The Quebec government recently passed legislation that requires all government employees – from school teachers to police officers – not to wear any religious symbols.  That means no Jewish men wearing the yarmulke; no Sikhs wearing a turban; no Muslims wearing the hijab; no Christians wearing a cross lapel pin. 

What does all this mean for Christian charities?

First, even if we do not live in Quebec, we may find ourselves facing similar attitudes, as we are living in a time of militant secularism. This is not a secularism that is neutral or indifferent toward religion. Rather, it is a forceful, anti-religious secularism that claims to be acting under the banner of separation of church and state or state neutrality. Unfortunately, this form of secularism takes on characteristics of an extremist religion, imposed by the state on all citizens.

Second, the logic of this approach inevitably leads the secular state to conclude that it can no longer approve or accredit religious enterprises, because to do so would be an endorsement of the religious entity and its beliefs. Already, we’ve seen this logic on display at the Supreme Court of Canada in the Trinity Western University case, where the government insisted (and the Court agreed) basically saying, “we will not accredit a religious school because if we do, we are approving the discrimination of that school towards others.”

Already, the new bill is going to be challenged in the courts. It is questionable how far the court challenge will go, given that the Quebec government is using the “notwithstanding clause” in the Charter to override the religious freedom rights in s. 2(a) of the Charter. The notwithstanding clause allows legislatures to temporarily pass legislation that they know will violate Charter rights. Some suggest that the clause is undemocratic – however, it forms part of the Charter which was passed by the Canadian Parliament (and the UK Parliament) in 1982. It is meant to be a check against the power of the judiciary, to prevent judicial interference in the will of the legislature. 

To accommodate religious garb and adornment is a very low bar in the grand scheme of things. To deny accommodation means we are intruding on religious practices and denying the very beliefs that underlie those external symbols of faith. The justification for this Quebec policy originates with the 2008 commission report on reasonable accommodation of cultural communities co-chaired by Quebec sociologist Gérard Bouchard and McGill philosophy professor Charles Taylor. Their report recommended the banning of religious symbols of judges, policy officers and prison guards. Charles Taylor now says that recommendation was a mistake. Bouchard still maintains the recommendation was proper, but that it is being carried too far to include teachers.

What has happened, it would appear, is that the radical secularists have taken the Bouchard/Taylor recommendation and expanded it. Call it a “slippery slope” or an “abuse” – the fact remains we now have on the record legislation that is clearly anti-religious. That does not bode well for religious freedom for individuals or religious organizations in the long term.

Rather than bemoan this reality, however, we can use the controversy over religion in the public square as an opportunity. The public spotlight does not have to be feared but can be embraced to educate society on the contributions religious communities make every day. Yes, in some circles, religion is viewed as a problem for social cohesion. But we exhibit the exact opposite. The members of CCCC, now a community of some 3400 charities, are engaged in comprehensive work to enhance our country’s success. We assist all who are in need without regard to their religious or non-religious positions. We lift people out of poverty, we educate for competence in multiple fields of endeavour, we feed and clothe. The concern for our neighbour’s well-being is motivated by a religious imperative that guides our lives. This is who we are, and regardless of opposition, we can and should continue to care for others with Christ-like compassion, dedication, and hope.

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Sunscreen and splash toys, bug spray and BBQs remind us that summertime is fast approaching. But for some, the rising temperatures are part of a controversy that, for good reason, simply won’t melt away. The Canada Summer Jobs issue shows no signs of cooling down. It continues to garner press headlines and public attention across the country. The nub of the issue is government imposition of political ideology in order to receive government benefit. Liberal democracies are the planet’s one form of government that not only permits contentious debate but does so with the promise of no government reprisal. We take a dim view of being told by the state what we are to think and do on issues that speak to the core of who we are as human beings.

The government’s requirement that religious communities “tick the box” (attesting that they agree with the state’s view of “Charter values”, “other human rights”, and “access to abortion”) in order to receive public money to hire students for the summer has been greeted with staunch opposition. The Prime Minister and the Minister responsible for the program have said that they will not fund groups who do not “support Charter rights”. In other words, groups who do not endorse abortion are not in line with government policy and therefore will not receive funding.

However, the Government’s position is coming under new scrutiny. It was recently discovered that Dogwood, an activist group against the Kinder Morgan pipeline expansion in B.C., was given CSJ funding, even though the group’s “core mandate” is contrary to the government’s promised support for the pipeline. Meanwhile, charitable groups that did not agree to the government’s position on abortion were denied grants. Ironically, the PM rose in the House to defend that decision by insisting that his government believes in free speech. He claimed, “we will not remove funding from advocacy organizations because we as a government happen to disagree with them!” Mr. Scott Simms and Mr. John McKay, both government MPs, would certainly beg to differ. They took a stand against the government precisely because it did remove funding from groups with pro-life beliefs. In retribution, Mr. Simms was removed as chair of the House committee on fisheries. The entire CSJ issue is seen by McKay as “a lamentable state of affairs.”

Upon hearing the PM’s statements, the House went into an uproar over the apparent hypocrisy — as did the political commentators: Rob Breakenridge of Global News, John Ibbitson in The Globe and Mail, Rex Murphy in The National Post. Dr. Andrew Bennett, former Canadian Ambassador for Religious Freedom, also spoke out on the issue.  Across the country, people took note of the doublespeak.

The irony continues as Kelly McParland points out that the CSJ controversy has re-opened the abortion debate — a debate that the government presumably wanted to silence rather than initiate. Canadians are awakening to the reality that Canada, unlike most liberal democracies, does not have a law on abortion. Abortion, in fact, is not a constitutionally protected right, yet the government continues to obfuscate on the matter.

We now know that the Canada Summer Jobs controversy had its genesis in the abortion issue. The Abortion Rights Coalition of Canada (ARCC) were dismayed that crisis pregnancy centres (CPC) were receiving CSJ funding, and mounted a letter-writing campaign to the government against it. In the Toronto Right to Life application for judicial review at the Federal Court, the government has put in evidence that it received letters from 6 organisations against the CPC receiving government money. All but one of those letters were, in fact, form letters from the ARCC. 

While faith groups seek to replace the government funding shortfall, new lawsuits against the government are being commenced. CCCC is currently reviewing our legal options to support our members and to support the important principles of freedom that underlie our liberal democracy. We are of the view that this government action cannot go unchallenged.

