Ontario October 2011 Take Five

October 2011

Ontario Edition

Inside this Issue:

This month we have summarized what we feel are the five most interesting cases from the Ontario C.A. in September 2011.

We highlight cases from the following areas of law:

Civil litigation; Civil Procedure; Judgments and Orders; Stay of Enforcement - p.3

Bankruptcy and Insolvency Law; Proceedings; Leave to Appeal - p.5

Tort Law; Negligence; Power to Overturn Jury’s Verdict - p.6

Civil Litigation; Exceptions to Parol Evidence Rule; Contracts - p.8

Pensions and Benefits Law; Private Pension Plans - p.10

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O N P O I N TLEGAL RESEARCH

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Agenda- Legal Research: From Problems to Solutions 2011

8:30- 9:00 Registration and Pastries and Coffee

9:00- 9:20 Welcome from Sarah Picciotto, Founder of OnPoint

9:20-10:00 Gregory Pun- “Preparing for the Trek”

- The How and Why of legal research - The importance of obtaining the proper facts, instructions, and scope of the research - Ethical and practice management considerations

10:00- 10:30 Ellen Vandergrift- “Starting Out on the Expedition and Staying on the Right Course”

- The importance of paper and online secondary materials in legal research (texts, digests, encyclopedias and course materials) - Tips on the best secondary sources to use and how to make the most of them - Making good research choices- when to stop, when to take a different path, when to check back with the client or supervising lawyer

10:30- 10:45 Coffee break (with pastries)

10:45- 12:00 Ellen and Gregory- “Navigating the Electronic Terrain”

- Insider tips from research lawyers who performs computer research every day - Cost-efficient uses of electronic resources - Pointers on when to use which resource for what task - Tips on how to construct effective searches and manage search results - Noting up as an essential research tool - Important resources for keeping current

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1:00- 2:00 Meghan Maddigan- “Tackling Legislative Research Like a Pro”

- Making it modern: How to ensure you are looking at the most current, in-force laws - So many sources, so little time: Where to start and finish when looking at legislation - Working backwards: How to trace specific provisions through time - Who said what: Finding judicial consideration of legislation

2:00- 2:20 Gregory- “Legislative Research- Some Roads Less Travelled” - Points on legislative research (electronic and paper) - Hansard, bills, proclamations, regulations, Court Rules - Old and repealed statutes 2:20- 2:45 Ellen- “Mapping Your Route” - Keeping notes for future research or defend research choices - A review of our Research Checklist

2:45- 3:00 Coffee break (with goodies)

3:00- 4:00 Ellen and Gregory- “Time to Take the Plunge: A Sample Research Issue, Step By Step”

Agenda (cont.)

Date: November 15, 2011- 9:00 to 4:00 (continental breakfast starts at 8:30)Format: Live Program with MaterialsLocation: The Sutton Place Hotel, VancouverPrice: After Oct.15: Regular: $495; Paralegal: $425; Student: $295

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BTR Global Opportunity Trading Limited v. RBC Dexia Investor ServicesAreas of Law: Civil Litigation — Civil Procedure — Judgments and Orders — Stay of Enforcement Under Appeal: Justice Campbell

The appellants/defendants were RBC

Dexia Investor Services Trust and Lehman Brothers International (Europe) (“LBIE”). The respondents/plaintiffs were BTR Global Opportunity Trading Limited, BTR Global Growth Trading Limited, BTR Global Arbitrage Trading Limited, and BTR Global Prospector Trading Limited (“BTR”). LBIE is a trading and brokerage company registered in England. BTR placed publicly and privately traded securities with LBIE under various brokerage contracts. LBIE became insolvent in September 2008. BTR started a proceeding in New York and two actions in Ontario to recover its securities. In

