A Rather Quick Response to a Rather Typical Vexatious Litigant

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Case commented on: Onischuk v Alberta, 2013 ABQB 89.

The prominent September 2012 decision of Court of Queen’s Bench Associate Chief Justice John D. Rooke in Meads v Meads, 2012 ABQB 571, established a continuum of litigants, ranging from commonly encountered self-represented litigants, to infrequently encountered and almost always self-represented vexatious litigants, through to the highly unusual organized pseudolegal commercial argument (OPCA) litigant who is usually self-represented. Justice Rooke’s decision in Onischuk v Alberta concerns a litigant who appears to fit in the middle of that continuum, a rather typical vexatious litigant, although perhaps found to be so more quickly than has been the usual case. It is those two matters — typicality and velocity — that I focus on in this post.

Facts

Onischuk’s initial claim arose from his allegation that he was exposed to toxic chemicals as a result of voluntarily participating in a cleanup of chemicals that spilled into Lake Wabamun as a result of the derailment of a Canadian National Railway (CNR) train in 2005. Justice Rooke says nothing more about this instigating event; he has no reason to do so in the context of the applications before him. However, some third party description of the event is necessary to support my claim that Onischuk is a “typical” vexatious litigant.

The spill is described by Ron Goodman in “Wabamun: A Major Inland Spill” as follows:

On August 3, 2005, forty-three cars of a westbound Canadian National Railways freight train derailed on the shore of Lake Wabamun, just west of Alberta’s capital city of Edmonton, spilling about 750 m3 of Bunker C and 75 m3 of a pole-treating agent on the lakeshore. The spilled materials quickly flowed into the lake, forming a slick that spread rapidly along the north shore of the lake, oiling more than 12 km of shoreline …. The local volunteer fire department responded in a few minutes and evacuated local residents. There was no fire and the spilled material quickly flowed into the lake. There was a large amount of a single product (750m3), which at the time was not identified as a dangerous good, so the fire department turned the response of the spill to the spiller. Canadian National Railways (CNR) called upon their response contractor to respond to the spill …. Bunker C is well known to have a serious environmental impact, mostly due to smothering. Its density being near that of freshwater, means it has a tendency to sink with only a limited amount of weathering or picking up of debris.

In 2009 CNR was fined a total of $1.4 million for the 2005 Lake Wabamun derailment. CNR pleaded guilty to three charges — one under Alberta’s Environmental and Enhancement Act for failing to take all reasonable measures to remedy and confine the spill, one under the federal Fisheries Act, and a third under the federal Migratory Birds Convention Act, 1994. CNR was also ordered to implement an emergency response plan to meet industry standards. See Environment Canada Enforcement Notification, “Canadian National Railway Convicted In Environmental Enforcement Cases in Alberta and British Columbia” (May 25, 2009). Also as a result of the spill, and due to public concern about the lack of government response, the Alberta Minister of the Environment established the Environmental Protection Commission to develop an improved infrastructure to respond to environmental emergencies in Alberta. See “Environmental Disasters and Lake Wabamun: A Review of the Government’s Response” by Jodie Hierlmeier, Staff Counsel, Environmental Law Centre (News Brief, Vol. 20 No. 5, 2005).

Onischuk initially sued CNR and a number of its employees, the Province of Alberta and several of its ministries, as well as ministries, boards and agencies of the federal government in August 2007. He discontinued his action against Alberta and Canada in 2009. His action against CNR and some of its employees was struck in 2009 by Justice Sulyma on the basis that Onischuk’s claim did not disclose a reasonable cause of action. Negligence, as a cause of action, requires that the defendant owe the plaintiff a duty of care, a breach of that duty of care by the defendant, a causal connection between the negligent conduct of the defendant and the resulting injury to the plaintiff, and resulting damage to the plaintiff. Justice Rooke does not indicate in what way Onischuk’s initial claim failed to disclose a reasonable cause of action, but I imagine it failed because the law does not recognize that a duty of care is owed by someone in CNR’s position to someone in Onischuk’s position.

That was the beginning. There was certainly a wrong by CNR: the spill of the Bunker C oil and pole-treating agent. And Onischuk may well have been exposed to toxic chemicals as a result of voluntarily participating in the cleanup of the spill. But because his claim was struck for failing to disclose a reasonable cause of action, we do not know if Onischuk suffered an injury that was caused by exposure to the Bunker C oil or pole-treating agent spilled by the derailment.

