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Category: Constitutional Page 54 of 71

Leave to Appeal Granted in Street Preacher Case

PDF version: Leave to Appeal Granted in Street Preacher Case 

Case considered: R v Pawlowski, 2011 ABCA 267

On September 27, 2011, Justice Patricia Rowbotham of the Alberta Court of Appeal granted Artur Pawlowski leave to appeal certain elements of the decision in R v Pawlowski , 2011 ABQB 93 (per Justice R.J. Hall). (For a description of the facts, the laws that are being constitutionally challenged by Pawlowski, and the decision appealed from see here). Pawlowski’s challenges to City of Calgary bylaws restricting his street preaching activities were largely successful at the Alberta Provincial Court level (see R v Pawlowski, 2009 ABPC 62 and here), but he lost some ground in the City’s summary conviction appeal to the Court of Queen’s Bench. Pawlowski sought leave to appeal (1) the Queen’s Bench decision granting an extension to the City of Calgary to serve its Notice of Appeal on Pawlowski, and (2) his conviction under section 21 of the City’s Parks and Pathways Bylaw, 20M2003 (using an amplification system in a park), arguing that Justice Hall made several errors in his decision. It appears the City has not sought leave to cross-appeal Justice Hall’s holding that section 17(1)(a) of its Street Bylaw (placing material on a street) violated Pawlowski’s section 7 Charter rights because it was vague and overbroad. This post will review Justice Rowbotham’s decision to grant leave, and consider the issues for appeal in light of the Supreme Court of Canada’s recent judgment in Canada (Attorney General) v PHS Community Services Society, 2011 SCC 44, released on September 30, 2011.

Alberta Court of Queen’s Bench finds Personal Information Protection Act, Regulations, section 7 Unconstitutional

PDF version: Alberta Court of Queen’s Bench finds Personal Information Protection Act, Regulations, section 7 Unconstitutional 

Decision considered: United Food and Commercial Workers, Local 401 v Alberta, 2011 ABQB 415 (“UFCW“)

This decision is interesting because it illustrates the interplay between the Canadian Charter of Rights and Freedoms (“Charter“) subsection 2(b) freedom of expression, and Alberta’s privacy legislation. The employees of Palace Casino in West Edmonton Mall were on strike, and both the United Food and Commercial Workers, Local 401 (“Union”) and the employer photographed and videotaped the picket line. People who crossed the picket line and those who walked in and out of the casino were also photographed or taped. The Union posted a sign which stated: “by crossing the picket line you are providing your consent for your image to be posted at www.CasinoScabs.ca“. The employer’s Vice President complained to the Privacy Commissioner that his photo was displayed on a poster at the picket site, in the Union’s newsletter and on pamphlets distributed at the site. Two other complainants who crossed the picket line said that they had been photographed or videotaped, although they never saw any images. The Office of the Privacy Commissioner’s Adjudicator accepted that it was a long-standing historical practice for Unions and employers to photograph and videotape at picket line sites (UFCW, para 6).

No Advance Costs Awarded on Charter Application

PDF version: No Advance Costs Awarded on Charter Application

Case considered: D.W.H. v D.J.R., 2011 ABQB 119

Mr. H. and Mr. R. lived together as partners and planned to have a baby through a surrogate mother. The baby lived with the two male partners and visited the surrogate mother once or twice a week. The couple separated and Mr. H. applied for access. Madame Justice K.M. Eidsvik in D.W.H. v D.J.R., 2009 ABQB 438 found that the child had a mother (who was the surrogate), but no father who would be recognized in law (see Melissa Luhtanen, Gay Fathers Not Seen as Parental Unit Under Family Law Act). Mr. H. was given access to the child and later, Mr. R. successfully applied to become the child’s guardian. Mr. H. also applied for guardianship but his application was opposed. Mr. H. proceeded to make a section 15 Charter challenge to the validity of relevant sections of the Family Law Act, SA 2003, c. F-4.5 (“FLA“) and Vital Statistics Act, RSA 2000, c. V-4 (“VSA“). In that application, Mr. H. is arguing that these sections discriminate against him on the grounds of gender and sexual orientation. The present application is for advance or interim costs in order for Mr. H to retain counsel for the constitutional argument.

French Language Rights in Alberta Get a Boost

PDF version: French Language Rights in Alberta Get a Boost 

Case considered: R v Pooran; R v Vaillant, 2011 ABPC 77

Significant consequences can arise from what might otherwise have appeared to be just another mundane case; in this instance, charges under Alberta’s Traffic Safety Act, R.S.A. 2000, c. T-6. The facts and charges that led to Sonia Pooran and Guy Vaillant standing trial before a provincial court judge on April 14 are not important. What is important is that the entire proceedings will be in French, after a provincial court judge in Calgary decided they have that right.

A National Securities Regulator? – No way! says the Alberta Court of Appeal

PDF version: A National Securities Regulator? – No way! says the Alberta Court of Appeal 

Case considered: Reference Re Securities Act (Canada), 2011 ABCA 77

Can the federal government pass legislation to establish and empower a national securities regulator? Essentially, this is the question referred by the Alberta Cabinet to the Alberta Court of Appeal. Specifically, the question relates to the draft National Securities Act, Sessional Paper No. 8 525-403-10. The National Securities Act would mean federal regulation of participants in the Canadian securities industry, federal disclosure rules and limits for raising money from the public, federal regulation of the trading of securities, and federal monitoring and enforcement of these rules to protect the public.

This question, the Alberta Court of Appeal answered with a resounding “No”.

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