the Ontario cases, one was regarding Canadian privately traded securities and the other regarding Canadian publicly traded securities. Although LBIE was aware of the Ontario proceeding to recover private Canadian securities, it chose not to participate. In that matter, it was found that BTR beneficially owned the private securities. LBIE received a copy of that order but took no action. LBIE was named a defendant in the Ontario action for recovery of publicly listed securities. In the New York proceeding, LBIE counterclaimed for a declaration that it owned all the securities- publicly and privately traded, Canadian and American- placed with it by BTR. Both the New York and Ontario actions raised the same issue of the beneficial ownership of the Canadian publicly traded securities. LBIE sought a permanent stay of the action for recovery of the publicly traded securities as the parties had agreed that exclusive jurisdiction over any proceeding relating to their contracts would be with a New York court. The Ontario court refused to grant the stay as BTR had shown “strong cause” as to why the exclusive jurisdiction clause should not be enforced. In July 2011, the Court of Appeal dismissed LBIE’s appeal from that order. LBIE sought leave to appeal to the Supreme Court of Canada, and in early September 2011, perfected its leave motion.

BACKGROUNDCLICK HERE TO ACCESS

THE JUDGMENT

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October 2011


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BTR Global Opportunity Trading Limited (cont.)

The motion for a stay was dismissed. The test for a stay to appeal has

three components: that a serious issue for adjudication has been raised, that there will be irreparable harm if a stay is not granted, and that the balance of convenience favours a stay. The three components encompass the question of whether or not it is in the interests of justice to grant a stay. The Supreme Court of Canada typically only grants leave to appeal in cases of public or national importance, and a provincial appellate court can grant leave to appeal to the Supreme Court only after taking into account the stringent leave requirements in the Supreme Court Act (Merck & Co. v. Nu-Pharm (2000), 5 C.P.R. (4th) (F.C.A.), Ontario Public Service Employees Union v. Ontario ((A.G.) (2002), 158 O.A.C. 113). LBIE’s leave motion raised no issues of national importance and failed to meet the strong cause test addressed by the Supreme Court of Canada in Z.I. Pompey Industrie v. ECU-Line N.V., [2003] 1 S.C.R. 450. Additionally, deference was due to Campbell J.’s order as it was

consistent with the law of the Court of Appeal for Ontario and also the Supreme Court of Canada. LBIE’s claim that it would be irreparably harmed if a stay was not granted also failed. Being forced to attorn to the jurisdiction of the Ontario court would not render LBIE’s leave motion moot. BTR addressed LBIE’s irreparable harm claim, and if LBIE were to deliver a statement of defence, BTR would not require it to be filed with the court, would not argue it amounted to an act of atonement, and would not invoke the jurisdiction of the Ontario courts until LBIE’s leave motion was decided. There was not a court order or involuntary participation required of LBIE as BTR only requested that LBIE file a statement of defence so that it could move ahead with discoveries. Neither a statement of defence nor participation in discoveries amounts to attornment. Any prejudice to LBIE by refusing the stay should not be substantial even if both the New York and Ontario cases proceeded concurrently. Discoveries were to be consolidated, and the risk of inconsistent judgments was practically non-existent, as the Supreme Court of Canada would likely decide LBIE’s leave motion long before the Ontario action went to trial. The balance of convenience was very much against granting a stay.

APPELLATE DECISION

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Lechcier-Kimel (Re)Areas of Law: Bankruptcy and Insolvency Law — Proceedings —Leave to appealUnder Appeal: Justice David M. Brown

The moving party (and respondent by way of cross-motion) was HSBC Bank Canada (“HSBC”). The responding party (and moving party by way of cross-motion) was Jack Lechcier-Kimel (“JLK”). HSBC filed a motion to be