It was what happened after October 2009 — after Onischuk’s 2007 action was struck — that resulted in him being declared a vexatious litigant less than three-and-a-half years later. Justice Rooke accepted the summary of facts prepared by CNR’s lawyer and reproduced it as an eleven page Appendix to his Reasons for Decision. To very briefly summarize that summary:

    • Onischuk filed a Notice of Appeal of Justice Sulyma’s decision to strike his claim against CNR but did not file the required documents on time and his appeal was struck.
    • Onischuk filed applications to restore his appeal and to retroactively extend the time to appeal but those applications were dismissed by Justice Costigan in Onischuk v Canadian National Railway Co., 2010 ABCA 411 because the appeal lacked arguable merit, there was no reviewable error on the face of Justice Sulyma’s decision, and Onischuk had not proceeded with his appeal with the necessary diligence.
    • Early in 2011 Onischuk filed a claim in the Federal Court that was nearly identical to the one struck by Justice Sulyma, an action which was struck by Prothonotary Lafrenière for lack of jurisdiction, failure to disclose a reasonable cause of action, futility and abuse of process.
    • Onischuk appealed Prothonotary Lafrenière’s decision but that decision was upheld by the Federal Court Trial Division.
    • Onischuk appealed the Trial Division decision and it was upheld by the Federal Court of Appeal: Onischuk v Alberta, 2011 Carswell Nat 6111.
    • Onischuk applied for leave to appeal to the Supreme Court of Canada but that was denied: Onischuk v Alberta, 2012 Carswell Nat 359.
    • Early in 2011 Onischuk filed a second Court of Queen’s Bench action that was nearly identical to the one struck by Justice Sulyma and the one struck by the Federal Courts. It differed in two ways from the first two:
      • Judges and lawyers who were involved in the first Queen’s Bench action and in the Federal Court action were added as defendants, and Onischuk alleged negligence, bias, discrimination, misrepresentation, fraud and deceit, and more against them,
      • Remedies not available in our judicial system were sought, including a request for lawyers and judges submit to “lie detection exams” and the administration of a “truth serum” drug.
    • In March 2012 Onischuk filed an Amended Statement of Claim in the second Queen’s Bench action which named twenty-one additional defendants, including more lawyers and judges, the Governor General of Canada, the Premier of Alberta.
    • In April 2012 Onischuk filed a 51 page Amended Amended Statement of Claim.
    • In April 2012, Onischuk wrote to the Associate Chief Justice Rooke requesting the appointment of a Case Management Judge, a request to which all the Defendants subsequently agreed.
      • Onischuk subsequently requested adjournments of case management meetings and document production deadlines.
      • Onischuk subsequently alleged bias in Justice Rooke’s actions as Case Management Judge.

Law

The Alberta government passed new legislation in 2007 for the express purpose of giving the courts in the province more power to deal efficiently and effectively with “vexatious litigants.” Once a person is declared a “vexatious litigant,” they are barred from bringing or continuing court actions without permission from a court. The new provisions are found in the Judicature Act, RSA 2000, c J-. Section 23(2) provides a non-exhaustive list of the types of conduct that make proceedings vexatious:

(2)  For the purposes of this Part, instituting vexatious proceedings or conducting a proceeding in a vexatious manner includes, without limitation, any one or more of the following:

(a) persistently bringing proceedings to determine an issue that has already been determined by a court of competent jurisdiction;
(b) persistently bringing proceedings that cannot succeed or that have no reasonable expectation of providing relief;
(c) persistently bringing proceedings for improper purposes;
(d) persistently using previously raised grounds and issues in subsequent proceedings inappropriately;
(e) persistently failing to pay the costs of unsuccessful proceedings on the part of the person who commenced those proceedings;
(f) persistently taking unsuccessful appeals from judicial decisions;
(g) persistently engaging in inappropriate courtroom behaviour.

As can easily be seen from this list, a prolonged or insistently continuous quality to behaviour is key. Justice Rooke relied upon Del Bianco v 935074 Alberta Ltd., 2007 ABQB 150, Jamison v Denman, 2004 ABQB 593, Prefontaine v Pairs, 2007 ABQB 77, and O’Neill v Deacons, 2007 ABQB 754  to synthesize a definition of a “vexatious litigant” as “one who repeatedly brings pleadings containing extreme, unsubstantiated, unfounded, and speculative allegations against a large number of individuals to exploit or abuse the court process for an improper purpose, or to gain an improper advantage” (at para 9).

