Innu Council of Pessamit v. St-Onge

Innu Council of Pessamit v. St-Onge

Applying the reasonableness standard, the Court concluded the Council's resolution could not reasonably be found to reflect the broad consensus required under the 1994 Code; therefore the 2015 Code could not validly govern the August 17, 2016 election and the resolution was set aside.

Source-derived case information.

Citation
2019 FCA 13
Parties
Appellant: THE INNU COUNCIL OF PESSAMIT; Appellant: RENÉ SIMON; Appellant: ÉRIC CANAPÉ; Appellant: GÉRALD HERVIEUX; Appellant: DIANE RIVERIN; Appellant: JEAN-NOËL RIVERIN; Appellant: RAYMOND ROUSSELOT; Appellant: MARIELLE VACHON; Respondent: JÉRÔME BACON ST-ONGE
Court
Federal Court of Appeal
Jurisdiction
Canada
Judgment Date
23 January 2019
Procedural Posture
Appeal / Judgment on Appeal (final Disposition)
Outcome
Appeal dismissed
Legal Topics
Standard of Review, Custom Election Code, Band Governance, Consensus Requirement, Judicial Review of Resolutions
Source Language
en
Administrative Law Indigenous Law Election Law Standard of Review Custom Election Code Band Governance Consensus Requirement Judicial Review of Resolutions

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Parties

THE INNU COUNCIL OF PESSAMIT

Appellant

RENÉ SIMON

Appellant

ÉRIC CANAPÉ

Appellant

GÉRALD HERVIEUX

Appellant

DIANE RIVERIN

Appellant

JEAN-NOËL RIVERIN

Appellant

RAYMOND ROUSSELOT

Appellant

MARIELLE VACHON

Appellant

JÉRÔME BACON ST-ONGE

Respondent

Procedural Posture

Appeal / Judgment on Appeal (final Disposition)

  1. 1 What standard of review applies to the Council's resolution?
  2. 2 Was the 2015 Code validly adopted by resolution to govern the August 17, 2016 election?
  3. 3 Whether broad consensus was required under Chapter 9 of the 1994 Code to amend the election code?

Ratio Decidendi

Applying the reasonableness standard, the Court concluded the Council's resolution could not reasonably be found to reflect the broad consensus required under the 1994 Code; therefore the 2015 Code could not validly govern the August 17, 2016 election and the resolution was set aside.

Court Disposition

Appeal dismissed

Orders

  • Resolution of the Innu Council of Pessamit set aside
  • Appeal dismissed with costs assessed at the mid-point of column III