In many ways, the government CSJ action is but the thin edge of the wedge. It represents a trajectory that is not safe for the long term of our democratic institutions. We will be making an announcement in the coming days/weeks as to what legal actions we will be supporting.

Stay tuned. The summer is coming. Heat is rising on this very important subject.

The post Canada Summer Job Program Heats Up in Time For Summer appeared first on CCCC Blogs.

The Freedom For Faith, an Australian group that is advocating for religious freedom in the discussion on same sex marriage in Australia, recently interviewed me about how the redefinition of marriage changed the legal discussion on the relationship between equality and religious freedom.  This is the result.

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You would think that a cornerstone of equality would be the right to freedom of religion, belief and expression. However, Prof. Barry Bussey says in Canada, the argument for equality is actually being used to undermine those core beliefs for students at Trinity Western University (TWU).

Prof. Barry Bussey is an Adjunct Associate Professor at the University of Notre Dame Australia (Sydney), the Director of Legal Affairs for the Canadian Council of Christian Charities, and an experienced litigator for religious freedom at every level of the Canadian judicial system.

The trouble began, explains Prof. Bussey, when TWU sought to establish a law school, and proceeded through normal channels to gain the necessary accreditation.

“Advocacy groups lobbied the Federation of the Law Societies of Canada, saying don’t accredit TWU because [the university] requires students to sign a document saying they will not engage in sexual practices while they’re students that would violate the definition of marriage as one man and one woman,” he says.

The case is about to be heard by Canada’s Supreme Court. There have been years of litigation in lower courts in relation to TWU’s right to set standards in accordance with their beliefs as a private, religious institution.

If TWU loses the case, though, TWU students will be stripped of their ability to practise law in Canada.

“The argument for equality rights has become inflated to such a degree that we’re now willing to use it as a superior right against religious freedom,” Prof. Bussey explains.

The sole cause for this case is Canada’s redefinition of marriage.

“One Bencher in Ontario said, ‘The fact that we had the redefinition of marriage is why we are here today’,” Prof. Bussey says. “If there wasn’t this redefinition, chances are we wouldn’t have this Trinity Western University case.”

Prof. Bussey believes the nature of religious freedom will change dramatically in Canada if TWU loses the case. He says that just the mere fact that someone is offended by the failure to support a non-traditional definition of marriage becomes grounds for legal action.

“It’s a huge change in the attitude of the legal profession which says, as a result of this redefinition, we must now challenge your right to practise what you believe on your own religious campus.”

The post Australian Group Interviews Bussey on Equality and Freedom of Religion appeared first on CCCC Blogs.

The Supreme Court of Canada decided today that it will hear Trinity Western University’s appeal of its loss in the Ontario Court of Appeal last June.

Both the Ontario Divisional Court and the Ontario Court of Appeal ruled in favour of Ontario’s law society (The Law Society of Upper Canada). That law society refuses to accept any TWU law graduate that wishes to article in Ontario. Articling is the term given to the 12 month legal training a law graduate receives under the direct supervision of a senior lawyer before being eligible to be called to practice law on their own.

The Supreme Court also granted leave in the Law Society of British Columbia’s appeal of the BC Court of Appeal’s decision last year that ruled in favour of TWU. The British Columbia Supreme Court had also ruled in favour of TWU.

Both the Nova Scotia Supreme Court and the Nova Scotia Court of Appeal ruled in favour of TWU.  However, after its loss at the NS Court of Appeal, the Nova Scotia Barristers’ Society decided not to appeal to the Supreme Court of Canada.

Both the Ontario and the British Columbia appeals will be heard consecutively by the Supreme Court in Ottawa, on a date yet to be determined.

Supreme Court of Canada, Ottawa

Trinity Western University applied in June 2012 to the Federation of the Law Societies of Canada for accreditation of its proposed law school.  Opposition arose from a number of advocate groups including academics, such as the Canadian Law Deans, because of TWU’s requirement that its students sign a Community Covenant which, among other things, requires a lifestyle in harmony with its religious view of traditional heterosexual marriage. Though it is a private school, with no government funding, and though it had won a similar challenge at the Supreme Court in 2001, the opposition demanded that the school not be granted accreditation. However, in December 2013, the Federation, after much study and debate, recognized TWU’s religious freedom to be permitted to operate a law school, and given that the proposal met the academic requirements, it granted TWU accreditation.

A firestorm erupted among those against TWU and pressure was brought to bear on each provincial law society not to accept the Federation’s decision. Three societies ultimately decided against accepting TWU’s law school proposal: Ontario, Nova Scotia and British Columbia. That led to TWU appealing to the courts. The courts at both levels in Nova Scotia and British Columbia ruled in favour of TWU recognizing its right to religious accommodation under the Charter. However, both courts in Ontario ruled against TWU, citing its religious practice on marriage as being discriminatory against LGBT students.

For those in the legal community who wanted the 2001 TWU decision overturned, because it gave TWU the right to operate its university within a traditional Christian environment, getting the Supreme Court to hear this case has been a win. As Lisa Teryl, Legal Counsel for the Nova Scotia Human Rights Commission stated, “A judicial review would open up the possibility of the Supreme Court of Canada revisiting its [2001] reasoning. The High Court could consider the issues reframed in terms of the preservation of democratic state values of maintaining a separation of church and state for secular activities that conflict with discriminatory religious beliefs.”

For those of us in the religious community this case has been something that we had long suspected would happen as the sexual equality rights campaign becomes more focused on those religious communities that maintain their traditional sexual mores.  We are now entering a time where even private religious communities, in their own religious organizations, are being challenged for their “discriminatory religious beliefs.” Even though our organizations are “private” in that they are run and operated by religious communities, those who do not accept our right to so operate have labeled our enterprises (such as running schools and universities) as “public” because we have to be publicly accredited. This is a total re-imagining of the concept of religious freedom that we have enjoyed in Canada since its founding. It is a revolutionary position.

In the coming weeks Canadian Council of Christian Charities will be seeking leave to intervene in these two cases.  We will keep you informed how things work out.

The post Supreme Court Grants Leave On TWU appeared first on CCCC Blogs.

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Court House in Halifax

The Nova Scotia Barristers Society (Society) was “discomforted” by Trinity Western University’s (TWU) Community Covenant which, “in addition to mundane items” noted the Nova Scotia Court of Appeal (Court), “prohibits sexual intimacy outside the marriage between a man and a woman.”

