Richards v. Correctional Service Canada

Richards v. Correctional Service Canada

The request for reconsideration is dismissed because there was no denial of natural justice or procedural fairness, no substantial change in circumstances (Ramadan and the volume of disclosure were known or foreseeable and did not overlap the original deadlines), and reasonable alternatives (paper disclosure, limited computer access, adjournment or extension) remain available; security considerations justify denying 24-hour laptop access in a cell.

Citation
2024 CHRT 19
Parties
Complainant: Ryan Richards; Commission: Canadian Human Rights Commission; Respondent: Correctional Service Canada
Court
Canadian Human Rights Tribunal
Jurisdiction
Canada
Judgment Date
9 April 2024
Procedural Posture
Human Rights Tribunal Discrimination Complaints Consolidated / Ruling on Reconsideration Motion
Outcome
Request for reconsideration dismissed
Legal Topics
Reconsideration, Procedural Fairness, Reasonable Accommodation, Disclosure, Religious Accommodation, Disability Accommodation, Security Considerations in Custody
Source Language
English
Administrative Law Human Rights Law Prison/corrections Law Discrimination Law Reconsideration Procedural Fairness Reasonable Accommodation Disclosure +3 more

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Parties

Ryan Richards

Complainant

Canadian Human Rights Commission

Commission

Correctional Service Canada

Respondent

Procedural Posture

Human Rights Tribunal Discrimination Complaints Consolidated / Ruling on Reconsideration Motion

Legal Issues

  1. 1 Whether the Tribunal should reconsider its prior ruling refusing a laptop in cell
  2. 2 Whether there was a denial of procedural fairness or natural justice
  3. 3 Whether Ramadan and related health/religious obligations constitute a substantial change in circumstances

Ratio Decidendi

The request for reconsideration is dismissed because there was no denial of natural justice or procedural fairness, no substantial change in circumstances (Ramadan and the volume of disclosure were known or foreseeable and did not overlap the original deadlines), and reasonable alternatives (paper disclosure, limited computer access, adjournment or extension) remain available; security considerations justify denying 24-hour laptop access in a cell.

Court Disposition

Request for reconsideration dismissed

Orders

  • Mr. Richards' request for reconsideration is dismissed.
  • The parties must respect and comply with the Tribunal's directions and rulings and prepare for the hearing on April 23, 2024.