images produce by FLIR camera might suggest presence of marihuana grow operation - FLIR surveillance conducted prior to obtaining warrant and results of surveillance used in Information to obtain a warrant to search accuseds residence and seize items - Whtehr use of FLIR constituted a search for puirposes of s. 8 of Charter - Whether s. 8 of  Charter breached - Whether evidence should be excluded.

 

PROCEDURAL HISTORY
December 5, 2000
Ontario Superior Court of Justice
(Thomson J.)
 
Respondent found guilty of possession of marijuana for the purposes of trafficking and related offences under ss. 95, 29 (1), 86 (1) of the Criminal Code and ss. 7 (1), 5 (2), 4 (1) of the Controlled Drugs and Substances Act
January 27, 2003
Court of Appeal for Ontario
(OConnor A.C.J.O., Abella and Sharpe JJ.A.)
 
Appeal allowed; convictions set aside, verdicts of acquittal entered

 

CASE 4

 The Attorney General of British Columbia, The Medical Services Commission of British Columbia v. Connor Auton, an Infant, by his Guardian Ad Litem, Michelle Auton, and the said Michelle Auton in her personal capacity, Michelle Tamir, an Infant, by her Guardian Ad Litem, Sabrina Freeman, and the said Sabrina Freeman in her personal capacity, Jordan Lefaivre, an Infant, by his Guardian Ad Litem, Leighton Lefaivre, and the said Leighton Lefaivre in his personal capacity, Russell Gordon Pearce, an Infant, by his Guardian Ad Litem, Janet Gordon Pearce and the said Janet Gordon Pearce in her personal capacity (B.C.) (Civil) (By Leave)
 

       The application for leave to appeal and the application for leave to cross-appeal from the judgment of the Court of Appeal of British Columbia (Vancouver), Number CA027600, dated October 9, 2002, are granted.

 

NATURE OF THE CASE

Canadian Charter - Civil - Crown liability - Remedies - Whether Crown breached Charter rights of autistic children by failing to provide funding for early intensive behavioural treatment - Whether the Court of Appeal erred in holding that s .15(1) of the Charter requires the Crown to fund services which are directed at the amelioration of a disadvantage not created by law - Whether the Court of Appeal erred in holding that the failure of the Crown to fund behavioural therapies constituted a unjustifiable infringement of the equality rights of the petitioners - Whether the Court of Appeal erred in directing the Crown to fund behavioural treatments for autism rather than issuing a general declaration of right.

 

PROCEDURAL HISTORY
February 6, 2001
Supreme Court of British Columbia
(Allan J.)
 
Crown directed to fund early intensive behavioural therapy for autistic children; adult Respondents each awarded $20,000.00 in damages; proceeding against Applicant Medical Services Commission dismissed
October 9, 2002
Court of Appeal for British Columbia
(Lambert [dissenting in part on the cross-appeal], Hall and Saunders JJ.A.)
 
Appeal dismissed; cross-appeal allowed in part: jurisdiction of the Supreme Court to entertain an application for mandamus affirmed

 

CASE 5
 

Roger Gosselin, Guylaine Fillion, Daniel Trépanier, Claudette Gosselin, Guy Boulianne, Johanne Labbé, Alain Chénard, Rachel Guay, Gilles Maltais, Guylaine Potvin, Jean-Marie Martineau, Mance Bourassa, Marc Joyal, Marie-Irma Cadet, René Giguère and Lucille Giordano v. Attorney General of Québec, Minister of Education (Que.) (Civil) (By Leave)
 

       The application for leave to appeal from the judgment of the Court of Appeal of Quebec (Montreal), Number 500-09-010446-003, dated May 15, 2002, is granted with costs to the applicants in any event of the cause.

 

NATURE OF THE CASE
Constitutional Law - Schools - Charter of Human Rights and Freedoms, R.S.Q., ch. C-12 - Charter of French Language, R.S.Q., ch. C-11 - Discrimination - Whether sections 72, 73 and 75 of the Charter of the French Language are inconsistent with sections 10 and 12 of the Charter of Human Rights and Freedom?

 

PROCEDURAL HISTORY
November 14, 2000
Superior Court of Quebec
(Laramée J.)
 
Applicants' motions for declaratory judgments to declare sections 72, 73 and 75 of the Charter of the French Language inoperative dismissed
May 15, 2002
Court of Appeal of Quebec
(Gendreau, Mailhot and Forget JJ.A.)
 
Appeal dismissed

 

CASE 6

Edwidge Casimir v. Attorney General of Quebec (Que.) (Civil) (By Leave)
 

       The application for leave to appeal from the judgment of the Court of Appeal of Quebec (Montreal), Number 500-09-010454-007, dated May 15, 2002, is granted with costs to the applicant in any event of the cause.