Decision

Justice Rooke concluded (at para 12) that Onischuk had instituted vexatious proceedings and conducted proceedings in a vexatious manner. In fact, he found (at para 15) that Onischuk’s actions had “all the hallmarks of a vexatious litigant.” Those hallmarks were (at paras 13-14):

  • Onischuk continued to bring actions based on the same facts arising out of the 2005 derailment of the CNR train. When one action was dismissed, Onischuk started essentially the same action again, but with the addition of defendants who were members of the judiciary or legal community who were involved in the prior action.
  • Onischuk persistently brought proceedings on issues that have already been decided.
  • He failed to follow court directives and failed to meet procedural deadlines.
  • Onischuk failed to pay the costs awarded against him.
  • His pleadings were excessively lengthy.
  • His pleadings were filled with inflammatory accusations and theories about conspiracies among judges and lawyers.
  • His pleadings contained irrelevant arguments, jurisprudence and legislation, and failed to advance legitimate claims.

The defendants then asked that Onischuk’s claims against them be struck pursuant to Rule 3.68 of the Alberta Rules of Court. Under Rule 3.68(2), a claim may be struck if a pleading discloses no reasonable claim; if a pleading is frivolous, irrelevant or improper; or if a pleading constitutes an abuse of process. Justice Rooke examined each ground for striking Onischuk’s claim and found that it could be struck on all three bases.

Justice Rooke also went on to consider whether summary judgment was warranted in the circumstances. He concluded that it would have been available in the alternative, had the claims not been struck (at para 50).

Comments

A Rather Typical Vexatious Litigant

In the introduction to this post, I characterized Onischuk as “a rather typical vexatious litigant.” In doing so I was referring to two recent law review articles which sort vexatious litigants into two categories: Didi Herman, “Hopeless cases: Race, racism and the ‘vexatious litigant’” (2012) 8(1) International Journal of Law in Context 27, and Christian Diesen, “The Justice Obsession Syndrome” (2007-2008) 30 Thomas Jefferson Law Review 487. Herman is a Professor at Kent Law School in the UK. Diesen is a Professor of Procedural Law at Stockholm University in Sweden (where a person who become a vexatious litigant as a result of a loss in court is called rättshaverist or a “wreck of justice” (Diesen at 488-89).

In her study of the individuals declared to be “vexatious litigants” in the UK and her review of the vexatious litigant literature, Herman noted (at 28) that people declared to be vexatious litigants can be broadly sorted into two groups: (1) those with histories of mental health problems who launch multiple legal actions against diverse targets, and (2) those whose initial legal action was resolved against them, and who then attempt to carry on with aspects of that complaint in various ways. From the facts summarized by Justice Rooke, Onischuk appears to be a classic example of the second type of vexatious litigant as the series of actions summarized in the Appendix to Onischuk can be traced back to one instigating dispute, the 2005 CNR derailment. In the case of this second type of vexatious litigant, Herman argues that we can understand their litigation as being about a passionate search for justice, as opposed to, or at least as well as, an “obsession.”

Herman focuses on two overlapping elements or themes of vexatious litigation: persistence or obsession, and hopelessness. Vexatious litigants refuse to accept the results of their initial trials and appeals and their continued persistence is taken as evidence of their unreasonableness. Their refusal to accept a matter is over is a failure to adopt the judges’ perspectives on the injury. Linked to judges’ disapproval of vexatious litigants’ persistence and obsession is their understanding that the vexatious litigants’ cases are hopeless. As Herman notes (at 39), “[i]t is the persistence in the face of this hopelessness that the courts find so hard to fathom, and that becomes evidence of unreasonableness.” Linked to the hopelessness of the litigation is judges’ view that the excessive litigation is all extremely wasteful. We can see an example of this in Justice Rooke’s judgment in Onischuk (at para 35):

To allow Onischuk to continuously bombard counsel, the judiciary, and this Court with lengthy pleadings, replete with inflammatory accusations, irrelevant legal argument, jurisprudence and legislation, that advance no reasonable cause of action, is manifestly unfair to all parties involved and other participants vying for scarce judicial resources. Consequentially, to allow this action to proceed would surely bring the administration of justice into disrepute (emphasis added).

