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C Western Provinces - The Law of Workplace Sexual Harassment in Canada
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C Western Provinces

C Western Provinces

CaseYear Summary Compensatory Awards, Lost Income and Other Sums
MacDonald v. Najafi and another (No. 2)2013The conduct was limited to offensive language, yet insensitive and demeaning and persistent, made to a vulnerable young woman in need of employment, without physical contact.$4,000
Soroka v Dave’s Custom Metal2010Verbally offensive conduct, without affirmative evidence, medical or otherwise of the impact upon her, a disparity in age between the victim and the offender, yet causing the termination of the complainant’s employment, in part, due to her refusals.$5,000
McIntosh v Metro Aluminum Products2011Conduct was demeaning, provocative and aggressive, yet without any physical component.$12,500 plus $14,500 lost income
Harrison v Nixon Safety Consulting2008Verbal sexual harassment, including requests for sex and inappropriate touching.$15,000
 Harrison v. Nixon Safety Consulting and others (No. 3),2008Sexual harassment$15,000
Ratzlaff v Marpaul Construction2010The respondent forced his way into the applicant’s hotel room.  He grabbed her throat and kissed her aggressively, forcing his tongue into her mouth.  She said that he then grabbed her breasts and tried to get his hands into her vagina.  She kneed him in the thigh but he repeated his conduct.$25,000
 Senyk v. WFG Agency Network (No. 2),2008Sexual harassment and termination of employment.$35,000
MP v JS2020Respondent pushed MP onto his bed, put his hands under her clothing, touched her breasts, put his fingers into her vagina, and put her hand on his penis. Loss of employment a factor in assessing damages as applicant refused to continue in employment.$40,000
P.N. v FR and another2015A young Filipino mother who was hired as a housekeeper and required to perform sexual acts “at the whim” of her employer.$50,000
General Considerations 2016 BC CA approves of award of $75,000.The high side award, in 2016, was set at $75,000 made in a case based on adverse treatment due to a mental disability. Kelly v. University of British Columbia, set aside on a judicial review application as “patently unreasonable” on first review, yet later restored by the Court of Appeal.
Francis v BC Ministry of Justice #52021mental illness due to adverse conduct of employer due to race$176,000 after 20% contingency discount ($220,000 in total prior to discount)

B.C.

B.C.

CaseYear Summary Compensatory Awards, Lost Income and Other Sums
MacDonald v. Najafi and another (No. 2)2013The conduct was limited to offensive language, yet insensitive and demeaning and persistent, made to a vulnerable young woman in need of employment, without physical contact.$4,000
Soroka v Dave’s Custom Metal2010Verbally offensive conduct, without affirmative evidence, medical or otherwise of the impact upon her, a disparity in age between the victim and the offender, yet causing the termination of the complainant’s employment, in part, due to her refusals.$5,000
McIntosh v Metro Aluminum Products2011Conduct was demeaning, provocative and aggressive, yet without any physical component.$12,500 plus $14,500 lost income
Harrison v Nixon Safety Consulting2008Verbal sexual harassment, including requests for sex and inappropriate touching.$15,000
 Harrison v. Nixon Safety Consulting and others (No. 3),2008Sexual harassment$15,000
Ratzlaff v Marpaul Construction2010The respondent forced his way into the applicant’s hotel room.  He grabbed her throat and kissed her aggressively, forcing his tongue into her mouth.  She said that he then grabbed her breasts and tried to get his hands into her vagina.  She kneed him in the thigh but he repeated his conduct.$25,000
 Senyk v. WFG Agency Network (No. 2),2008Sexual harassment and termination of employment.$35,000
MP v JS2020Respondent pushed MP onto his bed, put his hands under her clothing, touched her breasts, put his fingers into her vagina, and put her hand on his penis. Loss of employment a factor in assessing damages as applicant refused to continue in employment.$40,000
P.N. v FR and another2015A young Filipino mother who was hired as a housekeeper and required to perform sexual acts “at the whim” of her employer.$50,000
General Considerations 2016 BC CA approves of award of $75,000.The high side award, in 2016, was set at $75,000 made in a case based on adverse treatment due to a mental disability. Kelly v. University of British Columbia, set aside on a judicial review application as “patently unreasonable” on first review, yet later restored by the Court of Appeal.
Francis v BC Ministry of Justice #52021mental illness due to adverse conduct of employer due to race$176,000 after 20% contingency discount ($220,000 in total prior to discount)

Alberta

CaseYearSummary Award 
Noel v 375850 Alberta Ltd.2010The complainant, living at a job site in northwestern Alberta, exited the shower and noticed a male camp maintenance worker watching her. A few days later, the same man was standing beside her bed when she awoke.$5,000
Hamm v WWDI Wireless2009The applicant was subjected to abusive behaviour of shoulder rubbing, being blown a kiss and retaliatory conduct of a dismissal letter and false accusations contained within it$4,500
General Considerations  The rough maximum of Alberta awards was considered $10,000 until the award of $25,000 upheld by the Alberta Court of Appeal  Walsh v Mobil Oil. There was also a reprisal sum awarded in this case of $10,000.

Saskatchewan

 CaseYear Summary Award 
General Commentary  The legislators of Saskatchewan have placed a limit on the sum which may be awarded for compensatory damages for a sexual harassment case, in fact any human rights violation, as $20,000. This includes any award for punitive damages. A person subjected to the most brutal forms of sexual abuse in a workplace environment will see such a maximum recovery.
Saskatchewan Board of Inquiry, Ratzlaff v. Dimas (1986), 7 C.H.R.R. D/3402B of I 1986A 19 year old woman, economically vulnerable, subjected to persistent physical and verbal harassment, suffering from severe injury to self-esteem.$2,400. The legislated cap was then $5,000.
Karlenzig v. Chris’ Holdings Ltd. (1991), 15 C.H.R.R. D/5.1991A woman suffered from a “serious physiological impairment” who reported “reported sleep disturbances, shaking, crying and nightmares”.$2,500. The legislated cap was then $5,000.
Shier v Edworthy Saskatchewan HRT2003A complainant who was the subject of one aggressive act of a physical nature, at age 21 or 22, highly physically and economically vulnerable, and subjected to verbal abuse on the same day, showing impact on her self-esteem, without “significant physiological impact”.$2,000. The legislated cap was then $10,000.

Manitoba

CaseYear Summary Award 
Emslie v Doholoco2014The applicant was subject to physical contact by the owner of the business which caused severe emotional harm, including “anxiety, depression, flashbacks and panic attacks which continued for several years”.$15,000 for general damages and $5,000 punitive damages. The Manitoba Code allows for punitive damages of up to $5,000 against an individual and up to $25,000 against a corporation. This order was made against the owner personally. The panel noted the Ontario law which suggested a range of $12,000 to $50,000 and stated that awards in other provinces have been higher than that of Manitoba. Nothing was done to correct that. The facts in this case were said to support an award in the high end of the range.
Garland v. Tackaberry (c.o.b. Grape & Grain), [2013] MHRBAD 5.2013Abusive comments and conduct towards a young woman by a customer upon which the company refused to act.$7,750. This was the highest award prior to Emslie.
Metaser v Jewish Community Campus of Winnipeg Inc Inappropriate sexual jokes and sexual solicitations.$5,250
Jedrzejewska v A+ Financial Services Ltd2016unwelcome sexual solicitations; adverse treatment due to sex$20,000
 T.M. v Gov’t of Manitoba 2019harassment due to homosexuality $75,000 

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