 

NATURE OF THE CASE

Constitutional law -- Schools -- Canadian Charter of Rights and Freedoms -- Charter of French Language, R.S.Q. ch. C-11 -- Whether the words « provided that that instruction constitutes the major part of the elementary or secondary instruction received by the child in Canada » in s. 73(2) of the Charter of the French Language are unconstitutional in light of s. 23(2) of the Canadian Charter of Rights and Freedoms?
 

PROCEDURAL HISTORY

December 14, 2000
Superior Court of Quebec
(Grenier J.)
 
Respondents Cezary and Isabella Solski's motion for declaratory judgment to declare s. 73(2) of the Charter of the French Language inoperative because of its incompatibility with s. 23 of the Canadian Charter of Rights and Freedoms granted
May 15, 2002
Court of Appeal of Quebec
(Gendreau, Mailhot and Forget JJ.A.)
 
Appeal allowed

 

CASE 7
 

The Minister of Forests, The Attorney General of British Columbia on behalf of Her Majesty the Queen in Right of the Province of British Columbia v. Council of the Haida Nation and Guujaaw, on their own behalf and on behalf of all members of the Haida Nation AND BETWEEN Weyerhaeuser Company Limited v. Council of the Haida Nation and Guujaaw, on their own behalf and on behalf of all members of the Haida Nation (B.C.) (Civil) (By Leave)
 

      The application for leave to appeal of the applicant, Weyerhaeuser Company Limited, from the judgment of the Court of Appeal of British Columbia (Vancouver), Number CA027999, dated February 27, 2002 and August 19, 2002, is granted with costs in the cause.

      The application for leave to appeal of the applicants, the Minister of Forests and the Attorney General of British Columbia, from the judgment of the Court of Appeal of British Columbia (Vancouver), Number CA027999, dated February 27, 2002 and August 19, 2002, is granted. By agreement, the applicants, the Minister of Forests and the Attorney General of British Columbia, shall pay the party and party costs of the Respondents, Council of the Haida Nation and Guujaaw, for this application for leave to appeal and for the appeal, in any event of the cause.


 

NATURE OF THE CASE
Administrative law - Native law - Judicial review - Ministerial decision - Nature and scope of duty to consult with First Nations - Whether Provincial Crown in exercising its powers and duties in the management of natural resources, owe constitutional or fiduciary duties to First nations to consult and to seek accommodations prior to the determination of disputed claims of aboriginal rights and title - If such duty exists, standard of review and applicable tests for determining whether decision makers have discharged their duty- Whether private persons or corporations operating on Crown lands, as licensees of the Crown, owe fiduciary or other legal duties to consult with and accommodate First Nations who claim Aboriginal rights or title may be infringed by the licensees' actions and if so, the source, nature and extent of those duties

 

PROCEDURAL HISTORY
July 10, 2000
Supreme Court of British Columbia
(Edwards J.)
 
Any issues requiring proof of Aboriginal rights or title referred to trial list
November 21, 2000
Supreme Court of British Columbia
(Halfyard J.)
 
Haida Nation's petition for judicial review, dismissed
February 27, 2002
Court of Appeal for British Columbia
(Finch C.J.B.C., Lambert and Low JJ.A.)
 
Haida Nation's appeal allowed: obligation by provincial Crown and Weyerhaeuser to consult with the Haida Nation concerning potential infringements of aboriginal title and rights; parties free to apply to a judge of the Supreme Court of British Columbia for determination of aboriginal title and rights, infringement and justification
August 19, 2002
Court of Appeal for British Columbia
(Finch C.B.C., Lambert and Low [dissenting] JJ.A.)
 
Additional reasons for judgment: order that all reference in the original reasons to any breach by Weyerhaeuser of its duty to consult the Haida Nation expunged from the original reasons, by consent of parties; provincial Crown had in 2000 and the Crown and Weyerhaeuser have now, legal enforceable duties to the Haida Nation to consult and seek accommodation


 

CASE 8
 

The City of Calgary v. The United Taxi Drivers' Fellowship of Southern Alberta, Rashpal Singh Gosal and Haringer Singh Dhesi, Aero Cab Ltd., Air Linker Cab Ltd. (Alta.) (Civil) (By Leave)
 

       The application for leave to appeal from the judgment of the Court of Appeal of Alberta (Calgary), Number 17693, dated May 29, 2002, is granted with costs to The City of Calgary in any event of the cause.

