In the period September to November 2019, six complaints were filed against Ottawa City Councillor Richard Chiarelli with the Integrity Commissioner for the City of Ottawa. The Commissioner investigated and then prepared one report in respect to three of the complaints, which were similar. The Commissioner filed the Report with Ottawa City Council on July 9, 2020. City Council considered the Report on July 15, 2020, accepted its conclusions that Councillor Chiarelli had engaged in acts of misconduct in respect to the three complaints, and imposed the maximum available penalty: suspending Councillor Chiarelli’s salary for 270 days in the aggregate. City Council also adopted a resolution calling upon Councillor Chiarelli to resign from City Council.
Councillor Chiarelli applied to the Ontario Divisional Court for judicial review of the proceedings below. He argued that the Commissioner lacked jurisdiction to investigate the complaints, showed bias against him, and denied the Councillor procedural fairness. He argued that City Council exhibited bias against him. He sought various remedies, including orders quashing the findings and sanctions against him and orders prohibiting the respondents from taking further steps against him respecting the complaints.
In its decision released December 22, 2021, Chiarelli v. Ottawa (City of), 2021 ONSC 8256 (CanLII), the Divisional Court (Morawetz C.J.O.S.C.J., D.L. Corbett and Ryan Bell JJ.):
- Dismissed the application as against the Commissioner, with costs payable by Councillor Chiarelli to the Commissioner fixed on a partial indemnity basis at $40,000, inclusive, payable within thirty days;
- Granted the application as against the City of Ottawa;
- Quashed the sanction decision of City Council, with costs payable by the City of Ottawa to Councillor Chiarelli fixed at 50% of partial indemnity costs, in the amount of $20,000, inclusive, payable within ten days of the date on which Councillor Chiarelli pays the $40,000 in costs he owes to the Commissioner; and
- Imposed a sanction on Councillor Chiarelli of suspension of salary for 270 days in the aggregate.
Facts
Between September 6 and October 8, 2019, the Commissioner received three similar complaints from three different interviewees, alleging that Councillor Chiarelli violated ss. 4 and 7 of the Code of Conduct during their job interviews:
Complaint 1: During a job interview, Councillor Chiarelli asked the complainant what she would be willing to wear on the job, including whether she would go “bra-less” and if she was comfortable showing her arms and legs. The Councillor showed her inappropriate photographs on his phone of former staff and explained how attractive women are important to gather information and attract volunteers by getting men to hit on them.
Complaint 2: During a job interview, the Councillor discussed recruiting volunteers (specifically young men) at nightclubs, indicating that recruitment works best if the individual is not wearing a bra, and asked if the complainant would be willing to go to nightclubs not wearing a bra to recruit young men.
Complaint 3: During a job interview, Councillor Chiarelli made inappropriate comments about the complainant’s body and asked her inappropriate questions including whether she would consider stripping (because of her dance experience) and whether she had participated in “World Orgasm Day”.
Councillor Chiarelli did not participate in the Commissioner’s investigation. For a period of roughly nine months, the Commissioner sought responses and participation from Councillor Chiarelli. Aside from a bald denial issued as a public statement on October 3, 2019, the Councillor provided no substantive response and would not confirm that he would ever provide a response.
The Integrity Commissioner’s Report
In his report, the Commissioner provided the chronology of the complaints and the investigation, as well as the communications between the Commissioner and Councillor Chiarelli’s counsel. The Commissioner set out his conclusion, based on the correspondence, that Councillor Chiarelli had no intention of participating in the investigation. The Commissioner also set out his decision to use Councillor Chiarelli’s public denial as his evidence in the investigation.
The Commissioner found the complainants’ evidence to be credible and concluded that the public denial published by Councillor Chiarelli was “simply not credible.”
The Commissioner concluded, on a balance of probabilities, that the conduct of Councillor Chiarelli in interviewing and seeking to recruit the three complainants for employment did not serve the interest of his constituents. Nor, in interviewing and seeking to recruit the three complainants, was Councillor Chiarelli acting in a conscientious and diligent manner. The Commissioner found that in the interviews of complainants 1 and 2, Councillor Chiarelli told them that he was planning to objectify the complainants by using their sexuality to recruit male volunteers to assist in his re-election efforts. Finding that “[n]one of this serves the public good. None of this meets the definition of the word ‘integrity[,]” the Commissioner found that the allegations were made out and that Councillor Chiarelli had breached ss. 4.1 and 4.4 of the Code of Conduct in respect of each of the three complainants. The Commissioner also found that Councillor Chiarelli had breached s. 7 of the Code of Conduct. The Commissioner found, on a balance of probabilities, that Councillor Chiarelli made comments to and asked questions of the complainants that were sexual in nature or focused on women’s bodies.
