This award, established in recognition of former Chief Justice of Manitoba Richard J. Scott, honours individuals who have made significant contributions to the rule of law and the legal profession through scholarship, advocacy, mentorship, and leadership.

Over her distinguished 35-year career at the University of Manitoba’s Faculty of Law, Professor Busby has had an extraordinary impact as a teacher, scholar, and advocate. Her academic work spans many critical areas of law, including the legal responses to gender-based violence, sexual and reproductive rights, 2SLGBTQIA+ rights, civil procedure, constitutional and administrative law, and the human right to water.

Beyond her extensive scholarship and teaching, Professor Busby’s commitment to the legal community is also reflected in her longstanding editorial leadership of the Manitoba Queen’s Bench Rules Annotated, which has served as an essential tool for civil litigators across the province for nearly three decades.

Throughout her career, Professor Busby has advanced the pursuit of justice and equality in Canada. Her work has been cited by courts across the country and has informed both legal education and public policy.

Read the Law Society of Manitoba announcement.

Karen Busby has been with the Faculty since 1988, and she was the founding Director of the Centre for Human Rights Research. She has a J.D. (Manitoba, 1981) and LL.M. (Columbia, 1988). She was called to the Manitoba Bar in 1982 and she practiced for a year with Thompson, Dorfman, Sweatman. After studying in France for a year, she was the first clerk with the Federal Court of Appeal (1984-87).

Professor Karen Busby’s research and teaching interests include gender-based violence (GBV), constitutional law, in particular human rights and equality law, civil procedure and administrative law. The GVB and equality law research is action-oriented, inter-disciplinary and collaborative; civil procedure research involves conventional legal scholarship (a fastidiously technical pursuit); and administrative law marries law and politics. Her research is also directed at diverse audiences including equality theorists (legal and non-legal); students in different disciplines (Law and Women’s Studies); practitioners; judges across Canada and the grassroots women’s movement.

In September, 2021, the Faculty of Law celebrated her more than 30 years of teaching at the University of Manitoba, and the legacy of her contributions to Human Rights research.

Isabel Ross (MacLean) Hunt (1894 – 1990) was the first woman to earn a Bachelor of Laws (LL.B.) degree from the University of Manitoba. She graduated in 1916, was called to the bar in 1917, and was the first woman in Western Canada to establish a law office in 1918. She temporarily withdrew from practice upon getting married, but returned after her husband’s death in 1923. In 1928, she joined the City of Winnipeg’s legal team, served as a solicitor in the department of welfare for 30 years, and was an expert in family law.

In 1952, she was the first woman to receive the Queen’s Counsel designation in the province of Manitoba. In 1983, she received the Governor General’s Award in Commemoration of the Persons Case for her role in improving the status of women in the legal field in Canada.  The Manitoba Bar Association created the Isabel Ross MacLean Hunt Award in 2011 to recognize role models for women lawyers deserving of special recognition.

Host, alumnus and professor, David Ireland kept the program lively with his wit and warmth, making everyone welcome. The faculty’s brand-new Dean, Professor Richard Jochelson brought alumni up to date on current events and upcoming changes taking place at their alma mater. In particular, he shared a number of important experiential learning opportunities now available including the Indigenous People and the Criminal Justice System seminar.  

Manitoba Law Student Association President Michael Badejo shared a perspective of law student life during the pandemic, including the way the student community pulled together this year in the wake of the passing of law school graduate Darius Maharaj Hunter to create a scholarship fund in his memory. Badejo also brought a glimpse of the forthcoming transitional year as the law school returns to the classroom after nearly two full years of virtual learning and expressed hope of restoring and improving connections between students and alumni.

Professor Emeritus Cameron Harvey.

Professor Emeritus Harvey, who normally eschews the limelight, acquiesced – to the delight of his former students and colleagues – to share some anecdotes regarding how he came to teach at the Faculty, including the fact that he nearly studied forestry instead of arts at the University of Toronto and subsequently law at Osgoode Hall, and that in 1966, the Manitoba Law School paid its new professors an annual salary of $7500 per year, which was $500 more per year than Osgoode Hall!