However “discomforted” the Society may have felt about that Covenant, it had no jurisdiction to punish a TWU law graduate in its attempt to punish the University. As the Court put it, “Trinity Western’s law graduate is not Trinity Western’s alter ego.” Well said. The Court’s decision is a helpful reminder of just how out of step the Society became with its campaign of political correctness by overreaching its jurisdiction in an attempt to control the admissions policy of a law school in another province, British Columbia.

When one steps back and considers what the Society tried to do, one cannot but be amazed at the height of hubris. Consider this: a Nova Scotia entity charged with the solemn responsibility to protect “the public interest” in the practice of law in its province, answered the call of critical academics and activists that the Society must show its disapproval of a British Columbia law school because it is “discomforted” by the religious practice of marriage as being between one man and one woman on that campus. The Society gave itself the jurisdiction to decide that TWU’s Community Covenant was discriminatory against potential LGBTQ applicants, and that it violated the Charter and human rights legislation and therefore was “unlawful.”

The Court of Appeal rightly rejected the Society’s power grab. In the first place, the Court noted that TWU is a private university, as recognized by the Supreme Court of Canada in 2001, and therefore not subject to the Charter. It was illogical for the Society to suggest that TWU violated the Charter when it is not even subject to the Charter! “Trinity Western did not “unlawfully” violate an enactment that has no application to it,” the Court held.

Further, the Court of Appeal noted that there was no statutory authority for the “Society to issue an independent ruling that someone has violated Nova Scotia’s Human Rights Act.” There was not one “supportive word” in any legislation that gave the Society such authority. Nor, said the Court, was there any ability for the Society to establish its own “court of competent jurisdiction under the Charter with the authority to rule that someone’s conduct in British Columbia unlawfully violated the Charter.”

The Society’s role in protecting the “public interest” in the practice of law is to ensure that a person practicing law has the required “knowledge and skill of a person trained in the law.” To the extent that the Society needs to approve an institution to ensure law graduates obtain the proper education is within its jurisdiction. What is not in the Society’s bailiwick is to focus on matters at a university not related to the practice of law. By implication lawful religious beliefs and practices are not related to legal practice.

Common sense is an apt description for this decision. The Court was not amused that the Barrister’s Society unilaterally declared jurisdiction to govern admissions policies that have nothing to do with the general competence to practice law. If only the Ontario Court of Appeal had followed a similar course.

TWU Counsel Brian Casey and Kevin Sawatsky with the counsel of interveners supporting TWU’s position

It truly is remarkable that TWU has been forced onto this arduous road of legal attrition over an issue already settled by the Supreme Court of Canada. The University has had to fight for its right to practice its religious belief a second time. The process is the punishment it seems. In 2001 the Supreme Court of Canada ruled in its favour to have an education degree despite its admissions requirements. Today, in 2016, because it desires to have a School of Law, the politically correct academics and activists have created such an uproar that TWU has had to fight for its constitutionally protected right not on one front but on three separate fronts in three provinces. It is simply ridiculous.

What TWU wishes to do is to continue with its role as a religious university that issues degrees with which its graduates may enter the work force — something it has done since the 1960s. It has not violated one iota of Canadian law in doing so. But because its religious views on marriage are no longer in vogue it was forced to face this colossal legal barrage. It is time in this country for the harassment of Christian institutions to come to an end. The law societies show how untrue their claim is that ours is a country for everyone when they disregard the constitutional protection of religious institutions.

Thankfully, we still have courts, like the Nova Scotia Court of Appeal, that can see through the legal sophistry and allow common sense to prevail.

Supreme Court of Canada, Ottawa

We now await the soon to be released decision of the British Columbia Court of Appeal. Then off we will go, no doubt, to the Supreme Court of Canada where we will finally see whether its 2001 TWU decision that respected religious freedom is still good law. Hopefully, common sense will prevail there too.

The post Common Sense Prevails at the Nova Scotia Court of Appeal appeared first on CCCC Blogs.

The Law Courts, Halifax, Nova Scotia

The post Nova Scotia’s Highest Court Rules in Favour of TWU appeared first on CCCC Blogs.

Sign on TWU Campus

I detected a general theme in the respective Court of Appeal arguments of the Law Societies in British Columbia and Ontario over the last two weeks.  “We are the experts.  We know what we are doing.  Now give us deference.  Our decisions against accrediting Trinity Western University’s School of Law are reasonable.”

The final hearing of the TWU controversy was held June 7 before the Ontario Court of Appeal in historic Osgoode Hall, Toronto.  There TWU lawyer Robert Staley faced the Law Society of Upper Canada’s lawyer Guy Pratte.  It was fiercely contested.  Each eloquently put forward their clients’ position.

TWU argued that the LSUC did not correctly apply the proper legal test in its decision making process, thus eviscerating its religious freedom.  To understand the argument you first need to understand how the courts analyze Charter rights.

The Charter protects citizens from the state.  It is the supreme law of the land.

The “state” can be government officials, politicians, legislatures, police, or bodies that have been delegated authority by the state such as law societies.  Law societies are known in this context as “state actors” – they are created and authorized by the provinces to protect “the public interest” in the practice of law.  They regulate who can be lawyers, establish the professional ethic codes, set the ongoing education requirements, and discipline lawyers as necessary.  Professions, such as law, covet such roles.  From one perspective it is highly irregular to have the public interest of an influential profession being safeguarded by the profession itself.  On the surface it looks like a systemic conflict of interest.  However, there are measures to soften that by including members of the public on the Society’s governing council, known as “the Benchers”.  Nevertheless, it is extremely important that these “state actors” are mindful of the law and of the competing interests in the cases they have to decide.

Supreme Court of Canada

The Supreme Court of Canada (SCC) laid down the rules as to how administrative bodies, such as law societies, are to decide cases that involve constitutional rights.  The law is laid out in the 2012 case known as “Doré v. Barreau du Québec”.  Doré teaches us that when a law society is faced with a decision that involves claims of Charter rights it must follow a particular formula or “test” in its analysis.  If it does this it will be considered a “reasonable” decision even though it could have arrived at a different conclusion using the same test.  In other words, the Court is saying, the law society is the expert panel to decide issues that come within its jurisdiction and must be given deference in its decisions.  It may not be the way a court would decide but it is within the realm of “reasonableness.”

