Ontario v. Coote

Ontario v. Coote

The constitutional challenge to s.140 was rejected; the application judge properly applied s.140 and the quantum of costs was reasonable; courts may award costs against self-represented litigants where circumstances warrant it.

Source-derived case information.

Citation
2011 ONCA 563
Parties
Respondent: Her Majesty the Queen in Right of Ontario; Appellant: Antoine Coote aka Antoine Coote aka Claufield Anthony St. Orbin Coote; Respondent: Lawyers' Professional Indemnity Company
Court
Court of Appeal for Ontario
Jurisdiction
Canada
Judgment Date
24 August 2011
Procedural Posture
Civil / Appeal (motion in Court of Appeal)
Outcome
Motion dismissed; constitutional challenge and costs challenge rejected
Legal Topics
Section 140 Courts of Justice Act, Costs Against Self Represented Litigants, Constitutional Validity Challenge
Source Language
en
Constitutional Law Costs Civil Procedure Section 140 Courts of Justice Act Costs Against Self Represented Litigants Constitutional Validity Challenge

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Parties

Her Majesty the Queen in Right of Ontario

Respondent

Antoine Coote aka Antoine Coote aka Claufield Anthony St. Orbin Coote

Appellant

Lawyers' Professional Indemnity Company

Respondent

Procedural Posture

Civil / Appeal (motion in Court of Appeal)

  1. 1 Whether s. 140 of the Courts of Justice Act is constitutionally invalid or improperly applied
  2. 2 Whether the quantum of costs awarded by the application judge was unreasonable
  3. 3 Whether costs can be awarded against an in-person (self-represented) litigant in these circumstances

Ratio Decidendi

The constitutional challenge to s.140 was rejected; the application judge properly applied s.140 and the quantum of costs was reasonable; courts may award costs against self-represented litigants where circumstances warrant it.

Court Disposition

Motion dismissed; constitutional challenge and costs challenge rejected

Orders

  • Motion dismissed
  • Costs order of the application judge upheld