JLK’s request for leave to appeal was refused. Section 193 of the BIA provides that unless otherwise expressly provided, an appeal lies to the Court of Appeal from any order if the point at issue involves future rights. Otherwise, the party must have leave of the court. Elias v. Hutchison (1981), 121 D.L.R. (3rd) 95 (Alta. C.A.) defined future rights as those rights not asserted at the present but that will come into existence

at a future time. At issue was HSBC’s present right to be added as a creditor. JLK’s argument that the decision should be heard by a panel was negated by s. 193, which states that leave can be granted by “a judge” of the Court of Appeal. Under s. 193(e) of the BIA, one factor to be considered in granting leave to appeal is whether the appeal is prima facie meritorious. The applicant must prove that the appeal raises arguable points that create

“a realistic possibility of success on the appeal” (see Ravelston Corporation Limited (Re)) 2007 ONCA 268, at paras. 11-12). JLK’s two grounds of appeal did not meet the test. The original bankruptcy application was brought by JLK and his spouse, MLK, but the two matters are now separate proceedings. In MLK’s proceeding, the court found that leave was required and that adding a party did not raise a point involving future rights.

added as a creditor to JLK’s bankruptcy application, which was granted. JLK filed a notice of appeal from that decision. HSBC brought a motion for an order requiring JLK to obtain leave of court to pursue an appeal under the Bankruptcy and Insolvency Act (the “BIA”), and if leave was required, HSBC requested that leave be refused as JLK’s appeal had no merit. Although arguing that leave was not required, JLK brought a cross motion requesting leave to appeal.

BACKGROUND

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APPELLATE DECISION




October 2011


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BACKGROUND

The appellants/plaintiffs were George Salter (“Salter”) and

Karen Hogan. The respondents/defendants were Dr. Jason Hirst and Nurses Santina Murvella, Kelly Comer, Jackie Logan, Carol Worgan, Molly Coughlin, Sandy Tomaszewski, and Stevenson Memorial Hospital. Salter was admitted to Stevenson Memorial Hospital with severe abdominal pain. The admitting physician, Dr. Hirst, diagnosed “abdominal pain not yet diagnosed.” Over two days, Salter’s condition worsened and his pain increased substantially. A nurse requested that Dr. Hirst reassess Salter, which led Dr. Hirst to transfer Salter to Southlake Regional Health Centre. There, Dr. Deepak Gupta gave a provisional diagnosis of aortic dissection, a life-threatening condition with which the doctor had no experience. As a result, Salter was again transferred, next to Hamilton General Hospital. Immediately upon his arrival,

Salter underwent CT imaging which revealed a distal aortic occlusion or abdominal blood clot. He underwent surgery within a few hours. The post-operative diagnosis of saddle embolus and mesenteric vein thrombosis showed that Dr. Gupta’s provisional diagnosis was incorrect. Due to a lack of blood flow, Salter lost the use of both of his legs. To treat Salter’s problems and avoid injury, he would have required surgery within six hours from the time he began to experience the lower extremity symptoms. Nearly twelve hours had elapsed before Salter’s surgery was completed. Salter sued Dr. Hirst for negligence. Damages were agreed upon, and the only issues at trial were liability and causation. The jury agreed with expert testimony that Dr. Hirst failed to meet the standard of care by not transferring Salter to another facility sooner, and that Dr. Hirst’s decision not to transfer Salter sooner caused his paraplegia. The trial judge, finding that there was no evidence upon which the jury could have found the appellants/plaintiffs established causation, invoked Rule 52.08 of the Rules of Civil Procedure to overturn the jury’s finding of negligence. The appellants sought to have the trial judge’s judgment set aside and have judgment entered in accordance with the verdict of the jury.

Salter v. HirstAreas of Law : Tort Law— Negligence — Power to Overturn Jury’s VerdictUnder Appeal: Justice Margaret P. Eberhard







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Salter v. Hirst (cont.)