Herman argues (at 40) that hope is about more than the rational assessment of legal prospects. Many of the vexatious litigants in her study appeared to recognize quite clearly that the legal system was unlikely to deliver justice in their case, but they were prepared to go on despite lack of this type of hope. They may have other kinds of hope they are pursuing.

Herman also found that many litigants refused to accept that a declaration that they were vexatious litigants terminated their pursuit of justice. They returned to court on their behalf or on behalf of others. They blog, post YouTube videos, and participate in online “victims of injustice” communities. Perhaps those online “victims of justice” communities lead them to “organized pseudolegal commercial argument” gurus.

Along very similar lines, Diesen (at 491) distinguishes between persons with querulous behaviour and persons with justice obsession syndrome. The core of justice obsession is the experience of justice denied and thus the starting point for the syndrome is “a legal decision or judgment against the complainant or the seeking of a legal decision to establish justice without the support of legal professionals” (at 492). With regard to this type of vexatious litigant, Diesen questions whether the legal system has a tendency to create these fixated losers. He also asks whether the syndrome might be a symptom of legal disorder, i.e., a way to identify the disadvantages of certain procedural rules.

A Rather Quick Response

I had also suggested in the introduction to this post that Onischuk was perhaps found to be a vexatious litigant more quickly than normal. The vexatious litigant provisions in Alberta’s Judicature Act require persistence, or a prolonged or insistently continuous quality. In the first five years following the 2007 amendments to those vexatious litigation provisions, it appeared that vexatious litigant orders were only being granted in extreme cases. As I noted in an earlier post — “How persistent does a vexatious litigant have to be?” (July 27, 2011) — it seemed to take a lot of improper behaviour against a large number of long-suffering defendants for a very long time (more than ten years in the case commented upon) before a person was denied unmediated access to a court.

In Onischuk’s case, the time from his initial loss to his being found a vexatious litigant was just over three years (October 2009 to November 2012). In Onischuk there were fewer years of litigation, fewer court actions, fewer interlocutory proceedings, and fewer unpaid cost awards than in many previous cases where people have been found to be vexatious litigants.

If I were to speculate, I might suggest that the relatively shorter time line may be because Justice Rooke, in his role of Associate Chief Justice of the Court of Queen’s Bench and as the author of Meads v Meads, 2012 ABQB 571, has much more familiarity with vexatious litigation than most judges and is therefore more willing to put an end to it when it is identified. It may also be that Onischuk picked the wrong defendants. Justice Rooke characterized part of the content of Onischuk’s pleadings as “inflammatory accusations and ever expanding conspiracy theories against Counsel who have argued, and the Judiciary who have heard his applications” (at para 14). Lawyers and judges have relatively easy access to all available judicial remedies for vexatious litigation.

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About Jonnette Watson Hamilton

B.A. (Alta.), LL.B. (Dal.), LL.M. (Col.). Professor. Member of the Alberta Bar. Please click here for more information.
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7 Responses to A Rather Quick Response to a Rather Typical Vexatious Litigant

  1. Student says:

    I applaud the swift and decisive action taken in this case, and others. Let us hope that ACJ Rooke and his colleagues continue to send a clear an unequivocal message that the Court system will not be bogged down with this kind of conduct, with the same measure of rapidity.

  2. David Laidlaw says:

    As a defendant in a number of these cases, I applaud this move. As a lawyer I could always rely on Alberta Legal Insurance Association (ALIA) to prosecute a defence but even then the “psychic toll” of reporting yourself in an appropriate case and a lawsuit was telling. I shudder to think what it was like for some of the other defendants without insurance.

    Further, if the speed with which this was resolved was telling, and I do believe it is more rapid (see the long running Rose Marie Watts case(s)) then scarce judicial resources can be directed towards cases like Dani Polsom, the Airdrie teen who’s sexual assault trial was dismissed. The argument over how much and why is another matter but if this decision conserves those resources it is a good thing.

  3. Shaun Fluker says:

    Thanks for following and analyzing this area Jonnette. Another great reason why Ablawg is such an excellent legal resource. The facts here, however, lead me to suggest a word of caution on this developing vexatious litigant line of jurisprudence in Alberta.