The Report then sets out the Commissioner’s recommendations with respect to sanctions and other corrective actions. The Commissioner considered the following principles with respect to sanctions for violation of the Code of Conduct:
a. sanctions are normally progressive in their severity;
b. sanctions depend on the experience of the Councillor;
c. how flagrant was the behaviour; and
d. whether there is any acknowledgement of wrongdoing, remorse or regret.
The Commissioner concluded that “because the Councillor is the longest serving elected public office holder on Council and that this offensive and disreputable behaviour has been going on for a very long time”, the most severe of sanctions was warranted.
The Commissioner therefore recommended that City Council receive the Report, including the finding that Councillor Chiarelli had contravened ss. 4 and 7 of the Code of Conduct, and consecutively impose a suspension of Councillor Chiarelli’s remuneration for 90 days in respect of each of the complaints.
Decision of Ottawa City Council
The Report was placed on the agenda for the meeting of City Council on July 15, 2020. The Commissioner attended that meeting and responded to questions posed to him by Councillors about the Report and his recommendations.
The Report noted that, pursuant to s. 5(2.1) of the Municipal Conflict of Interest Act, Councillor Chiarelli would have the opportunity to respond to the Report by participating in the debate when City Council considered the Commissioner’s recommendations. Councillor Chiarelli was present but did not address City Council on July 15, 2020.
The motion to receive the Report and to impose consecutive 90-day suspensions of the remuneration paid to Councillor Chiarelli in respect of his service as a member of Council for each of the three complaints, for a total of 270 days, was passed by Council unanimously. Council voted that the suspension of remuneration would commence on August 14, 2020.
Councillor Chiarelli then commenced an Application for Judicial Review to the Ontario Divisional Court, making myriad allegations about the Commissioner’s lack of jurisdiction and allegations of bias as against both the Commissioner and City Council. Interestingly, Councillor Chiarelli did not allege that the findings and conclusions of the Commissioner were unreasonable.
Decision of the Ontario Divisional Court
With respect to Councillor Chiarelli’s allegation that the Commissioner was biased against him, the Court began its analysis by noting that Councillor Chiarelli had not raised the issue of alleged bias prior to commencing his application for judicial review. Wrote the court on this point, “this failure is fatal to his pursuing the issue before us.”
As to why such failure is fatal, the court said,
[78] This is no mere technicality. An allegation of bias impugns the integrity and conduct of the person against whom it is made. That person is not a party to the underlying conflict, and the allegation, by its nature, seeks to cast a neutral party into the conflict itself. That person is entitled to respond to the allegation and, where the allegation of bias is rejected, to explain why they are not biased in fact, and why their conduct does not give rise to a reasonable apprehension of bias. Usually, this is the only chance the person has to respond to serious allegations made against them. If this issue is then pursued on judicial review, it is the task of this court to review the decision on the bias issue – a task we cannot perform since the issue was not raised with the Commissioner and so he has not made a decision on the issue that we can review.
The court went on to consider the Commissioner’s conduct and concluded “There is nothing to ground allegations of bias or reasonable apprehension of bias against the Commissioner, who discharged his job with patience and professionalism.”
On the other hand, and with respect to Councillor Chiarelli’s allegation that City Counsel was biased against him, the Court did have reservations.
In its opening comments on the subject, the Court observed that “the standard of conduct expected of City Councillors is not the same as that expected of a judge or tribunal member. When faced with reports of shocking and unacceptable behaviour by another Council member, members of Council can be expected to react. They can be expected to ask questions. They can be expected to speak for their constituents and for the City they lead.” However, the court went on to caution “when City Council is called on to adjudicate, it should bring itself back to the decision at hand with an open mind on the basis of the record and the applicable principles.”
At paragraphs 10-12 of its reasons, the court held that:
[10] The role of an elected representative and civic leader and the role of an adjudicator are not incompatible. In assigning an adjudicative role to City Council, the Legislature must be taken to have done so knowing that members of Council are not independent and neutral in the way that judges are. But, having been assigned this adjudicative role by the Legislature, members of Council are required to keep an open mind and to be seen to keep an open mind.