The Doré test that applies to administrative tribunals operating under a statute then is this:  What are the statutory objectives?  Is there a Charter right or value engaged?  How will the Charter value at issue be best protected in light of the objective?  In other words, what would be the least onerous and least restrictive infringement on the constitutional right or value while carrying out the statutory objective in the case?

The Law Society arguments made in Ontario and British Columbia have centred on the Doré test.  They maintain that the statutory objectives include the “public interest” of ensuring that there is equal access to the profession for all people.  It is here where TWU fails they say.

TWU has a Community Covenant, a contractual arrangement, between the University and its students, wherein each student agrees to abide by its terms and conditions.   It’s a basic arrangement not unlike numerous other Christian universities in North America that establish the religious nature of the campus environment.  One of the requirements is that the students not engage in sexual activity outside of the traditional marriage (one man, one woman).

The law societies argue that TWU can maintain its religious campus.  That is TWU’s constitutionally protected religious freedom to do so.  But when TWU comes to a public body for state recognition of its degree then it must abide by the public norms.  The refusal to accept LGBT students who do not accept the Community Covenant is discriminatory.  As a result the law societies cannot accredit the TWU School of Law.

TWU lawyers in Ontario (Robert Staley) and British Columbia (Kevin Boonstra) argue the law societies did not apply the Doré test in reaching their conclusions.

Ontario Court of Appeal

Osgoode Hall – Ontario Court of Appeal – TWU hearing was in Court Room 1

At the Ontario Court of Appeal, Robert Staley went through the transcript of the Benchers as they made their decision.  “Not a single Bencher followed the Doré analysis,” Staley informed the Ontario Court of Appeal.  Instead the Benchers spoke in absolutist terms that the rights of the LGBT community must not give way.

When asked by the Justices about the references the Benchers made about “balancing” the rights of religious freedom and equality rights, Mr. Staley noted that the Benchers’ use of the “buzz words” did not in and of itself mean they applied the proper Doré analysis.  What they did, Staley maintained, was to use part one of the Doré test – that is they recognized that they were to exercise their duty to maintain the public interest by ensuring equality of access to the practice of law.

However, even here, Staley argued, the Benchers failed because there was no public interest engaged.  The only public interest was that of ensuring that TWU graduates were competent to practice law, which the Society has agreed they would be.  Further, the recognition of TWU’s law school did not take away any right of the LGBT community.  Recognition of one right does not mean a diminution of the rights of others.

Even if they could say that there was a public interest engaged, then the Benchers should have applied the second part of the Doré test which was:  what would be the least onerous and least restrictive infringement on TWU’s religious freedom while carrying out the statutory objective of ensuring equality of access?

The Benchers did not bother.  They refused to even consider accommodation.

In essence, I take Staley’s argument to be, that the Benchers were so opposed to the teachings of TWU that they were blinded by their distaste of the belief of traditional marriage that was manifested in the Community Covenant.  That blind opposition meant they did not even entertain the thought of how they were to find a way of accommodating TWU’s religious freedom.  It was simply rejected.  There was no possibility as far as they were concerned.  It was repugnant, plain and simple, and did not need further consideration.

Staley argued that the Divisional Court’s decision provided a Doré analysis of how the Benchers could have arrived at its decision.  But it is not the role of the courts to do the work of the administrative tribunals.  The tribunal, in this case the Law Society, is to be the expert and given deference.  However, the Law Society does not to get “a free ride” since fundamental religious freedom is at stake.

Guy Pratte, the lawyer representing the Law Society, argued that the Society’s decision was reasonable as the Divisional Court showed.  For 200 years the Society has played the role of the gatekeeper to the profession and over time it has sought to remove barriers rather than raising barriers.  To support TWU’s law school would be to endorse TWU’s discrimination.  Admission to a law school should be based on merit, not on religion.

Mr. Pratte asserted that the religious freedom TWU wants to advance goes further than keeping its own faith.  It seeks to enforce it on others who are “not part of the club.”  However, when they enter the public sphere and enter into a public profession they have to lay their beliefs aside.  Denying applicants on grounds of sexual orientation has nothing to do with the merits of being a lawyer.  They cannot force the Law Society to approve that.

Entrance to the Law Society of Upper Canada

If the Law Society breached the freedom of religion in its decision making process because it did not follow some “magic words” it does not matter.  TWU’s position that the Doré analysis was not followed is an argument of “form over substance.”  What matters is the outcome.   And the outcome was a reasonable decision.  Since the Divisional Court used Doré and arrived at the same conclusion then how can the Law Society’s decision be unreasonable?   It is not unreasonable for the Law Society to say that religious freedom does not go so far as to force your beliefs on another.  The Law Society was asked a “binary” question – it was a simple “yes” or “no.”  After seriously considering the issues the Law Society said “no”.  The Law Society could have said “yes” and if it did – that too would have been reasonable.  TWU does not “get to have everything.”

When the court pointed out that TWU did not get anything.  Mr. Pratte noted that there is only one part of the Community Covenant that is at issue.  The Society would have no problem with the Covenant if it were not made mandatory of TWU students.  It is concerned with the exclusion of students at the “door”.  Religious conduct is worthy of less protection than beliefs.  Though there are only a few from the LGBT community who would want to attend TWU, the state doesn’t take the sting out of the discrimination by closing its eyes or holding its nose because of the few.

In reply Mr. Staley reminded the court that the Doré analysis is not simply a magic formula but a very clear direction from the Supreme Court as to the proper analysis that is to be applied that ensures Charter rights are respected.  There was absolutely no evidence that the Law Society considered what was the least infringement on TWU’s rights.

Lawyers representing TWU and supporting interveners at Ontario Court of Appeal

British Columbia Court of Appeal

Entrance to the British Columbia Court of Appeal

The TWU case in BC is different from Ontario in that the Law Society of British Columbia (LSBC) had first voted to accredit TWU’s law school but then decided to change its mind.

The LSBC was faced with what it thought was a no win situation.  When the Federation of the Law Societies of Canada approved the school, BC lawyers in opposition to TWU called on the LSBC to disapprove the Federation’s decision.  After much debate and discussion about the competing rights of religious freedom and equality issues the LSBC decided, in April 2014, not to overturn the Federation.

However, the opposition got louder and demanded a Special General Meeting in June to discuss a resolution demanding the LSBC to overturn its support of TWU.  That meeting was held in several locations simultaneously throughout BC.  Those who attended reported to me that there was tremendous animosity expressed towards TWU for having the audacity to ask that its religious rights be respected.  It was a classic case of a crowd being ticked off at the minority that stands its ground on matters of conscience.  The vote at the SGM was overwhelming against TWU.