Harvey said that he has loved all three aspects of being a law professor: teaching, researching and writing, and even administration, and that he never experienced stress or tension while teaching. He continues to teach to this day because he quite enjoys it, he said. While Harvey spoke, former students shared in the Zoom chat, memories of Harvey’s notably aggressive hockey-playing (“fighting was allowed and I enjoyed mixing it up,” he grinned), and tough marks they had received from him that were well-deserved.

Professor Karen Busby.

Next, Ireland engaged Professor Karen Busby in a conversation that explored Busby’s journey to the study and practice of law and her pursuit of Human Rights as a legal scholar and inaugural Director of the Centre for Human Rights Research. An award-winning professor, Professor Busby discussed her teaching experiences, her motivation for teaching, and the roles she’d had over the years in various landmark cases in human rights law. Colleagues with whom she had shared these experiences were on the call and knowing smiles of these common memories were witnessed by all.

Any law alumni, faculty or students who missed the event can still watch a recording by emailing the Dean’s office to obtain the link at lawdean@umanitoba.ca.

Professor Busby met with law students in a separate call right before the hearing to answer any questions and help clarify what legal issues the hearing would address. As third-year students, most had already attended various court hearings before, but never something like this. Robson Hall Communications spoke with Professor Busby about the importance of this hearing both as a learning experience for law students, and as a way for the public to understand the role of the courts in enforcing pandemic restrictions. This interview was edited for clarity.

Q: What issues most stood out for our students in your pre-hearing discussion?

Karen Busby: They wanted to know what the likely issues were, what was the test for an injunction or an order that the rule against meetings did not apply to [Springs Church] in the circumstances under which they were meeting. [The church] wanted an interpretation of the order and what was meant by the word ‘meeting.’

We talked mostly about what were the steps to get an injunction. It was my view that the hard thing for [the church] to overcome was the third step, which is the balance of convenience: “Is it better in the end to grant the injunction or not grant the injunction?” I wanted them to better understand the advocacy that would be going on.

Q: Was this new material for the students, or does this typically get covered in law school?

KB: It doesn’t necessarily get covered. It might be covered in civil procedure, and in remedies. [Otherwise] a law student might not encounter such a matter in school.

The level of advocacy was really terrific. That was great, especially because they were working under tremendous pressure. The hearing was on a Saturday. It got moved ahead really quickly, and involved a lot of complicated questions.

There had been pre-hearing conferences between the lawyers and the judge prior to this Saturday call. They had agreed on what were the exact issues that needed to be determined at this time. So each lawyer had an hour to present their case on the two issues that were the particular focus of this hearing.

The bigger case involved a charter challenge, but this hearing was simply an injunction – that is, a remedy sought in the context of a larger claim. You have to file a statement of claim alleging various wrongdoings, and then you’re asking for an immediate remedy to stop the wrongdoing. So you don’t decide all the issues in the statement of claim, but you decide whether or not on balance, it’s a good idea to issue an injunction to stop the behavior now. And it’s hard to get an injunction.

Q: What key lessons did you hope students would take away from this experience?

KB: Of the legal points, what is the test for an injunction, and then also the way the issues really crystallized into two or three very discrete specific issues that needed to be resolved. It was a classic case of – there’s a million issues, and these were the two key things. And that took a lot of cooperation on the part of the lawyers not to take a “throw in the kitchen sink and see what happens” kind of approach, but actually sit down and really seriously think through what needs to be decided now. And the advocacy was excellent. The cooperation between counsel was excellent. The supervisory role played by the judge was excellent. It was just a fantastic example of good advocacy all around.

Right now, our students are craving that practical experience, something that’s missing this year. And we felt like we were in the courtroom – it was a very real experience.

Q: What should every lawyer representing either party keep foremost in mind, either defending or bringing this challenge? One day, our students may find themselves on each side of the courtroom in those lawyers’ shoes.

KB: When you’re doing litigation, it’s a fine balance between Blue-skying, what possible arguments you can make – so you come up with a huge range of ideas about what you can possibly argue, and then you have to start winnowing, figuring out, what are the real issues here. And that’s the hard job. You want to be creative in big thinking. And then you want to be practical, and dive deep into the issues that you need to get in. That’s why we see cases are very different at trial than they are, say, before the Supreme Court of Canada, because issues become so much more crystallized. It was just really fantastic to see the issues crystallize, in this case at an early stage.

