Noah Sarna on the issues, cases and events of interest to British Columbia's educational community
UBC Celebrates Legal Victory in Prolonged Discrimination Claim
The storm of controversy and commentary surrounding Cynthia Maughan, the UBC student who alleged discrimination by the university and several professors on the basis of her Christian beliefs, reached what many think is an ultimate conclusion a couple of weeks ago. The BC Court of Appeal for British Columbia released its decision in Maughan v. University of British Columbia et al, which capped something of a litigation nightmare for UBC. The court’s decision on CanLII is here.
Here’s a brief summary of the facts. Maughan was an Anglican Christian pursuing a Masters of Arts degree in English at UBC, during which time she alleged several incidents of discrimination occurred:
- An email was sent to the English graduate student listserv, where a student jokingly suggested Christians should be stoned; and
- She experienced what she said amounted to discrimination in a seminar course, where she asserted an anti-religious bias motivated the course’s professor to treat her poorly.
The professor had agreed to schedule a course event on a Sunday, refused to grant Maughan an extension on her final paper, provided negative comments on that paper, and awarded her an unsatisfactory grade, all of which Maughan attributed to the professor’s opposition to her religious beliefs.
Maughan, disturbed by her experience with the professor and disappointed with her grade, pursued redress through the avenues available within UBC, including an appeal to the Senate Committee, which ultimately ruled against her. She subsequently commenced an action against the professor, UBC and other professors who she alleged facilitated or ignored the discrimination she experienced.
The Court of Appeal emphatically rejected Maughan’s claims. The court held that Maughan presented no evidence to demonstrate that her treatment by the professors was based on her religion. Similarly, Maughan failed to show that they were acting in bad faith, which is a requirement under the University Act (BC) to establish negligent conduct in this sort of relationship.
The decision included a couple of important points for parties involved in these sorts of disputes:
- There is a high standard to meet for claimants attempting to win against a university or professor where something was done while executing duties on behalf of a university (see this provision of the University Act, from BCLaws). They must demonstrate bad faith – like malice or a dishonest purpose - which can be very difficult to prove.
- The strength and legitimacy of internal bodies devoted to dispute resolution is significant. The court referred to UBC’s Senate Committee approvingly as a “quasi-judicial body”.
- Despite the court’s conclusion, the fact that Maughan’s claim received the attention and resources of two judicial levels – requiring UBC to respond with counsel at every turn – shows the degree of concern courts have for university students, particularly ones pursuing advanced degrees. Maughan’s claim consumed a considerable degree of time, money and effort just to be dismissed for no evidence.
This article in University Affairs discusses the decision and other examples of student lawsuits and how universities and their lawyers are confronting them.
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December 28, 2009 - 2:21 pm
Perhaps an interesting comparative light would be that of the Company Town. The definitive case is the US Supreme Court decision, Marsh v. Alabama, 326 U.S. 501 (1946).
Jack Balkin summed it up in “Virtual Liberty” at 2076:
“In Marsh v. Alabama, the Supreme Court held that a town wholly owned by a company could not use its property rights to prevent people from distributing leaflets on its streets. Because the company had assumed all of the major functions of a municipality, it had to obey First Amendment values.”
The comparison, I suggest, is not in the quasi-judicial weight given to the UBC Senate by the BCCA, but in the objectives of the governing bodies and how they compete with the rights of the individuals taking the actions.
In Marsh, we’re looking at company employees whose Freedom of Expression rights are being threatened by the employer that owns the town, and who seeks to profit from the labour of those employees.
In the present case, we’re looking at a student whose Freedom of Religion rights are being ostensibly threatened by the university that “owns” the campus, and who seeks to offer an educational forum.
The goals of the governing bodies are different: one is primarily industrial, and one is primarily educational. Does having a primary goal of education and all that falls under that mantle mitigate the responsibility of the UBC Senate to uphold certain freedoms at the possible expense of their own objectives? Does having that primary goal increase the authority or at least the deference given to that senate?
It would seem that the University Act, as defended by the BCCA, imputes great gubernatorial authority to the UBC Senate without demanding an equal increase in responsibility.
With company towns, the assumption of government powers is coupled with an assumption of citizens’ rights. It seems that the university is able to assume governing, or at least quasi-judicial powers without also assuming an equivalent responsibility to uphold the quasi-citizens Charter rights.
I see this as a dangerous propping up of university gubernatorial power without any balancing increase in responsibility to student rights as citizens. Perhaps the University Act should be challenged using the principles of administrative law as they are broadened to company towns. I’m not familiar with any Canadian company town cases off the top of my head, but there must be something with all the company towns in northern Alberta.
December 28, 2009 - 2:34 pm
Forgot my conclusion:
The difference in goals is very important. The danger of going too far to the Company Town set of rules is that it could impact education. At least, that is how I understand the greater power given by the University Act and deferred to by the Court.
Is it possible that in the intellectual cauldron that a university claims to be, certainly at the graduate level, a certain mitigation of Charter rights is warranted?
Can one say that the pursuit of higher education and the expansion of thought into realms that were only personal potential beforehand requires a sacrifice of rights? The general cultural assumption has been that student life is ascetic to some extent. It is important to do without certain comforts, and to indulge in experiences not necessarily compatible with a normative citizen life, in order to potentiate the intellectual and personal growth afforded by that education.
We agree to live in lousy apartments or basement suites; we agree to eat barely sustaining food; we agree to challenge the philosophical foundations upon which our childhoods were based; and we do all this in the name of academic betterment. Do we agree also to subject ourselves to the whim, often flawed, of professors who may trample certain rights but who have, generally, earned their place in the Ivory Tower?
Is the battle and the scarring not part of the education? If the student is to be completely shielded, how far can education go? If not shielded at all, will the educator go too far (yes, we all know of cases of such abuse)?
Where lies the middle ground, and is it significantly different from that of the Company Town?