In an attempt to overcome the impasse the LSBC decided, in September, to hold a referendum of the entire membership rather than to have another extensive debate as it did in its April meeting.  Not surprisingly, the referendum results were against TWU.  Upon judicial review, Chief Justice Hinkson ruled that the LSBC had illegally fettered its discretion by turning over its decision making jurisdiction to the membership rather than having a full consideration of the issues as it did in its April decision.  He then ordered the reinstatement of the April decision thereby approving TWU School of Law.  The LSBC appealed.

At the Court of Appeal, LSBC lawyer, Peter Gall argued that there were three issues to consider.  First, whether the LSBC had the jurisdiction to approve or disapprove TWU.  Second, how to reconcile the competing rights in light of LSBC’s statutory obligations.  Third, whether using the means of a referendum was an appropriate process.

Gall explained that the law society was in a no win situation.  It was going to be faced with opposition whether it approved TWU or not.  CJ Hinkson’s decision said that the LSBC didn’t balance the rights and more should have been done.  But what more could have been done or could it do now, Gall asked?

The court noted that the LSBC had given its jurisdiction over to the members of the entire law society to make the decision involving Charter rights.  To which Gall responded it is difficult and it depends upon the “lens” you use to look at the right from either the perspective of religious freedom or equality rights – there is a reasonable answer both ways and therefore it was reasonable for the LSBC to allow the members to decide the matter.  The LSBC still could override the members if what they decided was unreasonable.  In this case their decision not to approve TWU was reasonable.

The court had a rough time with this line of argument.  One justice asked, “So the entire members are able to conduct a Doré analysis?”  Another asked if at the point the members were engaged in making the decision were they then all “Benchers” under the enabling legislation of the LSBC?  Mr. Gall continued with his line of reasoning that the Benchers were able to ascertain whether all of the rights were being properly assessed to ensure the final result was reasonable.

Still the court struggled with the idea that the entire body of lawyers could be granted such decision making power.  The court asked to whom it gives deference to – the LSBC Benchers or the members?

Chief Justice Bauman said, in what appeared to be a look of wonder, “That would make the Law Society the largest tribunal in B.C.”  There are over 10,000 lawyers in BC.

“Potentially, yes.”  Replied Gall.  The court was wanting to be clear and asked whether that would also mean the LSBC could give matters of discipline of lawyers over to the complete membership?

“Yes,” came the reply. They could by SGM resolution take up matters of discipline. If it is an important issue for members as a whole to decide, the LSBC could delegate it to the members.

Mr. Gall went into an extensive discussion about the objectives of TWU and argued that to change the Community Covenant so that it is not mandatory would not affect those objectives.  Such a compromise would not prevent teaching from an Evangelical perspective.  TWU welcomes students who are not evangelical to attend and that does not impact the associational rights so why is it necessary to have a covenant dealing with sexual intimacy?

The court asked if the LSBC was challenging the “bona fides” or validity of the rule of faith of the religious people at TWU.

“No,” replied Mr. Gall.  He went on to explain that the question is whether there is a proportionate result from a proper balancing of the  beliefs and practices of TWU  against the equality considerations of the LGBT community.  Emphasis should be given to the determination of  the impact on TWU’s beliefs and  the objectives of the law school.

The court noted that it is not for the court to say whether the belief is important to TWU or to intrude on those beliefs.  Mr. Gall agreed but he explained  that the court does have to determine the extent of the harm if insignificant or trivial.  Mr. Gall observed that it is not easy to weigh but one has to look at the impact of what the LSBC statutory mandate is on the Charter right.  The balancing must be made with the LGBT community losing out on 60 law school spaces and the psychological harm of seeing the state approve and in so doing, condone a discriminatory school of law.  Such an endorsement would harm the public interest of protecting the administration of justice.

The Benchers’ October decision not to approve on basis of the memberships view was consistent with the statutory mandate and its constitutional obligations.  It was a proportionate balance of the competing rights.  The question on review is whether that decision of the Benchers was reasonable.  To determine reasonableness the court must look at the impact of the competing rights.  When you consider the stated objectives of TWU to have a law school what is the impact of removing from the Community Covenant the offending provision?

Kevin Boonstra, TWU’s counsel, argued that the court has to consider the contexts – the statutory context and the factual context.  The statutory context requires the court to determine whether the Benchers had the authority to determine admissions policies of a law school.  The statute gave the LSBC authority over qualifications to practice law and not the determination over how law schools are run.  The factual context discloses two opposite decisions of April and October.

Mr. Boonstra noted that there can only be one correct decision that is consistent with the public interest.  The Doré analysis requires that the impact on a Charter right must be infringed only as what is absolutely necessary to carry out the public interest.  If in April that meant that TWU’s school of law was approved, what made the difference to that calculation in October?  Why could the LSBC no longer accommodate TWU’s interest?  Why was it necessary to remove the right altogether in October?

TWU serves the needs of the Evangelical community.  They believe in moral boundaries.  There is no distinction between what one believes and how one lives one’s life.  You cannot pick and choose which boundaries are important and which are not.

TWU’s mission is to educate the whole person – called spiritual formation.  There are codes of conduct in other evangelical organizations.  The Federation looked at the rules of US Christian law schools and found that it would not be an impediment to practice law in Canada.  American students from those schools would be able to practice here.  TWU is not availed this right in Canada. [But it is interesting to note that if TWU were in the US, its students would be able to practice in Canada through the current rules of the Federation.]

In its April meeting the LSBC undertook a full public review.  Two legal opinions were obtained that supported TWU’s position.  All of the issues of accommodation and balancing of rights were reviewed.  In the end the Benchers voted in support of TWU.

The court asked how it could be fair to allow the April decision to stand when it was clear that the LSBC wanted to change its position.

Mr. Boonstra noted that the LSBC was motivated by political and governance pressure within its ranks.  In October there was no balancing considered. It was simply what the members wanted.  Only a proportionate balancing underlying a decision makes it a reasonable decision as noted in Doré where rights are limited only to the extent necessary to maintain the legislative objectives.  It was the duty of the Benchers to conduct this analysis not the members.  The transcripts clearly show that October was a political decision and not a substantive review.

