Question of the Month

Legal research is a big part of the services we provide here at the Manitoba Law Library. This new section will present some of the interesting queries we receive, and highlight how we can point you towards helpful resources, or suggest answers for difficult questions.

Q: What constitutes copying in Canada?

In recent news Ed Sheeran has recently won his copyright battle after being challenged that his song had similarities to a Marvin Gaye song. This isn’t the first time a song has been accused of being too similar to another artist’s. It can even be funny how many songs can sound the same, but how close do songs, or artistic works, need to be to be considered copying?

In “Musicians and the law in Canada – 3rd ed.” p. 144 “…”not every authorized reproduction is an infringement. The copying must be substantial. What constitutes copying is a matter of fact. Generally, courts will give greater weigh to the ‘quality’ of what is taken than to the ‘quantity’ taken.” While Halsbury’s Law of Canada – Copyright (HCY-61 VI 2(1)) notes that “The court will consider whether there are substantial similarities based on the relevant parts of the works, including latent similarities not necessarily obvious to the layperson, that may influence how a layperson experiences the work” citing Pyrrha Design Inc. v. Plum and Posey Inc. In Pyrrha, [2022] FCA 7 the judge clarified in paragraph 17 “Pyrrha argues that the Federal Court erroneously focused on what it viewed to be the relative simplicity of the Pyrrha Designs. By relying on this simplicity, the Court is asserted to have erred by relying on the “sweat of the brow” approach to originality. The correct approach is the “skill and judgment” approach set out in CCH.[2004 SCC 13]”

What is meant by the “skill and judgment” approach in CCH Canadian Ltd v Law Society of Upper Canada? Paragraph 16 gives some explanation, “For a work to be “original” within the meaning of the Copyright Act, it must be more than a mere copy of another work. At the same time, it need not be creative, in the sense of being novel or unique. What is required to attract copyright protection in the expression of an idea is an exercise of skill and judgment. By skill, I mean the use of one’s knowledge, developed aptitude or practised ability in producing the work. By judgment, I mean the use of one’s capacity for discernment or ability to form an opinion or evaluation by comparing different possible options in producing the work. This exercise of skill and judgment will necessarily involve intellectual effort. The exercise of skill and judgment required to produce the work must not be so trivial that it could be characterized as a purely mechanical exercise. For example, any skill and judgment that might be involved in simply changing the font of a work to produce “another” work would be too trivial to merit copyright protection as an “original” work.” 

Looking to the future, the concept of “skill and judgement” may become more complex with the rise of AI generated content. From a Fillmore Riley blog post[1] , “Given that AI platforms often just produce content after a simple text-based request is made, it could be said that there is no demonstration of skill and judgment. Conversely, there is the argument that human interaction with the AI’s content output can be original and worthy of protection.” For even further discussion on AI ownership see the CBA article “State of the Arts: How Should Canadian Copyright Law Treat Works Generated by Artificial Intelligence?”.

[1] Badejo , Michael O & Steven Z Raber. “Copyright and Generative AI: Creative infringement or timeless innovation?”, (20 April 2023)

Court Notices & Practice Directions

Provincial Court

Practice Directives

• April 25, 2023 – Adult Pre-Trial Coordination Protocol (Winnipeg Centre)
• April 5, 2023 – Adult Bail Triage Court Protocol (Winnipeg Centre)

Book Reviews

Review taken from the Canadian Law Library Review, vol 48 no 1

Fertility: 40 Years of Change. By Maureen McTeer. Toronto: Irwin Law, 2022. ix, 266 p. Includes glossary, bibliographic references, and index. ISBN 978-1-55221- 637-8 (softcover) $39.95; ISBN 978-1-55221-638-5 (PDF) $39.95. <irwinlaw.com/product/fertility-40-years-of- change>.

Reviewed by Alexandra Kwan, Digital Services & Reference Librarian, Bora Laskin Law Library, University of Toronto

“Fertility: 40 Years of Change is a retrospective look at the legal, medical, and research developments in assisted human reproduction (AHR) and in vitro fertilization (IVF) in Canada since 1978. This is reflected in the primarily chronological structure of the book, which is separated into short chapters focusing on significant developments in the history of AHR and IVF.”

This title is available through the library on the vLex platform behind the members portal.