The appeal was dismissed. The court held that the trial judge

correctly dismissed the claim pursuant to Rule 52.08. The trial judge found that two reports submitted by vascular surgeons, Dr. Gupta and Dr. Lossing, gave no evidence to suggest what “earlier, leisurely investigation would have shown”. As a result, the appellants failed to provide evidence upon which a jury could rely to find that Dr. Hirst’s delay in transferring Salter caused his paralysis. The vascular surgeons’ reports did not say that if more time had been available prior to Salter’s transfer to the third hospital that he could have reviewed the CT scan results and identified the

blood clots. They offered no evidence that Dr. Hirst’s negligence caused or contributed to Salter’s paraplegia. Under Cotrelle v. Gerrard [2003] O.J. No. 4194 (C.A.), a plaintiff must prove on the balance of probabilities that, but for a doctor’s negligence, the unfavourable outcome would have been avoided with prompt diagnosis and treatment. The vascular surgeons’ reports did state that surgery could have been conducted by Dr. Gupta within the six-hour window of opportunity, and gave no evidence that the correct diagnosis likely would have been made and successful treatment likely would have been completed before the close of this window had Salter been transferred earlier.

APPELLATE DECISION

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BACKGROUND

The respondent/applicant was SeaWorld. The appellant/

respondent was Marineland. Both parties operate facilities for the care and display of captive marine animals. In December 2005, the parties entered into the Mammal Support and Interchange Agreement (“the interchange agreement”) to collaborate on future projects, with each project to have its own separate agreement. Attached to the interchange agreement as exhibits were four specific agreements covering the loan and/or sale of certain sea creatures. In November 2006, the parties executed a breeding loan agreement for SeaWorld to loan a male killer whale named Ikaika to Marineland. SeaWorld gave written notice of its intent to terminate the November 2006 Breeding Loan Agreement upon its expiration on December 31, 2010. The Breeding Loan Agreement stated that it was to be governed by the law of the state of Florida.

Marineland declined to return Ikaika to SeaWorld. SeaWorld brought an action seeking a declaration that the Agreement was properly terminated and ordering the return of Ikaika to them. The application judge held that the Breeding Agreement did not have to be read with the Interchange Agreement as a single contract. The trial judge found that no trial was needed based upon both parties’ expert evidence that Florida law was substantially the same as Ontario law, and further found that the Breeding Loan Agreement permitted SeaWorld to terminate it when it did. Marineland appealed.

SeaWorld Parks & Entertainment LLC v. Marineland of Canada Inc.Areas of Law : Civil Litigation —Exceptions to Parol Evidence Rule — Contracts Under Appeal: Justice Richard A. Lococo







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SeaWorld Parks & Entertainment LLC v. (cont.)

The appeal was dismissed. Consideration of the

circumstances under which a contract was made are part of a court’s interpretive process “to determine the meaning of the contract against its objective contextual sense” (Dumbrell v. Regional Group of Companies (2007), 85 O.R. 3rd (616) (C.A.). However, the Court of Appeal looked also to Eli Lily and Co. v. Novopharm Ltd. (1998), 2 S.C.R. 129 at para. 55, which provides that ambiguity in the words of a contract are required prior to extrinsic evidence being allowed to alter the meaning of the words of a contract. The Breeding Agreement was clear and explicit and constituted the entire agreement

between the parties regarding Ikaika. The Interchange Agreement stated future animal exchanges between the parties would each require negotiation of a single contract. The Breeding Contract was a standalone contract, with its own unambiguous termination provision, and extrinsic evidence could not be considered. It required no reasons to be given for termination, and thus, there was no guarantee of a long-term relationship. The Interchange Agreement envisioned future agreements negotiated between the parties, but specifically provided that its language would control only inconsistencies in the four agreements attached to it as exhibits.

APPELLATE DECISION


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BACKGROUND

The plaintiffs and respondents by way of cross-appeal were

Ronald Sutherland and John Scott on their own behalf and on behalf of the current members, retirees, and other beneficiaries of the defined benefit component of the Dumai Pension Plan, which was formerly the Simpsons, Ltd. Supplementary Pension Plan. The defendants and appellants by way of cross-appeal were Hudson’s Bay Company, Royal Trust Corporation, Investors Group Trust Co. Ltd., and other specifically named individuals.