Mr. Boonstra also noted that the 2001 Case that involved TWU’s education program was a binding precedent in this matter.  The BC College of Teachers argued that they could not condone the discriminatory admissions policy of TWU.  The Supreme Court of Canada ruled that TWU was not for everyone.  Boonstra went on to note that since 2001 the protections of religious freedom have increased in SCC decisions including the right of religious communal rights in the Loyola decision of 2015.

In reply Mr. Gall stressed the importance of the court to give deference to LSBC and though the process in October may not have been in accordance with the Doré analysis, at the end of the day it is whether the decision was right.

Lawyers representing interveners supporting TWU at the BC Court of Appeal

Concluding remarks and observations

With the Courts of Appeal in British Columbia and Ontario having held their hearings we are now at the end of this phase of the TWU saga.  Over the coming months we  wait for the decisions from three Courts.  Nova Scotia’s can be expected anytime in the coming weeks.  I do not expect to hear from Ontario or BC until the fall.  Whatever the results, we can expect that this case will be heard at the Supreme Court of Canada.

It remains baffling that TWU would have to put forward so much money, energy and effort to defend its right to open a law school.  One only has to consider that TWU is not subject to the Charter.  In other words, it is not a state actor that it has to open its doors to whoever applies.  There are never any requirements for religious institutions to be other than who they are.  By definition religious communities discriminate.  They have to.  In fact, the human rights laws and the Constitution provides the space for this.  That is what the Supreme Court in 2001 explicitly stated about TWU.  TWU’s “discrimination” is lawful.  It is how it works.  How can you have a church where anyone can be a minister of that church even if they do not hold to the church’s beliefs?  How can it be said that a university remains a religious university if it cannot hire faculty and accepts students who are willing to abide by its religious principles?  It simply makes no sense.

The millions of dollars that have been spent in defending TWU’s right to have a Code of Conduct that supports its religious beliefs on marriage is beyond comprehension.  It seems there is a growing opinion among some legal elites in Canada that has moved beyond the judiciary.  This is evident in Nova Scotia and British Columbia where the lower courts supported TWU’s position.  While the Ontario Divisional Court’s decision is the outlier so far it is also a direct challenge to the Supreme Court’s 2001 decision which said that “TWU is not for everybody.”  For the Ontario Divisional Court it would appear that TWU’s law school is not for Ontario.

From my attendance at every court of appeal hearing in this case I sense that there is a great deal of sympathy for TWU’s position.  At the very least, the justices appear to understand TWU’s position.  It seems to me that there is a lot of work to do in informing the public, the opinion makers, and policy makers about the importance of this case.  In my opinion, this is the most important religious freedom case in recent Canadian history.  The implications of a loss in this matter is huge.  Where, for example, will the logic end if TWU loses?  If the law societies can deny TWU, what about all the other professional organizations?  Would there be a movement to move against other religious colleges and universities in other disciplines?  I think that is exactly where we are headed.

One of the interveners, LGBTQ Coalition, argued that if the LSBC had approved TWU it would be an “endorsement of an unconstitutional definition of marriage.”  An unconstitutional definition of marriage?  That is a remarkable statement.  It is a very good thing that the Supreme Court of Canada in 2004 decided that clergy who performed only such “unconstitutional” marriages of one man and one woman would be protected.  Further, the SCC also said in 2004 that churches could exclusively use its facilities for “unconstitutional” marriages of one man and one woman.  Without those very minimum protections there is no question, in my mind, that there would be demands for the use of all churches for whatever “constitutional” marriages people would want.

I have said it many times before but this case is about trying to find a way for various communities, with very different views on basic moral issues, to be able to live on the same piece of real estate in civil peace.  A failure to allow TWU to have a law school because of its religious views and communal practices – practices that are constitutionally protected – is a step back from the promise of Canada that we have all enjoyed.  The Supreme Court of Canada noted in the 2001 TWU decision:

Indeed, if TWU’s Community Standards could be sufficient in themselves to justify denying accreditation, it is difficult to see how the same logic would not result in the denial of accreditation to members of a particular church.  The diversity of Canadian society is partly reflected in the multiple religious organizations that mark the societal landscape and this diversity of views should be respected.  (Paragraph 33.)

The denial of TWU’s school of law would mean that we can expect our individual church membership may be cause for denial of state issued licenses.  That would not be a recipe for a diverse Canada.  In other words, we are fast approaching a time where there will be significant pressure against a diversity of communities and religious views.  Monochromatic hegemony is approaching.

Equality Before the Law – the lion and the lamb outside of the Ontario Courts in Toronto

The post The Experts Demand Deference: Law Societies & TWU appeared first on CCCC Blogs.

Yesterday, our agents in Vancouver filed our factum at the BCCA in the matter of Trinity Western University and the Law Society of British Columbia. The hearing is scheduled for June 1-3, 2016 in Vancouver. Our factum outlines our concerns about institutional religious freedom raised by this case. In summary,  we argue that the LSBC’s decision amounts to nothing less than a rejection of Canada’s jealously and expansively protected religious freedoms. It strikes a devastating blow to the very heart of religious civil society and has the effect of reducing the rich tapestry of Canadian society to a monochromatic banner of uniformity. The long-term preservation of freedom, diversity, integrity, and Canada’s social capital requires the law to be willing to accept differences of belief and practice on such controversial issues as marriage.

You may read the factum in full by clicking here.

Bussey explains the work of CCCC in TV interview:

The post Recent Happenings: CCCC Files Factum At BC Court of Appeal; Bussey appears on TV appeared first on CCCC Blogs.