Events

Free webinar on vLex and Vincent AI

The library will be hosting three online training sessions for vLex with instruction on how to use the platform and its features. These webinars will also cover vLex’s AI ‘Vincent’ explaining how this powerful tool assists with legal research, analyzes documents, and automatically generates headnotes from decisions.

Session 1 Vincent/AI Webinar: Tuesday May 30th at 1 pm CT
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Session 2 Navigating the vLex Platform with a focus on Irwin Law Webinar: Tuesday June 13th at 1 pm CT
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Session 3 vLex Platform Walkthrough Webinar (Vincent AI, Navigating the Platform, Irwin Law): Tuesday June 27th at 1 pm CT
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Upcoming Events

Substantive Law

Civil Litigation

295 Garry Street Inc. v. Mittal et al, 2023 MBCA 35: Appeal of summary judgment granting a mandatory injunction requiring Mittal Group to remove some of its equipment from 295’s parkade. Other party cross appealed order that it was not entitled to punitive damages. Dispute over interpretation of a commercial easement agreement between the previous owner of the property and the owner of the parkade. Easement does not have any measurements to define the exact limits of the encroachment area. Analysis of the principles governing contractual interpretation as noted in Vesturland Development Ltd. et al v. Gimli (Rural Municipality) et al, 2021 MBCA 45 (paras 37-42). CA found motion judge made a palpable and overriding error of mixed fact and law by focusing on the boundaries of the easement rather than the easement agreement as a whole. Summary judgment is appropriate; CA allowed appeal and dismissed cross appeal.

RS Distribution Services Ltd. v. MTS Inc. et al, 2023 MBCA 34: Plaintiff appeals trial judge’s dismissal of its claim for damages for breach of contract. Parties had signed an agreement for provision of services which did not contain a clause providing a minimum financial or volume guarantee. Plaintiff argued a memo prepared by MTS in-house counsel constituted a part of the agreement. Defendant claimed the memo was sent inadvertently and did not form part of the agreement. CA determined trial judge did not make any reviewable error warranting appellate intervention. Appeal dismissed.

Badda Boom Trucking Ltd. v. Liondale Inc., 2023 MBKB 64: Contested motion for specific orders concerning a buy-sell notice, the return of a shareholder loan, as well as other remedies. Initial application seeks a variety of oppression remedies. Applicant and respondents had incorporated a company to perform signals work for rail companies, with each party contributing different skills and experience. Turner, J. reviewed Gershkovich et al. v. Sapozhnik et al., 2019 MBQB 115, in which Grammond, J. summarized a number of decisions from other jurisdictions where interim relief was requested in the context of an oppression remedy claim. Application  granted.

Jon Peters. Beyond Gladue: Addressing Indigenous Alienation From the Justice System in Civil Litigation. (2023) 28 Appeal 119.

In 1999, the Supreme Court of Canada’s seminal decision R. v. Gladue enunciated principles that recognized systemic bias and inter-generational trauma leading to the overrepresentation of Indigenous Peoples in incarcerated populations. Now, nearly a quarter century later, long-evolving efforts to meaningfully include Indigenous Peoples within colonial legal systems have focused primarily on Indigenous Peoples’ interactions with the criminal justice system. Such efforts have yet to meaningfully reconcile Indigenous legal orders with Canada’s civil justice system. This paper surveys the historical development of Canada’s judicial approaches to reconciliation, and within that context, posits applications of Gladue principles to contemporary civil litigation.

 Connor Bildfell and Diana Wang. B.C. Court of Appeal Clarifies the Law on Internet Defamation. Canadian Appeals Monitor (McCarthy Tetrault), 25 April 2023, viewed on 02 May 2023. Case comment on Pineau v. KMI Publishing and Events Ltd., 2022 BCCA 426.

The B.C. Court of Appeal’s recent decision in Pineau v. KMI Publishing and Events Ltd. clarifies that although sharing a hyperlink to a defamatory article published by a third party does not establish liability for defamation, sharing a hyperlink to a defendant’s own defamatory article—and thereby increasing its circulation—should be considered in assessing damages. 