In 1971, a defined benefit pension plan was established for Simpsons’ employees. Initially, only Simpsons contributed to the plan. In 1976, Simpsons’ employees also began contributing to the plan. The assets of the Simpsons pension were held in a trust fund established and originally governed by an agreement between Simpsons and Canada Permanent Trust Company (the “Trust Agreement”). Both the plan and the Trust Agreement were amended a number of times, and the Trust Agreement was replaced first with one with Investors Group Trust Co. Ltd., and later with one with Royal Trust Corporation of Canada.

In 1979, the Hudson’s Bay Company (HBC) acquired Simpsons and took over administration of the pension plan. The Simpsons plan was closed to new members in 1988. It was reopened in 1994 with an added defined contribution component. Approximately 8000 employees of an HBC subsidiary were made members of the defined contribution component of the plan on a “go-forward” basis, and the name of the plan changed to the Dumai Pension Plan. In 1998, employees of another HBC subsidiary were introduced as members of the plan. Between January 1, 1994 and December 31, 2006, approximately $111 million of surplus assets in the plan were applied to pay employer annual defined contribution costs for the employees of the HBC subsidiaries.

A class of retirees who worked for Simpsons and who were members of the Simpsons pension plan filed suit, alleging that HBC improperly used surplus funds that accrued in the trust fund for the Simpson plan to pay for employer contributions to the defined contribution pensions of the subsidiary employees. The trial judge found that the Plan assets were impressed with a trust in favour of the Plan members, HBC was not a beneficiary of the trust, and that, on termination of the Plan, the Plan members were entitled to any surplus assets in the trust fund. The plaintiffs filed an appeal which was then abandoned. Only the defendants’ cross-appeal, in which HBC challenged the trial judge’s conclusions that HBC was neither a beneficiary of the plan nor entitled to any surplus assets remaining upon termination of the plan, required the court’s attention.

Sutherland v. Hudson’s Bay CompanyAreas of Law: Pensions and Benefits Law — Private Pension Plans —Under Appeal: Justice Herman J.W. Siegel







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Sutherland v. Hudson’s Bay Company (cont.)

APPELLATE DECISION

The cross-appeal was dismissed. The trial judge correctly

concluded that the surplus should be paid to Plan members. Burke v. Hudson’s Bay Co., [2010] 2 S.C.R. 273 is a recent Supreme Court of Canada decision which dealt with the law governing ownership of surplus pension funds. Although the trial judge did not have the benefit of the Burke decision at the time of his decision, his analysis followed the relevant framework set forth in Schmidt v. Air Products of Canada Ltd., [1994] 2 S.C.R. 611, which outlines steps for determining the question of surplus ownership of pension plans. Following the Schmidt framework, the court found:

1. The pension fund was impressed with a trust.

2. The second Schmidt step, which deals with there being no trust, was inapplicable.

3. A trust is governed by equity.

4. The trust explicitly extended to the surplus.

5. No power of revocation had been reserved, and since that power cannot be implied, HBC can claim the surplus on termination only if the terms of the trust so provide.

6. Article 11 of the Trust Agreement clearly intended to establish an irrevocable trust for the exclusive benefit of Plan members and their beneficiaries. Article 2 of the Trust Agreement contained a statement of the company’s intent to part outright with all money contributed to the pension fund.

The court found Burke distinguishable from this case. In Burke, the Supreme Court held that employees had no equitable interest in surplus on plan termination and, therefore, no equitable interest in the actuarial surplus while the pension was ongoing. However, the pension plan documents in Burke gave employees entitlement only to the defined pension benefits upon retirement, and the original plan documentation expressly limited the employee’s rights to receive pension benefits upon retirement. In the present case, from the start, all plan assets were in an exclusive benefit trust for the plan members and beneficiaries.


October 2011


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