    I note that it took CNR 4 years to plead guilty – surely the cause of some aggravation here for the applicant. And that most of the applicant’s troublesome acts took place after that guilty plea. I wouldn’t be surprised if the applicant was repeatedly told in advance of his pleadings there was no cause of action on behalf of the polluted environment here. Perhaps this is why he chose to initiate a cause of action alleged harm to himself. No doubt a tough argument – but nonetheless with maybe no legal counsel willing or able to help him construct something else and being frustrated that little appeared to be happening for 4 years after the spill he went forward with what he thought was an arguable case? As for what happened after 2009 – the legal system in Alberta for environmental plaintiffs can be a frustrating place that can easily lead someone to appear obsessed with justice.

    I am reminded of how many times Martha Kostuch tried to prosecute the Alberta government for going ahead with the Oldman River Dam – seemingly banging her head against an Alberta Justice policy that only the Attorney General prosecutes in this province – I wrote about this on Ablawg back in 2008 – I wonder if Martha would be seen as vexatious today – someone obsessed with justice? I hope this line of jurisprudence is carefully developed and does not become yet another hurdle for environmental plaintiffs in Alberta.

  4. Jonnette Waston Hamilton says:

    You make a good point, Shaun. I think you may be correct to suggest that the line between cause “lawyering” for environmental issues and vexatious litigation may be a difficult one to draw some times. The “typical” vexatious litigant category into which Mr. Onischuk appears to fall is that described by Professor Herman as being about a passionate search for justice. How can that type of litigious conduct be distinguished from what is called “cause lawyering” when done by those with a license to practice law? (See Austin Sarat and Stuart Scheingold, eds., The Worlds Cause Lawyers Make: Structure and Agency in Legal Practice (Stanford Law and Politics; 2005) and Gerald N. Rosenberg, The Hollow Hope: Can Courts Bring About Social Change?, 2nd ed. (University Of Chicago Press, 2008).)

    I did not mention it in this post, but when Justice Rooke declared (at para 54) Mr. Onischuk to be a vexatious litigant requiring the court’s permission to commence or continue any court proceedings in Alberta, he excepted out Mr. Onischuk’s then ongoing Queen’s Bench Action #1101 14786, Onischuk v Canmore. That case is the Canmore rabbit injunction case that received quite a bit of media attention recently and it is even more relevant to the points you made.

    According to various media accounts and Mr. Onischuk’s web site at http://canmorerabbits.ca/index.html, Mr. Onischuk, described as a “an Edmonton photographer and rabbit advocate,” sought an injunction against the Town of Canmore’s proposed cull of its feral rabbit population (see “Court OKs Canmore rabbit cull”, CBC News, 14 November 2011 at http://www.cbc.ca/news/canada/calgary/story/2011/11/14/calgary-rabbit-canmore-cull.html). However, Court of Queen’s Bench Justice Hawco concluded: “I am satisfied you have no standing and this is an inappropriate use of the courts and is in fact an abuse of the process” and awarded costs to the Town of Canmore. Apparently the Town’s lawyer argued that Mr. Onischuk did not have sufficient interest for the court to hear the application and that it was an abuse of process because Mr. Onischuk was asking the courts to enforce statutes that are within the government of Alberta’s responsibility to enforce. But lack of standing, the issue of having “sufficient interest,” and a government monopoly on the enforcement of environmental statutes seem to be perennial problems in environmental law, as you have noted, Shaun, in a number of your ABlawg posts such as “Environmental Private Prosecution Update: John Custer v. Syncrude Canada,” “The problem of Locus Standi at the Energy Resources Conservation Board: A Diceyan solution”, and “Standing Against Public Participation at the Alberta Energy and Utilities Board.”

    Mr. Onischuk appealed Justice Hawco’s decision to the Alberta Court of Appeal and that appeal was heard April 3, 2013. According to News Talk 770, that appeal was dismissed on April 22: see http://www.newstalk770.com/News/Local/Story.aspx?ID=1942557. The radio station reports that the Alberta Court of Appeal agreed that Mr. Onischuk’s action was an abuse of process, noted that Mr. Onischuk has a tendency to relitigate matters, and directed that he not be allowed any further appeal relating to the rabbits without prior approval from one of the appeal court justices.