[11] We find that the answer lies in the process required of City Council when it embarks on an adjudicative function. Where a matter has engendered significant public interest and has led some City Councillors to conduct themselves in a manner that suggests predetermination of the issue before them, and where an allegation of bias has been made against City Council and some of its members, members of Council should remind themselves formally and publicly of the nature of the task before them and their responsibility to act with an open mind as adjudicators. In this case, certain members of Council did not do this.
[12] In our view, the combined effect of the conduct of some members of City Council and the absence of a formal and public commitment by members of City Council to set aside their preconceptions to decide the matter before them with an open mind, in the overall charged context in which this all took place, must lead to a finding of a reasonable apprehension of bias on the part of City Council. For this reason, Council’s sanctions decision must be quashed.
In impugning the comments made by and conduct of City Councillors prior to the completion of the Commissioner’s investigation the Court took note of the following actions:
- In September 2019, shortly after the allegations against Councillor Chiarelli were made public, Mayor Watson and one Councillor issued a public statement in support of the women who had come forward with their allegations. Another Councillor agreed with their statement and reposted it to her Twitter account.
- Three other Councillors also issued a joint statement in which they commended the complainants for coming forward and called on Councillor Chiarelli to “resign and immediately apologize” if the allegations were true. Two Councillors publicly stated that they believed the allegations against Councillor Chiarelli were true.
- On October 19, 2019, Mayor Watson is reported to have said to the media: “As more allegations come forward, it becomes more disgusting and very upsetting as to what was going on in his office, for what appears to be many, many months if not years.”
- At the Council meeting on November 6, 2019, one Councillor refused to sit at the Council table while Councillor Chiarelli was present.
- Following the Council budget meeting, the Mayor stated that Councillor Chiarelli’s presence at the meeting made Council “extremely uncomfortable” and that most members of Council, including himself, did not want to be seen near him.
- Another Councillor stated on his Twitter account: “I support city staff who are protesting the return of Councillor Chiarelli. They want a safe and secure workplace.”
- Three weeks later, on November 27, 2019, Mayor Watson publicly stated: “My hope is that Mr. Chiarelli makes a decision. Either he decides he’s going to come back to work, which he’s been paid for the last several months, or he decides to resign.”
- Approximately two weeks later, the Mayor told the media that Council was no longer willing to work with Councillor Chiarelli and that the Councillors who had been assisting with his ward duties while Councillor Chiarelli was dealing with medical challenges no longer wanted to be associated with his office. Shortly thereafter, Mayor Watson again called for Councillor Chiarelli’s resignation: “Do the honourable thing and step down, and move on with your life… This is a situation that’s not going to go away until he goes away.”
- During the Council meeting of December 11, 2019, all members of Council but three – the Mayor and two Councillors – refused to sit at the Council table while Councillor Chiarelli was present. The same Councillor who had also refused to sit at the Council table on November 6, 2019 posted a photo on her Twitter account with the following quote: “Stand up for what is right, regardless of who is committing the wrong.” Mayor Watson later stated that he was standing “in spirit” with the rest of Council. One of the two Councillors who remained seated on December 11 subsequently issued a statement in which she noted that it was extremely important for Council to refrain from acting in a manner that could jeopardize the investigatory and adjudicative process by giving the impression that they had prejudged the outcome.
In resolving that such comments and conduct demonstrated a reasonable apprehension of bias on the part of City Counsel, the court wrote the following:
[146] It is useful to reiterate here the dual role that members of City Council, including the Mayor, are required to fulfill. As elected representatives, Councillors are expected to express and act on their views on a wide variety of issues. They are political actors: they have been elected by the voters to represent particular points of view and they are expected to speak for their constituents: Old St. Boniface Residents Assn. Inc. v. Winnipeg (City), [1990] 3 S.C.R. 1170, at 1197.