Conversation With The Author

It was my pleasure today to speak with one of the authors, Stanley W. Carlson-Thies, about this book and why he and Stephen V. Monsma wrote it.  You may be interested in watching our conversation.  It is divided into three parts:

Part 1 Stanley W Carlson Thies with Barry W Bussey 15 11 02 

Part 2 Stanley W Carlson Thies with Barry W Bussey 15 11 02 

Part 3 Stanley W  Carlson Thies with Barry W  Bussey 15 11 02

Book Review

Stephen V. Monsma & Stanley W. Carlson-Thies, Free To Serve: Protecting The Religious Freedom of Faith-Based Organizations (Grand Rapids: Brazos Press, 2015), 198 pages.  $18.69 Canadian at Amazon

The Problem:  Faith-based Organizations Are Denied Religious Freedom

Faith-based organizations’ ability to freely express their religious convictions is threatened more than ever and such threats are on the rise.  However, Monsma and Carlson-Thies assure us that there is hope.¹ They optimistically suggest that the American pluralist society has room for all to live together despite “deep differences.”  Religious and non-religious alike benefit when freedom is protected for all faith-based organizations.  However, religious freedom is challenged when religiously motivated people are denied freedom to allow their faith-based organizations to carry out their faith in the “public realms of health care, education, and services to the needy.”²

The Solution:  Principled Pluralism

Their vision is for all people to be free to worship, or not, as their beliefs require.  Religious people ought to be able to live out their faith in the nation’s public life through faith-based organizations.  Religious freedom requires at least as much.  There must be a profound respect for the diversity of belief/non-belief systems, perspectives and organizations where none is favoured over another.  It is a commitment to religious freedom, pluralism and tolerance.³

The solution to this quandary is a “principled pluralism” that has four principles:  first, all human beings are morally responsible.  They are free individuals who possess human dignity and certain fundamental rights, the most basic of which is freedom of religion;⁴ second, human beings are social;⁵ third, government must not prevent its members from being able to create and sustain nongovernmental organizations that are based on and reflect their members’ deeply held beliefs;⁶ and fourth, as government should not dominate society’s organizations nor should one organization seek to dominate or control other organizations or individuals.⁷

Working out this “principled pluralism” will require a mutual “forbearance and toleration as they experience inconvenience and burdens due to their fellow citizens living as their beliefs require them to live.”⁸

The False Assumptions

The authors reject the notion that religious organizations are said not to be deserving of religious freedom because they operate outside a church.  They point to World Vision’s struggle to maintain its right to fire three employees who no longer supported its statement of faith.  The US Court of Appeals for the Ninth Circuit ruled 2-1 in World Vision’s favour.  However, as Monsma and Carlson-Thies point out, it was a close call.⁹

Judge Marsha Berzon’s dissenting decision causes one to pause when she argued that World Vision was “nothing like a church” to be exempt from the requirement not to discriminate against the religious beliefs of its employees.  It’s humanitarian work, she pointed out, “on its face, [is] secular.”¹⁰

Berzon’s view is one that is gaining popularity, not only in the US but throughout Western democracies.  It is a very narrow description of religious freedom based on at least two assumptions.  First, religious activities involve only those that fall within the rubric of church services and religious rites.  Second, it assumes that religious freedom is solely for individuals and their religious communities – it does not include faith-based (profit or not-for-profit) corporations.

Throughout this volume Monsma and Carlson-Thies addresses these assumptions, and others, that would deny religious freedom to faith-based organizations.  They do so by arguing that the protection of religion includes not only the worship rites but it also includes the manifestation of those beliefs in all areas of life.  In particular, they point out that Christianity (and other religions as well) does not limit itself to weekly church services.  Its religious norms are applicable throughout the week and are operative in all occasions.  It is why Steven McFarland, vice-president and chief legal officer of World Vision could say, “We are not just another humanitarian organization, but a branch of the body of Christ.”¹¹  Faith-based organizations operationalize the religious sentiments that are articulated in the churches, synagogues, mosques, etc. in the form of health care, education and other endeavours to help those in need.  When religious people “…band together to create service organizations to fulfill their religious obligations more effectively than they could as individuals or as members of a local congregation, there is no reason why those organizations are any less religious than local congregations.”¹²

The secular/religious divide is a construct of recent origin.  The American Civil Liberties Union, Political Research Associates and other groups have been advocating this description.  The authors point out that Martin Luther King Jr. “would have problems calling desegregation a ‘secular value,’ as would hosts of brave demonstrators who marched out of their churches and into the streets in the 1960s.”¹³

To suggest that government funding transforms a faith-based organization to a government actor is a wrong characterization of the relationship.  Rather, the authors point out that it should be seen as a partnership whereby the government recognizes that it can be more efficient and effective by tapping into the support networks of the “independent sector” to remedy a common problem.¹⁴  In the same way that a government gift to an arts organization does not mean that organization is now a government actor so a faith-based organization should not lose its identity because it receives government funding.¹⁵

The authors reject the assumption that Christianity’s cultural dominance and any attempt to protect religious freedom is an attempt to use public policies to maintain a favoured position.¹⁶  The opposite is true.  “Christianity, is anything but culturally dominant” in the U.S. and one might add in much of Western liberal democracies.¹⁷  The reality is that both the religious and the non-religious feel marginalized by the other group which makes it more difficult to establish common ground.¹⁸

Religious Freedom Also Extends To Faith-based For-Profit Entities

Monsma and Carlson-Thies point out that faith-based organizations are not solely non-profit or charities.  They are also for-profit entities – such as the Hobby Lobby case illustrates.  Consider for a moment that Hobby Lobby applied its owners’ Christian principles in the workplace by giving employees about double the minimum wage, comprehensive health coverage and one day (Sunday) off each week.  Media reports were not as interested in those provisions as they were about Hobby Lobby’s refusal to provide abortifacient medication to its employees.  The refusal was due to the conscientious objection of Hobby Lobby owners, the Green family of Oklahoma.¹⁹

While the US Supreme Court ruled 5-4 in favour of granting Hobby Lobby the exemption based on its right to religious freedom, that decision, as Monsma and Carlson-Thies point out, “remains on shaky ground.”²⁰  The media tried to frame the case as the Green family imposing their religious scruples on its employees.  Such a position is unfair.  That would only be the case, the authors argue, if the Green family fired those employees who were using the abortifacients, or the Green family was lobbying Congress for a law against this form of birth control.  The only coercion in this case came from “…those who were seeking to force the Green family to act contrary to their religious beliefs.”²¹  The authors reject the argument that this was a “secular” corporation and therefore not entitled to religious freedom.  The corporate mission statement and faith inspired practises establish that the owners were, in fact, operating it as a religious based entity.  To deny it protection because of its corporate status could also exclude incorporated churches.  In short, “…religion is more than worship….”²²

Monsma and Carlson-Thies emphasize two limitations on the religious freedom of for-profit organizations.  One, there must be a “clear, explicit, demonstrable religious commitment.  Two, there is no “general right to avoid legal requirements to which they have religiously based objections.”²³  There has to be a balancing of the competing interests.