  5. sandra Olson says:

    To deny someone access to the court, is a serious violation of that persons rights. In my case, I was declared vexatious, and my case without merit. No one permitted examination of the evidence, no examination of the facts at all. The courts just did not like what I had to say about the dna industry and how the courts are responsible for allowing it in without regulation and verifiable standards. It appears that sometimes the declaration of vexatious is how the courts try to “shut up” anyone who makes critical comments about them. I have been trying to point out that dna industry results cannot be examined unless the entire file is released to BE examined. The courts refused to order this release. No examination of evidence is the most basic denial of a person right to question evidence that stands against them. If I keep fighting this massive injustice, I hope you understand. If you had been framed by poor science, and judged by it and courts refuse to hear you ask for their help, what would you do.

  6. Shawn Jordan says:

    The word vexatious was removed from the wording in rule 129 when it evolved to rule 3.68 in November of 2010. All of the lawyers and decisions after November 2010 that rely upon rule 3.68 to discard a claim as vexatious is bad law practice.

    Remember the courts belong to the people, if a want of competence exists becase a litigant (self represented or represented) is not presenting their case or defence properly then they should receive some proper help.

    Remember approximately 70% of all people who use the justice system have not completed grade 12. The justice
    system is supposed to be high school equivalency friendly.

    Surely we assist (h_l_ ) our fellow citizens who are using our multi billion dollar predominantly publically funded and supported legal system.

  7. Jonnette Watson Hamilton says:

    Mr. Jordan is mistaken about the source of the “vexatious” wording. It comes from the Judicature Act, RSA 2000, c J-2, and not Rule 3.68 of the Alberta Rules of Court. The Judicature Act, despite being amended in June 2007, still uses the word “vexatious” as in “vexatious proceedings” and “vexatious manner”; see Part 2.1 in the Judicature Act.

    I agree with Mr. Jordan that low education and literacy levels are part of the access to justice problem confronting Canada and Canadians. I disagree with his implicit suggestion that a disproportionate portion of vexatious litigants have less than a Grade 12 education. There is nothing in the literature that I am aware of that indicates a lack of either formal education or functional literacy is the cause of vexatious proceedings.

    He says “Remember approximately 70% of all people who use the justice system have not completed grade 12” but does not indicate where he got that number from. There are a number of different reports that provide statistics on the intersection of access to justice and education levels, but none of those statistics are very close to the “approximately 70%” figure that he mentions. Dr. Julie Macfarlane recently looked at education levels among Canadian self-represented litigants (and self-represented litigants are NOT vexatious litigants, but Mr. Jordan mentions self-represented litigants); see “The National Self-­Represented Litigants Project: Identifying and Meeting the Needs of Self-­Represented Litigants” Final Report May 2013 at pages 29-31. Fifty (50%) percent of her self-represented litigant sample report having a university degree. On the other hand, according to the Literacy and Policing Project, 79% percent of imprisoned Canadians do not have their high school diploma, a figure much closer to the Mr. Jordan’s 70%, so perhaps he was referring to the prison population. The difference between the education levels of those caught up in the civil and the criminal systems may be, at least in part, because people can often choose whether or not to become involved in the civil justice system, but they have no choice about getting involved in the criminal justice system once arrested. If you look at the general Canadian population as a whole, Macfarlane notes at page 30 that Statistics Canada reported in 2008 that 58% of 25-34 year olds across Canada had a college or university education, and 40% of 55-64 year olds. On the other hand, and regardless of education levels, according to Literacy Alberta, 40% of adult Albertans and 35% of working age Albertans do not have the basic literacy skills they need to get ahead in today’s demanding society and economy.

    As for Mr. Jordan’s point that litigants should receive some proper help, there are a large number of people and organizations working to provide hands-on help of a specific nature. As just one small example, I commend the work of the Justice Sector Constellation of the Calgary Poverty Reduction Initiative (see http://www.enoughforall.ca/). Their Final Report lists the issues, the resources, the goals and a time line for achieving those very practical goals that take supportive initiatives out of the court rooms and boardrooms and put them where the people who need them live and work. While not all self-represented litigants represent themselves for financial reasons, low-income people are more susceptible to legal issues for the reasons the Justice Sector Constellation notes. Their report also has links to other Canadian reports on access to justice, other recommendations, and other ways to get involved.

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