[147] Members of Council also have an adjudicative role. Councillors were acting in their role as adjudicators when they decided to impose the sanctions recommended by the Commissioner. While Council’s discretion as to the appropriate sanction is limited by the Municipal Act, 2001, its function remains adjudicative. And though members of Council are not restrained from their political role, and may speak for their constituents, even in respect to a matter in respect to which they will perform an adjudicative role, that does not mean that there are no limits that apply. As Sopinka J. wrote in Old St. Boniface Residents Assn. v. Winnipeg (City):
In my opinion, the test that is consistent with the functions of a municipal councillor and enables him or her to carry out the political and legislative duties entrusted to the councillor is one which requires that the objectors or supporters be heard by members of Council who are capable of being persuaded…. The party alleging disqualifying bias must establish that there is a prejudgment of the matter, in fact, to the extent that any representations at variance with the view, which has been adopted, would be futile. Statements by individual members of Council while they may very well give rise to an appearance of bias will not satisfy the test unless the court concludes that they are the expression of a final opinion on the matter, which cannot be dislodged….[148] In his written submissions, counsel for the Councillor argued that Council performs an adjudicative function in determining whether a fellow Councillor breached the Code of Conduct and then, if necessary, imposing a penalty. This is incorrect. Under the statutory scheme, it is the Commissioner who, following an investigation, determines if the complaint is sustained. Where the complaint is sustained, in whole or in part, the Commissioner is required to report to Council with his findings and any recommended corrective action. Council’s duty is to “consider and respond to the report.” In this case, City Council voted to receive the Report and to impose the sanctions recommended by the Commissioner.
[149] The public statements by Councillors about their belief in the complainants’ stories and the Councillor’s comment supporting City staff in wanting a safe and secure workplace do not support a conclusion that Council had closed its mind and predetermined the outcome. These statements were made to reassure their constituents and victims who come forward, and to reassure City staff of Council’s commitment to a safe and secure work environment. Comments at the outset that some Councillors “believed the complainants” could be seen predeterminations, but we are not satisfied that they reflect a closed mind, especially given the nature of the allegations and the position of the complainants.
[150] We see the refusal of the majority of Council (supported by the Mayor “in spirit”) to sit at the Council table with Councillor Chiarelli and the calls for him to resign in a different light. One of the Councillors who remained seated on December 11, 2019 recognized that Council’s conduct could give the impression that Council had prejudged the outcome. Given that the penalties that Council may impose are limited to a reprimand or a suspension of remuneration for a period of up to 90 days, demands that Councillor Chiarelli resign – a penalty not even available to Council – before the Commissioner had completed his investigation, give the appearance of prejudgment on the issue of sanction. When it is recalled that the issue of sanction was the point of decision for Council – not the veracity of the complainants (which was in the domain of the Commissioner), evidence of predetermination of sanction impugns the adjudication that Council was obliged to perform.
[151] As political actors, Councillors are expected to express their views and preconceptions, particularly on a matter such as this that has engendered significant public interest. When, however, the matter comes before them in their capacity as decisionmakers, it is important that the Councillors remind themselves of their responsibility to adjudicate fairly and with an open mind on the matter before them. With the one exception, members of Council did not do so. In our view, the combined effect of the statements by Councillors demanding Councillor Chiarelli’s resignation, their refusal to sit with him at the Council table, and the absence of their commitment to set aside their preconceptions and to decide the issue of sanctions based on the Commissioner’s Report and findings, the applicable principles, and their consideration of these matters (including anything Councillor Chiarelli might say to Council), is to taint Council’s decision on penalty.
[152] The Municipal Act, 2001 does not require a City Council to swear, affirm or otherwise indicate that they will discharge their adjudicative function with an open mind, on the basis of the record before them and the applicable principles. Such a formality may not be necessary where no allegation of bias has been made respecting City Council or a member of Council. However, in this case an allegation of bias was made by Councillor Chiarelli, by way of his counsel’s letter to City Council on February 11, 2020. That letter was never answered by or on behalf of Council. In this circumstance, given the nature of the conduct engaged in by some members of Council, we conclude that an objective person, viewing the matter dispassionately, with a full appreciation of the circumstances, would doubt whether members of Council were approaching their task with an open mind. That concern would be assuaged, in respect to some Councillors, by the proceedings before Council on July 15, 2020. However, in our view, the failure of all members of Council to address the allegation of bias and the conduct suggesting predetermination of the issue of sanction, given all that was said and done, taints the result. We find there is a reasonable apprehension of bias.
With respect to the issue of remedy the court was mindful of the Legislature has entrusted the decision on sanction to City Council and not to the court. At the same time, however, the question of remedy must also be guided by concerns for the proper administration of justice and the need to ensure access to justice.