Other Views

This book also contains six essays written from Roman Catholic, evangelical, Jewish, Muslim and non-religious backgrounds.  Their purpose is to make explicit that Monsma and Carlson-Thies’ concerns are shared by a diverse group.  These essays are very helpful.  Tish Harrison Warren’s piece, “The Wrong Kind of Christian” gave a first-hand account of a Christian organization that was forced off Vanderbilt University’s campus because it required its student leaders to sign a statement of faith.  Warren, an Episcopal priest, said “Religious organizations were welcome as long as they were malleable – as long as their leaders didn’t need to profess anything in particular; as long as they could be governed by sheer democracy and adjust to popular mores or trends; as long as they didn’t prioritize theological stability.”²⁴ Warren came up against a university bureaucracy that was against “discrimination.”  The word “discrimination” was “lobbed like a grenade to end all argument.”  One university official stated, “Creedal discrimination is still discrimination.”²⁵  Creedal belief and sexual expression, notes Warren, were “not just wrong but evil, narrow-minded, and too dangerous to be tolerated on campus.”²⁶  There remained a “culture of fear” on campus where sympathetic professors remained silent in their support of the Christian organization for fear that “going public would be ‘career damaging.’”²⁷

“When religious liberty is not secure, nothing is,” wrote Kristina Arriaga de Bucholz in her short essay included in this volume.²⁸  Bucholz reviewed the experience of the religious order, Little Sisters of the Poor, who refused to agree to pay for the abortifacient drugs as part of the government’s mandatory healthcare.  Little Sisters provides elderly care for people of all faiths who otherwise would not have such help at the end of life.  Yet the government was willing to shut them down with crippling fines.  Little Sisters is currently pursuing their right to religious freedom in court.

Kim Colby’s essay asks the question, “Will pluralism survive the death of relativism?”²⁹  She maintains that relativism was good for religious freedom as, by definition, it had to respect the right of individuals to hold diverse opinions.  However, today there is a “Truth 2.0” that has swept relativism aside and proclaims a new fundamental truth:  “an individual’s sexual autonomy must be unhindered, even unquestioned, no matter what the cost to others’ liberty or even to others’ right to life.”  It demands “that everyone must agree that abortion and sexual conduct outside of traditional marriage are not only acceptable but affirmatively good.”³⁰ And dissent will not be tolerated.

Nathan Diament, an Orthodox Jew, points out that Jews realize that the religious freedom experienced in the U.S. is unprecedented in history.  Therefore, his question “Can it happen here, in America?” has an ominous tone – is it possible that such protections could be expunged in America?³¹  The Enlightened French experience for Jews was “a Jew in the home, but a Frenchman in the street,” has not been the American experience.  It is antithetical to Judaism which “recognizes no notion of ‘being a Jew in the home’ and something else in the street or office or classroom or marketplace or park.”³²

The Muslim perspective, in this book, was given by Hamza Yusuf Hanson and Mahan Hussain Mirza.  “Muslims,” they stated, “stand in solidarity with other faith communities to advocate for the right to live and preach their convictions in the public sphere.”³³  They maintain that the best way to mediate difference is to allow for a plurality of opinions in free and open debate with power of persuasion resting in arguments.  They see successful faith-based institutions in America as a model to bring hope and relief to Muslims everywhere.

Distinguished law professor Douglas Laycock presents a secular perspective in his essay.  “I do not support religious liberty because religion is good,” admits Laycock, “but because religion is profoundly important to those who care about it.”³⁴  He argues that when government “stays out of the way” religion flourishes.  “The whole point of religious liberty is that people from across the whole range of views about religion agree to respect the religious liberty of everyone else across the whole range of views about religion.”³⁵  However, government rarely has a compelling interest in preventing people from feeling offended, insulted, or irritated.

Conclusion:  Practical Steps Going Forward

The authors close their book with five practical steps faith-based organization can take to protect their religious freedom.  First, explicitly stating religious commitments.³⁶  By holding themselves out as religious in all publications, policies, web presence etc. they increase their credibility as being religious.  It will forewarn potential employees the religious nature of the operation.  Second, avoid even the appearance of coercing others to follow one’s religiously based practises.  There is a distinction between providing services to those engaged in “activities that are legal but immoral, and providing services that make it complicit in those immoral activities.”³⁷  There is also a distinction “between refusing to provide a service its religious beliefs hold to be immoral and attempting to prevent someone from obtaining that service elsewhere.”³⁸  By showing respect to a pluralist society the faith-based organization signals its commitment to pluralism and it will strengthen its defense of religious freedom.³⁹  Third, show respect for and work with others who disagree.⁴⁰  Such an attitude demonstrates that they are not simply another advocacy group interested solely in its own protections but cares about the religious freedom of others.  It also opens the door for others to reciprocate the support.  Fourth, get to know community leaders.⁴¹  Ignorance of a group will lead to misconceptions.  Faith-based groups will do best to meet and know community leaders before there is an issue or controversy.  Fifth, work with others to defend everyone’s religious freedom rights.⁴²  They argue that there is a need to work with umbrella organizations and not stand alone – “There is strength in numbers.”⁴³

Evaluation:  Timely but the Conversation Must Continue

While the authors are optimistic that a principled pluralism is possible and even desired I am not sure that society, as currently configured, is willing to put forward the requisite effort to make it happen. Our cultural moment appears less inclined for co-operative projects in these areas of concern. We need more discussion about what will be required to accomplish the vision that Monsma and Carlson-Thies outline.

It seems to me, that further discussions need to be had with those who oppose their views. In many ways this is a book that preaches well to the choir but I question how it may be perceived by those who disagree.  Further conversations must be made with those individuals and groups opposing religious freedom of faith-based organizations.

Monsma and Carlson-Thies’s Free to Serve is timely and necessary.  The pressure on faith-based organizations to conform to a secular ideology is intense.  Such conformity would result in the loss of their religious character.  The concept of the “public” has proven to be dynamic.  Religious communities have established education, healthcare and other centres to meet societal needs for millennia.  It is not as if they are new to the field.  Such endeavours were long considered “private,” that is to say, the religious groups that established the entity maintained their religious character while carrying out their work.  They did so with minimal supervision from government.  If there is anything new, it is the notion of a nation-state seeking to be the sole provider of such services and thereby removing faith-based organizations, or, at the very least, lessening their religious identity to conform to the dominant secular ideology.  Though this book is US centric it addresses issues that are salient throughout the Western World.

It is a great primer and needs to be read not only by law and religion academics, legal practitioners and those leading faith-based organizations but also by the general public.  Its language is easily accessible.

Notes:

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