Constitutional Law

Murray-Hall v. Quebec (Attorney General), 2023 SCC 10: Issue of paramountcy in federal-provincial legislation regarding decriminalization of recreational cannabis use. Federal cannabis statute allows individuals to cultivate no more than four plants. At the same time, Quebec legislation was introduced that completely prohibits the possession and cultivation of cannabis plants for personal use. Superior Court set aside those sections of the provincial legislation and declared them constitutionally invalid. Appeal court set aside the trial decision. Supreme Court dismissed the appeal. Per Wagner, C.J. (Karakatsanis, Côté, Rowe, Martin, Kasirer, Jamal and O’Bonsawin JJ. concurring):

[1] A few years ago, the federal Parliament passed legislation relating to cannabis. Under that legislation, it is prohibited for an individual to possess or cultivate more than four cannabis plants in the individual’s home. The provinces and territories subsequently passed their own legislation to regulate such practical matters as the manner in which cannabis was to be sold and stored. Through a broad legislative initiative that included the creation of a monopoly on the sale of cannabis, the Quebec legislature, for its part, enacted provisions that completely prohibit the possession and cultivation of cannabis plants at home, regardless of the number of plants. What must be determined in this appeal is whether the Quebec provisions are constitutionally valid in light of the division of powers and, if so, whether they are operative under the doctrine of federal paramountcy. For the reasons that follow, I conclude that the impugned provisions are a valid exercise by the Quebec legislature of the powers conferred on it by s. 92(13) and (16) of the Constitution Act, 1867. I also conclude that the impugned provisions do not frustrate the purpose of the federal legislation and are therefore operative.

 [2] In these reasons, I express no opinion on the appropriateness or merits of the approaches adopted by Parliament and the Quebec legislature, respectively. I focus on explaining why two approaches to the self‑cultivation of cannabis — the more “permissive” federal approach and the more “restrictive” Quebec approach — can coexist from a legal standpoint within the Canadian federation.

Marion Sandilands, Danielle Bennett. The Charter’s Federal Spine: Why are Certain Charter Rights Immune from the Notwithstanding Clause? (2022) 43 Nat’l J. Const. L. 169. (WLC – LSM members can request a copy.)

The “notwithstanding clause” under s. 33 of the Canadian Charter of Rights and Freedoms applies to certain Charter rights, but not others. More specifically, it excludes democratic, language, and mobility rights–what the authors refer to as the “non-derogable rights”. Why is it that these rights are excluded from the ambit of s. 33? This article offers an answer to this important but disregarded question. The article begins by reviewing two competing theories about the exclusion of certain Charter rights from the ambit of s. 33–the “political compromise” theory and the “fundamental rights” theory. Neither theory provides an adequate answer. While the political compromise theory maintains that nothing can be gleaned from the exclusion of some rights over others from s. 33, fundamental rights theory is divorced from the historical record and creates an odd hierarchy of Charter rights.

Criminal Law

R. v. Hanan, 2023 SCC 12: Appeal as of right affirming the accused’s convictions by a jury for manslaughter, discharging a firearm with intent to wound, and possession of a restricted firearm without a license, based on a violation of the accused’s right to be tried within a reasonable period of time. Accused was charged in December, 2015 and was scheduled to go to trial in November 2018, which would have been under the ceiling as established by Jordan. However, it was delayed by the Crown and did not proceed until November 2019. Appeal allowed, conviction set aside. Present: Côté, Rowe, Martin, Kasirer and Jamal JJ. Reasons delivered by Côté and Rowe JJ.

 [1] This is an appeal as of right from a judgment of the Court of Appeal for Ontario which affirmed the appellant’s convictions by a jury for manslaughter, discharging a firearm with intent to wound, and possession of a loaded restricted firearm without a licence. Two grounds of appeal are raised: first, a violation of the appellant’s right to be tried within a reasonable time under s. 11(b) of the Canadian Charter of Rights and Freedoms that would justify a stay of proceedings and, second, an error in the charge to the jury that would require a new trial. We are of the view that the first ground is dispositive, so we decline to address the second.