In resolving to impose the appropriate sanction itself, rather than revert the decision back to City Counsel, the court wrote:
[156] The Supreme Court of Canada has recognized that there are “limited scenarios” in which remitting the matter would stymie the effective resolution of matters in a manner that the Legislature could not have intended. In our view, this case falls within the category of “limited scenarios” in which remitting the matter back to the decisionmaker for determination would not be appropriate.
[157] Where a decision is set aside based on a reasonable apprehension of bias, ordinarily this court remits the issue back to a new decisionmaker. However, in this case there is no other decisionmaker available. In our view, the strong views expressed by some members of Council as to how the matter should turn out before they had received the Report, and their failure to take steps to bring themselves back to their adjudicative role before determining sanction, preclude remitting the matter back to City Council. Doing so would not undo the objective observer’s reasonable apprehension that Council had already made up its mind, would risk bringing the administration of justice into disrepute, and would be unfair to Councillor Chiarelli. We therefore decline to remit the issue of penalty to City Council. Instead, we will determine the appropriate sanction.
In resolving to impose the maximum penalty available to it, the court provided the following reasons:
[159] The Commissioner found that the conduct of Councillor Chiarelli in interviewing and seeking to recruit the three complainants did not serve the interest of his constituents and that Councillor Chiarelli was not acting in a conscientious and diligent manner. The Commissioner found that in the interviews of two of the complainants, Councillor Chiarelli was planning to objectify them by using their sexuality for the purpose of recruiting male volunteers and assisting in his re-election efforts. Based on these findings, the Integrity Commissioner found that Councillor Chiarelli breached ss. 4.1 and 4.4 of the Code of Conduct in respect of each of the three complainants.
[160] The Commissioner also found that Councillor Chiarelli breached s. 7 of the Code of Conduct based on the finding that Councillor Chiarelli made comments to and asked questions of the complainants that were sexual in nature or focused on women’s bodies.
[161] The Commissioner based his recommendation that City Council consecutively impose the most serious sanction available in respect of each complaint – suspension of a Councillor’s remuneration for 90 days – on his conclusion that “the Councillor is the longest serving elected public office holder on Council and that this offensive and disreputable behaviour has been going on for a very long time.”
[162] For us, the nature of Councillor Chiarelli’s behaviour and his failure to participate in the process or to acknowledge his behaviour are dispositive of the issue of penalty. There is no question that Councillor Chiarelli’s conduct, as found by the Commissioner, was serious, offensive, and disgraceful, as well as a clear violation of the Code of Conduct. He engaged in a pattern of sexist harassment that demeaned the complainants who were seeking employment in his office; with respect to two of the complainants, the Commissioner found that Councillor Chiarelli planned to objectify them and use their sexuality to assist in his re-election efforts. As we note above, Councillor Chiarelli has not challenged the reasonableness of the Commissioner’s findings in this application.
[163] At no time, did Councillor Chiarelli acknowledge any wrongdoing or express remorse or regret for his offensive conduct. He refused to participate in the process with the Commissioner and he declined to address Council or to respond to the Report. His conduct brought disgrace upon the City he was elected to serve, and his response was to refuse to respond.
[164] We acknowledge Councillor Chiarelli’s long service in municipal politics. We acknowledge the serious health challenges he has faced. These factors do not persuade us that reduction in the sanction is warranted: we accept the characterization of it by the Commissioner.
[165] For these reasons, in relation to each of the three complaints, we would impose a suspension of Councillor Chiarelli’s remuneration as a member of Council for 90 days, with the sanctions to be imposed consecutively, an aggregate suspension of 270 days.
[166] We appreciate that this conclusion could leave some puzzled. If Council got it right, why would we set aside its decision and then re-impose it ourselves? The answer lies in the important principle that justice must not just be done, but also be seen to be done.
[167] We have found that there is a reasonable apprehension of bias on the part of Council. It would not be fair to let Council’s decision stand as a result. We would send the issue of sanction back for a fresh determination if we could, but there is no one for us to send it to. We cannot leave the conduct of Councillor Chiarelli unsanctioned, for obvious reasons. So, the task falls to us to decide.
[168] We could impose a different sanction: a substantial sanction short of the maximum could also be reasonable. But we will not impose a lesser sanction just so it is different from the one Council imposed: our task is to impose the appropriate sanction, whatever we find that to be. And in this case, we find that the maximum sanction is the appropriate sanction.