 

NATURE OF THE CASE
Canadian Charter - Civil - Municipal Law - Municipal corporations - Municipal powers - Bylaw Regulating Taxi Industry - Bylaw limiting number of available taxi vehicle plate licenses - Whether municipalities may be provided with broad general and regulatory powers rather than with specific powers, functions or activities - Whether power of municipalities may be circumscribed by what they cannot do rather than by what they can do - Whether Municipal Government Act, R.S.A. 2000, c. M-26, provides municipalities in Alberta with legislative authority to pass intra vires bylaws including, but not limited to, a bylaw limiting the number of taxi vehicle plate licenses to be issued - Whether bylaw violated ss. 2, 7 or 15 of the Charter by discriminating on the basis of age and analogous ground or by denying freedom of association or by denying liberty and security of the person to pursue a chosen profession.

 

PROCEDURAL HISTORY
March 5, 1998
Court of Queen's Bench of Alberta
(Rooke J.)
   
Respondents' application allowed in part; lottery system for taxi plate licenses declared discriminatory and contrary to s. 15 of CharterMay 29, 2002
Court of Appeal of Alberta
(O'Leary [dissenting], Picard and Wittmann JJ.A.)
 
Respondents' appeal allowed; s. 7(1), portions of s. 9.1 and all of s. 9.2 of the Bylaw declared ultra vires

 

CASE 9
 

Figueroa v. Canada (Attorney General)

ON APPEAL FROM THE COURT OF APPEAL FOR ONTARIO

     Constitutional law -- Charter of Rights -- Democratic rights of citizens -- Right to vote -- Right to be qualified for membership in House of Commons or provincial legislative assembly -- Right to meaningful participation in electoral process -- Canada Elections Act providing that political parties must nominate candidates in at least 50 electoral districts to qualify for certain benefits -- Whether provisions infringe right to vote or to run for office -- If so, whether infringement justifiable -- Canadian Charter of Rights and Freedoms, ss. 1, 3 -- Canada Elections Act, R.S.C. 1985, c. E-2, ss. 24(2), 24(3), 28(2).

     Under the Canada Elections Act, a political party must nominate candidates in at least 50 electoral districts in order to obtain, and then to retain, registered party status. Registered parties qualify for several benefits including the right of candidates to issue tax receipts for donations made outside the election period, to transfer unspent election funds to the party and to list their party affiliation on the ballot papers. The appellant challenged the constitutionality of the 50-candidate threshold. The trial judge held that the threshold was inconsistent with s. 3 of the Canadian Charter of Rights and Freedoms and that this infringement could not be justified under s. 1 of the Charter. The Court of Appeal held that the 50-candidate threshold was not inconsistent with s. 3 of the Charter, except to the extent that it denied candidates of non-registered parties the right to identify their party affiliation on the election ballot.

     Held: The appeal should be allowed. Sections 24(2), 24(3) and 28(2) of the Canada Elections Act are declared unconstitutional. The declaration of unconstitutionality is suspended for 12 months.

 

CASE 10
 

R. v. Blais and R. v. Powley

Heard - 2003: March 18; Judgment Delivered - 2003: September 19.

Present:  McLachlin C.J. and Gonthier, Iacobucci, Major, Bastarache, Binnie, Arbour, LeBel and Deschamps JJ.

ON APPEAL FROM THE COURT OF APPEAL FOR MANITOBA

     Constitutional law -- Manitoba Natural Resources Transfer Agreement -- Hunting rights -- Métis -- Métis convicted of hunting contrary to provincial statute -- Natural Resources Transfer Agreement providing that provincial laws respecting game apply to Indians subject to their continuing right to hunt, trap and fish for food on unoccupied Crown lands -- Whether Métis are "Indians" under hunting rights provision of Natural Resources Transfer Agreement -- Natural Resources Transfer Agreement, 1930 (Constitution Act, 1930), Sch. 1, para. 13.

     The appellant, a Manitoba Métis, was convicted of hunting deer out of season. He had been hunting for food on unoccupied Crown land. His appeals to the Manitoba Court of Queen's Bench and the Manitoba Court of Appeal were based solely on the defence that, as a Métis, he was immune from conviction under the Wildlife Act regulations in so far as they infringed on his right to hunt for food under para. 13 of the Natural Resources Transfer Agreement (NRTA). This provision stipulates that the provincial laws respecting game apply to the Indians subject to the continuing right of the Indians to hunt, trap and fish for food on unoccupied Crown lands.  Both appeals were unsuccessful. The issue in this appeal was whether the Métis are "Indians" under the hunting rights provision of the NRTA.

     Held: The appeal should be dismissed.

     The NRTA is a constitutional document which must be read generously within its contextual and historical confines and yet in such a way that its purpose is not overshot. Here, the appellant is not entitled to benefit from the protection accorded to "Indians" in the NRTA. First, the NRTA's historical context suggested that the term "Indians" did not include the Métis.  The historical documentation indicated that, in Manitoba, the Métis had been treated as a different group from "Indians" for purposes of delineating rights and protections.  Second, the common usage of the term "Indian" in 1930 did not encompass the Métis.  The terms "Indian" and "half-breed" had been used to refer to separate and distinguishable groups of people in Manitoba from the mid-19th century through the period in which the NRTA was negotiated and enacted. The location of para. 13 in the NRTA under the heading "Indian Reserves" further supports this interpretation. Third, the purpose of para. 13 of the NRTA was to ensure respect for the Crown's obligations to "Indians" with respect to hunting rights, who were viewed as requiring special protection and assistance. This view did not extend to the Métis, who were considered more independent and less in need of Crown protection.