…

[9] Like the majority and the dissent below, we reject the Crown’s proposed “bright‑line” rule according to which all of the delay until the next available date following defence counsel’s rejection of a date offered by the court must be characterized as defence delay. We agree with van Rensburg J.A. and Tulloch J.A., as he then was, at para. 56, that this approach is inconsistent with this Court’s understanding of defence delay. Defence delay comprises “delays caused solely or directly by the defence’s conduct” or “delays waived by the defence” (Jordan, at para. 66). Furthermore, “periods of time during which the court and the Crown are unavailable will not constitute defence delay, even if defence counsel is also unavailable” (para. 64). All relevant circumstances should be considered to determine how delay should be apportioned among the participants (R. v. Boulanger, 2022 SCC 2, at para. 8). We share the view of the majority and dissenting judges in the Court of Appeal that, in the circumstances of this case, it is unfair and unreasonable to characterize the entire period between June and October 2019 as defence delay (paras. 59 and 136).

 R. v. Haevischer, 2023 SCC 11: Appeal over standard to be applied in criminal cases for summary dismissal without a hearing on the merits. Accused applied for a stay of proceedings for abuse of process. Before it proceeded to a voir dire, the Crown brought a motion for summary dismissal. Trial judge dismissed the motion and the accused were convicted. Court of Appeal quashed the convictions and remitted the stay applications to the trial court for a voir dire. Supreme Court dismissed the appeal. Per Martin J. (Wagner C.J. and Karakatsanis, Côté, Rowe, Kasirer, Jamal and O’Bonsawin JJ. concurring):

 [2] There is a clear consensus in courts across Canada that trial judges have the power to summarily dismiss applications made in the criminal law context in certain circumstances. However, the national case law is divided about the proper threshold to be applied. It is time for this Court to provide guidance on this important issue, which is linked to concepts as fundamental to our criminal justice system as trial fairness and trial efficiency. The chosen standard must protect the accused’s constitutional rights to a fair trial and full answer and defence while avoiding undue delay and the disproportionate or wasteful use of court resources. It should also discourage decision makers from determining the merits of the underlying application without all the evidence, as this risks unfairness for an efficiency which may be more apparent than real.

 [3] As a result, an application in a criminal proceeding, including for a stay of proceedings for abuse of process, should only be summarily dismissed if the application is “manifestly frivolous”. This threshold best preserves fair trials, protects the accused’s right to full answer and defence, and ensures efficient court proceedings. It is a rigorous standard that allows trial judges to weed out the sort of applications that the summary dismissal power is designed to exclude, but permits most applications to be decided on their merits in proportionate proceedings.

R v. Breault, 2023 SCC 9: Appeal concerning the interpretation of the immediacy requirement when refusing a demand for a breath sample pursuant to s. 254(2)(b) of the Criminal Code. Officers requested accused submit a breath sample, although they didn’t have an approved screening device on them. Per Côté J. (Wagner C.J. and Karakatsanis, Rowe, Martin, Kasirer, Jamal and O’Bonsawin JJ. concurring):

 [4] The central issue in this case relates to the time within which a peace officer must enable a driver who is stopped for this purpose to provide the breath sample required for a proper analysis to be made by means of an ASD. Specifically, this Court must determine whether the validity of a demand made by a peace officer under s. 254(2)(b) Cr. C. requires that the officer have immediate access to an ASD at the time the demand is made.

…

[8] The Quebec Court of Appeal was correct in law in stating that the wording of the provision allows for a flexible interpretation of the word “forthwith” where there are unusual circumstances related to, among other things, the use of the device or the reliability of the result that will be generated, because the text of the provision indicates that the sample taken must enable a “proper analysis” to be made.

[9] It is neither necessary nor desirable to set out an exhaustive list of the circumstances that may be characterized as unusual. For the purposes of this case, it will suffice to say that the absence of an ASD at the scene at the time the demand is made is not in itself such an unusual circumstance. I would therefore dismiss the appeal.

R. v. Ballantyne et al, 2023 MBCA 38: Reasons for dismissal of sentence appeal for co-accused Ballentyne and Pereira. Three parties accused and convicted received the same sentence under the parity principle. Ballentyne and Pereira argue that was an error, and seek a reduction of their sentence from ten years to five years. Appellate court can only intervene on a sentence appeal if the sentence is demonstrably unfit or the sentencing judge made an error in principle. Denunciation and deterrence are the primary sentencing objectives in this case (home invasion where the victim was shot). Less weight given to personal circumstances of the co-accused. CA is satisfied trial judge gave appropriate consideration of all the factors in determining the sentence.