Commentary
There is a lot to unpack in this decision, which may have been missed given the date of its release.
Only because it is on my own mind, I want to start with the issue of Councillor Chiarelli’s failure to engage in the process. At paragraph 112 of its reasons, the court in this case writes, “It is not open to a party to opt out of the proceedings below and then raise his issues for the first time with this court.” This statement of law puts persons who believe they are wrongly the subject of workplace harassment complaints in the unenviably position of being required to participate in the process, even if they believe the process inappropriate or tainted by bias. The Chiarelli decision is a cautionary tale of the need to “preserve the record for appeal,” by making timely and appropriate objections as to bias, and to challenge jurisdiction, etc., to the correct party, at the correct time. Also, even if one staunchly disagrees with the process, as this (and other, similar cases) demonstrate, failure to participate in the process does not mean that the process will go away. That does not necessarily mean that one must inculpate by making statements against interest- however one cannot refuse to say anything and then charge, on appeal, that the decisionmaker failed to consider the other side of the story.
The second issue of interest is the fact that the court regarded Councillor Chiarelli’s failure to acknowledge any wrongdoing or express remorse or regret for his offensive conduct as an aggravating factor in the determining the appropriate sanction. As I commented in my summary of the Court of Appeal for Ontario’s recent decision in Hucsko v. A.O. Smith Enterprises Limited, 2021 ONCA 728 (see: “It's Too Late to Apologize” Court of Appeal Finds Refusal to Apologize For Inappropriate Conduct Just Cause for Termination of Employment, “if an employee, who is aware of the ramifications of engaging in workplace harassment, fails to show contrition and follow [the employer’s] reasonable directions for corrective action following a finding of wrong doing, then termination may be an appropriate next step.” Courts, rightly or wrongly, like to see evidence of contrition, especially following a finding of “guilt.” That can be a bitter pill to swallow for those who believe they are innocent. I don’t have a great answer to that problem, I simply note that it exists.
While I hope the Divisional Court’s ruling on this issue is the conclusion of this saga, I somehow doubt that it is. Political egos being what they are, I fear one or more of the parties involved may seek to appeal this decision higher.
Takeaways for Employers
While the application of the Municipal Act, 2001 and the fact that these allegations arise from complaints to the Integrity Commissioner, rather than complaints of workplace harassment under the Occupational Health and Safety Act colour the way by which the investigation and report proceeded, a lot of what the court said in this case is of general application to those charged with receiving and investigating reports of workplace harassment.
Of critical importance is that the person(s) charged with the adjudication of the facts and the imposition of the penalty must, at the very least at the time when the decision is being made, be seen to be acting in an impartial manner.
This whole subject is a minefield. The #MeToo movement and the push to believe survivors have correctly elevated the importance of making informed decisions in the areas of sexual assault and sexual harassment. Persons charged with making decisions in this area therefore must be especially attuned to such issues before making public statements on a specific case that may well come before them. Persons who find themselves in the middle of such a situation would be prudent to solicit and rely upon informed legal advice.
Takeaways for Employees
The takeaway for employees who find themselves the subject of workplace harassment complaints is to understand the process by which your place of employment will investigate and adjudicate claims. Every workplace is different, with the law permitting each employer to develop its own policy and procedure for responding to complaints. If you have been advised that you are the subject of a workplace harassment complaint, then step one is to request a copy of the policy under which the complaint was received.
Where the complaints are serious, with the potential to terminate one’s career, it likely makes sense to seek experienced legal advice. As this case demonstrates, getting a step wrong can be fatal.
Contact Me
Have a workplace harassment issue? Need a policy with respect to workplace harassment? Need someone to conduct an investigation into incidents and complaints of workplace harassment (or just want some guidance and advice on how to do one in-house)? Call me. Email me. Do what works for you.
I can be reached by email at sbawden@kellysantini.com or by phone at 613.238.6321 x233.
Sean P. Bawden is an Ottawa, Ontario employment lawyer and wrongful dismissal lawyer practicing with Kelly Santini LLP. For 2.5 years he was in-house legal counsel providing employment law advice to one of Canada’s largest corporations. He has also been a part-time professor at Algonquin College teaching Trial Advocacy for Paralegals and Small Claims Court Practice.
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As always, everyone’s situation is different. The above is not intended to be legal advice for any particular situation. It is always prudent to seek professional legal advice before making any decisions with respect to your own case.
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