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Category: Administrative Law Page 36 of 37

The Metaphysical Court: Dunsmuir v. New Brunswick and the Standard of Review

Cases Considered: Dunsmuir v. New Brunswick, 2008 SCC 9

PDF Version: The Metaphysical Court: Dunsmuir v. New Brunswick and the Standard of Review

Introduction
The standard used by courts to review administrative decision-making is of central importance to energy and resource development law. Key decisions about regulation of utilities, supervision of energy markets, development of energy projects and facilities, and environmental obligations imposed on resource development, are authorized by legislation, and made and implemented by regulatory authorities. While for the most part, most of the time, the focus of everyone involved is simply on the making and implementing of those regulatory decisions, the courts retain the constitutional power to review and ultimately control this exercise of regulatory authority. Thus, the question of how the courts will exercise that power – the level of deference they will employ and how willing they will be to override regulatory decision-makers – is the fundamental backdrop against which these decisions are made.

Supreme Court denies leave to appeal in Real Estate Council of Alberta v. Henderson

Cases Considered: Real Estate Council of Alberta v. Henderson, 2007 ABCA 303

On March 27, 2008 the Supreme Court of Canada denied Henderson leave to appeal. This result is not surprising given that the Alberta Court of Appeal characterized the issue in Henderson as seemingly straightforward statutory interpretation. However, the denial of leave is disappointing as the case is now an opportunity lost for judicial consideration into the merits of an administrative decision-maker impeaching its own decision.

For the original post on Henderson, click here.

Just a Bump on the Road to Socio-Ecological Ruin: Federal Court Finds Error in Kearl Oil Sands Project Environmental Assessment

By: Shaun Fluker

PDF Version: Just a Bump on the Road to Socio-Ecological Ruin: Federal Court Finds Error in Kearl Oil Sands Project Environmental Assessment

Case Commented On: Pembina Institute for Appropriate Development v Canada (Attorney General), 2008 FC 302

In late 2006, media attention in Alberta was directed to the Regional Municipality of Wood Buffalo, home to the Alberta oil sands and boom town Fort McMurray as the modern rendition of the 1800s frontier gold rush. Apparently, the Municipality was about to cook the goose that had laid the golden egg.

The Shotgun Approach to Judicial Review

Cases Considered: Weir v. Canada (Registrar of Firearms), 2008 ABPC 18, Woodcock v. Canada (Registrar of Firearms), 2008 ABPC 19

PDF Version: The Shotgun Approach to Judicial Review

These two almost identical judgments of Provincial Court Judge Bruce R. Fraser confirmed refusals by the Registrar to issue registration certificates for prohibited weapons. They were both references made pursuant to section 74 of the Firearms Act, S.C. 1995, c. 39. The standard of the review to be conducted by a provincial court judge in such a reference has been a controversial matter. Various methods for selecting the appropriate standard of review in a section 74 reference have been proposed and implemented by Alberta courts. The jurisprudence thus far suggests this shotgun approach is missing the mark when it comes to standard of review.

City Amends Land Use Bylaw in Bad Faith

Cases Considered: Airport Self Storage and R.V. Centre Ltd. v. Leduc (City), 2008 ABQB 12

PDF Version: City Amends Land Use Bylaw in Bad Faith

Although municipal councils in Alberta are generally entitled to amend land use bylaws by following procedures set out in the Municipal Government Act (the “MGA”), R.S.A. 2000, c. M-26, this decision tells us that sometimes a council will have to go further in order to ensure procedural fairness. There are circumstances where personalized written notice of a hearing to consider a proposed land use amendment will be required. As always, the content of the duty of fairness varies according to the particular facts of each case. The facts here are lengthy, but they are critical.

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