R. v. King, 2023 MBCA 37: Crown appeals accused’s acquittal of the charge of second degree murder. Trial judge found that the accused was in an advanced state of intoxication and that the Crown had failed to disprove she acted in self-defence. Crown argues findings are tainted by legal errors. Judicial review of s. 34(1) and 34(2) of the Criminal Code re self defence, including reference to R. v. Khill, 2021 SCC 37. CA found trial judge did not err by conflating the three distinct inquiries under s.34(1) or by importing subjective elements under s.34(1)(c) and s.34(2) (para. 59). Error in applying s.34(2)(c), (d) and (g) did not have a material bearing on the verdict (para. 60). Appeal dismissed.

R. v. N.B.T.,2023 MBCA 36: Appeal of convictions for sexual assault and sexual interference. Grounds are that trial judge erred by impermissible reasoning and drawing inferences that were not grounded in the evidence, and also erred by applying a higher or stricter standard to the evidence of the accused and his wife than to that of the complainant (uneven scrutiny). Trial judge’s reasons are to be read as a whole; Beard, JA found trial judge’s finding on credibility was reasonable. Review of recent SCC decisions questioning whether uneven scrutiny is an independent ground of appeal. CA found trial judge made no palpable and overriding errors; appeal dismissed.

R. v. Perswain, 2023 MBCA 33: Appeal of conviction for sexual assault and sexual interference, on the grounds of unreasonableness. Identity of assailant was based on circumstantial evidence, and accused argues that the trial judge’s finding that the Crown had proven beyond a reasonable doubt that he was the assailant was unreasonable. Test is that from R. v. Villaroman, 2016 SCC 33: were the inferences drawn by the trial judge reasonably open to them. Trial judge owed a high level of deference; appeal dismissed.

R. v. Scott and Jack, 2023 MBKB 70: Sentencing decision where accused were found guilty of second degree murder. Both are Indigenous offenders. Analysis of length of parole ineligibility, taking into consideration the planning and violence involved in the offence. Significant review of caselaw for similar offences across several jurisdictions. McKelvey, J. finds appropriate period of parole ineligibility is 15 years for Scott and 12 years for Jack.

R. v. Weitzel,2023 MBPC 19: Sentencing decision where accused pled guilty to arson with disregard to human life. Accused firebombed a house while people were sleeping in it. Aggravating factors include planning involved, and effect on the victims. PSR includes a statement from the accused’s foster mother that he has been diagnosed with FASD. Denunciation is most important of all sentencing principles in this case. Accused is sentenced to a period of 12 months in jail, followed by 18 months of supervised probation.

R. v. Dare, 2023 MBPC 18: Reasons for voir dire decision. Accused was charged with firearms offences and related breach charges. Possession is the sole issue at trial. Defence filed an application to exclude the evidence due to a warrantless search. Accused made incriminating remarks before he has an opportunity to call a lawyer. Crown argues that police gained entry to the residence due to exigent circumstances. Police entry was justified, but search, which found a shotgun, violated accused’s s.8 rights. Crown concedes a s.10(b) breach re right to counsel. Accused argues a second s.10(b) violation. Review of meaning of “without delay” regarding speaking to counsel. These rights were also violated. Shotgun admitted, oral comments at police station are inadmissible.

R. v. Toews, 2023 MBPC 14: Accused was charged with assault causing bodily harm in the context of a domestic relationship. Accused alleges that the complainant attacked him and fell against the overhead garage door, accidentally injuring herself. Accused testified. Devine, P.J. found accused’s evidence to be “fanciful” (para. 52), and concluded she was convinced beyond a reasonable doubt that he assaulted the complainant.

 Steve Coughlan. R. v. Beaver: Reasonable Grounds, Expediency, and “Fresh Starts”. (2023) 85 C.R. (7^th) 87. (WLC – LSM members can request a copy.)

Two central points separate the majority and the dissent in R. v. Beaver (2022), 85 C.R. (7th) 1 (S.C.C.), both relating to the arrest directed by the officer back at the station. These points relate to whether that arrest should be seen as “legitimate”, and how — if at all — it should be seen as insulating the early Charter violations from the later obtaining of evidence.

 Oliver Fitzgerald. More Loose Ends: The Crown’s Discretion to Call Witnesses in a Criminal Trial. (2023) 71 C.L.Q. 39 (WLC – LSM members can request a copy.)