     A requirement for "continuity of language" should not be imposed on the Constitution as a whole and, in any event, such an interpretation would not support the contention that the term "Indians" should include the Métis.  The principle that ambiguities should be resolved in favour of Aboriginal peoples is inapplicable as the historical documentation was sufficient to support the view that the term "Indians" in para. 13 of the NRTA was not meant to encompass the Métis.  Nor does the "living tree" doctrine expand the historical purpose of para. 13; while constitutional provisions are intended to provide "a continuing framework for the legitimate exercise of governmental power", the Court is not free to invent new obligations foreign to the original

 

CASE 11
 

Authorson v. Canada (Attorney General)

Heard - 2003: April 10: Judgment Delivered - 2003: July 17.

Present:  McLachlin C.J. and Gonthier, Major, Bastarache, Binnie, Arbour and
LeBel JJ.

ON APPEAL FROM THE COURT OF APPEAL FOR ONTARIO

     Civil rights -- Due process rights respecting property -- Expropriation without compensation -- Veterans' pension and allowances -- Government administering pensions and other benefits for war veterans and failing to invest funds or pay interest -- Legislation purportedly barring claim to interest -- Whether due process protections of Canadian Bill of Rights guard against expropriation of property by passage of valid legislation -- Canadian Bill of Rights, S.C. 1960, c. 44, ss. 1(a), 2(e) -- Department of Veterans Affairs Act, R.S.C. 1985, c. V-1, s. 5.1(4).

     The respondent was named representative plaintiff of a class of disabled veterans who received pensions and other benefits from the Crown under three different statutes.  These funds were administered by the Department of Veteran Affairs ("DVA") because the veterans were deemed incapable of managing their money. These funds were rarely invested or credited with interest until 1990, when the DVA began paying interest on the accounts.  But Parliament chose to limit the Crown's liability for past interest by enacting s. 5.1(4) of the Department of Veteran Affairs Act which provides that no claim shall be made after the coming into force of the provision for or on account of interest on moneys held or administered by the Minister during any period prior to January 1, 1990 pursuant to any of the three relevant statutes.  The class sued the Crown, alleging breach of fiduciary duty and claiming that the s. 5.1(4) bar was inoperative under the Canadian Bill of Rights, because it was inconsistent with the right not to be deprived of the enjoyment of property except by due process of law (s. 1(a)) and the right to a fair hearing in accordance with the principles of fundamental justice for the determination of one's rights and obligations (s. 2(e)). The Ontario Superior Court of Justice held that the Crown owed a fiduciary duty to the disabled veterans, and so was obliged to either invest the funds on their behalf, or pay interest, and that s. 5.1(4) of the Act was inoperative under the Bill of Rights.  The Court of Appeal upheld the decision.

     Held: The appeal should be allowed.

     Where federal legislation conflicts with the protections of the Bill of Rights, unless the conflicting legislation expressly declares that it operates notwithstanding the Bill of Rights, the Bill of Rights applies and the legislation is inoperative. The Bill of Rights protects only rights that existed in 1960, prior to its passage.
Section 5.1(4) of the Act is not inconsistent with either s. 1(a) or s. 2(e) of the Bill of Rights and the veterans were lawfully denied interest on their pension and other benefits.  The due process protections in s. 1(a) of the Bill of Rights do not require that the veterans receive notice and a hearing before Parliament prior to the passage of expropriative legislation. Long-standing parliamentary tradition has never required that procedure, and due process protections cannot interfere with the right of the legislative branch to determine its own procedure. Such a power to interfere would effectively amend the Canadian Constitution. Further, although due process protections of property in the Bill of Rights do confer certain rights to notice and an opportunity to make submissions in the adjudication of individual rights and obligations, no such rights are at issue in this case. No adjudicative procedure is necessary for the nondiscretionary application of a law to incontestable facts.  Lastly, while substantive rights may stem from due process, the Bill of Rights does not protect against the expropriation of property by the passage of unambiguous legislation. Parliament has the right to expropriate property, even without compensation, if it has made its intention clear and, in s. 5.1(4), Parliament's expropriative intent is clear and unambiguous.

     Section 2(e) of the Bill of Rights applies only to guarantee the fundamental justice of proceedings before any tribunal or administrative body that determine individual rights and obligations.  It does not impose on Parliament the duty to provide a hearing before the enactment of legislation.