The Crown is permitted to prosecute or “call” its case as it chooses in a criminal trial. The Crown shoulders the burden of proving the charges against an accused party beyond a reasonable doubt. How the Crown discharges that burden is up to a particular Crown Attorney prosecuting that accused party. That prosecuting Crown Attorney decides which witnesses she wants to call, the order in which those witnesses testify, and what questions she wants to ask them. A witness who was subpoenaed may ultimately never testify if the Crown determines that his anticipated evidence is irrelevant, redundant or otherwise unnecessary or unhelpful. This is rooted in the Crown’s discretion to present its case as it determines is most appropriate and also in the adversarial nature of a criminal trial.

 But, this power is not unlimited. As the Supreme Court of Canada held in R. v. Cook, the Crown cannot use this power for any “oblique motive” that abuses the trial process. An accused party’s substantive and procedural rights create further checks on the impact of this Crown power. The Supreme Court explained that an accused individual’s concerns about this Crown power resulting in a “trial by ambush” and the loss of the right to cross-examine a particular witness are ill-founded because an accused individual’s right to disclosure requires the prosecuting Crown to divulge any exculpatory material such that the accused party can call that evidence herself. That same accused party can also request that the trial judge call a witness whom the Crown has elected not to call or comment on the Crown’s failure to call the particular witness.

Family Law

R.M.S. v. B.D.W., 2023 MBKB 72: Dispute over parenting time, child support and child support arrears. Petitioner (father) now has parenting time every second weekend, but is now seeking parenting time during all weekdays. Petitioner had signed a voluntary child support agreement but was in arrears. He had a serious injury, was out of work and was now on social assistance. Respondent wants petitioner’s income imputed and for him to pay arrears. Father’s parenting time proposal was incomplete; parenting time is to remain the same as it is in the best interests of the children. Income is imputed at minimum wage for 35 hours per week. Arrears owed from prior to the father’s injury, other arrears cancelled.

S.L.S. v. R.J.P., 2023 MBKB 69: Issue of whether the respondent stood in loco parentis with one of the petitioner’s children from a previous relationship. Review of Chartier v. Chartier, [1999] 1 S.C.R. 242 for examination of standing in place of a parent under the Divorce Act. M.(L.M.) v. B.(W.G.), 2003 MBCA 17 held that in loco parentis under the FMA had the same meaning. Onus is on petitioner to prove it on a balance of probabilities. Leven, J. found for the respondent.

Debra Louise Vanbeselaere v. Daniel Gerard Vanbeselaere, 2023 MBKB 67: Application concerning the validity of a premarital agreement. Respondent argues that petitioner cannot claim spousal support and is not entitled to share in the majority of the assets accumulated in the marriage. Petitioner asks court to declare the agreement invalid. Respondent retained a lawyer to draft a premarital agreement. Agreement signed in 1997; petitioner did not request or receive independent legal advice. Analysis of whether the agreement was unconscionable, referencing Hartshorne v. Hartshorne, 2004 SCC 22 and Melnyk v. Melnyk, 2010 MBQB 121. Menzies, J. also considered Uber Technologies Inc. v. Heller, 2020 SCC 16 as guidance on the inequality of bargaining power. Marital agreement was found to be of no effect.

Michaela Keet and Jeff Edgar. Mediator Discretion in Cases Involving Intimate Partner Violence. (2023) 35:1 Can. J. Fam. L. 131.

Mediation is a centerpiece in the “agreement culture” around family law litigation. It is recognized by the courts as offering inherent protections to deal with challenging cases such as those involving intimate partner violence. To learn more about how mediators invoke and view the process’s protections, we conducted a series of interviews with senior mediators, trainers, and policymakers in the field. This article synthesizes current views within the mediation field about how to identify and screen for IPV, and implications for process management.

Wills, Trusts & Estates

The Estate of William Charles Gorrie, 2023 MBKB 66: Motion to dismissal an application for delay under KB Rule 38.12. Application was filed in June 2018. Two days after executing his will, deceased filed a petition for divorce against the applicant. Family and probate files were combined, but the application in this instance was not included and has never proceeded. Review of Gamble and Wojtowicz v. Karpluk, 2023 MBKB 39 for analysis of similarity to Rule 24. Motion dismissed, but Master Berthaudin directed parties to schedule the application within 30 days, relying on Rule 1.05.

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