Q: Chief Justice Joyal ultimately ruled against the application of Springs Church to be able to gather, but then the province allowed drive-in church gatherings. How are the courts to work with such constantly changing rules as in this example when the province had a change of heart and said, “Well, maybe that wasn’t such dangerous behavior after all, and maybe it’s okay for people to do this”?

KB:  Part of that is “what are the proper institutional roles for governments and for courts?” Joyal’s point in a nutshell in his decision is that in an emergency situation, it should be governments that make the decision about what should be in public health orders, not courts. So, if government had issued a public health authority, that says no public gatherings and the way they define public gatherings included in particular, configuration of church and our cars, then courts should not second guess that, and that’s a totally defensible position. But in some ways, you could take it as an invitation: don’t ask the court to interpret and change this rule. Ask the government to interpret and change this rule. It’s not surprising that the church went back to the government and said, “Look, reconsider this rule, because it doesn’t make sense.” And the government said, “Okay, yes, we reconsider it. You can have church in your cars.”

So, it wasn’t a lost effort – it was all necessary to get to this point.

The difficulty about working with courts is, it’s non-specialist judges working in isolation on issues they might not know a lot about, like public health and pandemic control. And, although in this case where the lawyers did an amazing job, it’s a constantly changing evidentiary situation. The Rules of Civil Procedure are not well suited to managing information and managing change and managing uncertainty. That’s better done around a corporate table, than across a courtroom.

Q: What are the main takeaways for students learning about Charter rights? And members of the public who are reading the newspaper and trying to understand what are their rights?

KB: There was an injunction sought in Alberta yesterday, but it was for a million different things. It just seemed to me that that application was lunacy compared to this one, because they were seeking to have so many rules interpreted by the court. And if the court was reluctant to reinterpret one rule in Manitoba, I don’t see how any court would reinterpret 10 or 20 different rules, as was requested in Alberta. So, the key takeaway for me from this was preparation in litigation. Creative thinking is important in litigation. Willingness to crystallize issues is really important to litigation. Although we often think of courts as being activist in Canada, courts actually are quite conservative, and they don’t step in unless there’s very good reason to step in.

Q: Last thoughts?

KB: One of the things that’s really interesting for me is that the process worked really well, being on conference call. I think going forward, we’re going to see way more hearings conducted by conference call. If you can do it from your home, or you can do it from your office, why would you go to the courthouse?

Some religious and civil-liberties organizations assert that laws making masks compulsory or forcing the closure of non-essential businesses violate rights to religious freedom, mobility, security and personal liberty that are protected by the Charter of Rights and Freedoms.

These organizations might be correct that charter rights have been violated, since the threshold for establishing a rights violation is low. Idiosyncratic religious beliefs and practices are charter-protected as long as they are genuine. Yet court challenges to the face-mask and business-closure laws based on charter rights violations are bound to fail.

Finding a rights violation is only the first step in a charter analysis. Governments may violate charter rights as long as the violation is a “reasonable limit” that is “demonstrably justified” in a “free and democratic society.” All government laws and policies should be vetted for charter compliance before they are passed.

The federal minister of justice posts this evaluation for new legislation on a government website, but Manitoba’s regime lacks this transparency. People affected by laws and policies who dispute the government’s justification for limiting rights can ask Canadian courts to examine this justification more closely.

Ever since Confederation, courts have been reluctant to interfere with the types of actions governments take in response to emergency situations, such as laws dealing with wartime shortages of goods or high inflation. While these historic cases were formally decided based on the division of powers between provincial and federal governments, their premise is judicial reluctance to interfere when governments are making very difficult decisions.

The first question a judge asks in evaluating whether a limitation on charter rights is reasonable and demonstrably justified is whether there is a “pressing and substantial” need for the government to respond to a problem. The answer to this question in the face of COVID-19 is obviously “yes,” as we need a considered government response to controlling a worldwide pandemic without unnecessarily undermining the economy.

The next step in determining reasonable justification for charter rights violations is to ask whether the government’s response is proportionate to the harm. First, judges must ask: is there a rational connection between the means to achieve a goal and the goal itself? In other words, will the law do what the law says it will do? Second, judges must ask: is there a less intrusive way to achieve the goal?

While almost no one would say the government should not respond at all, there are legitimate differences of opinion about whether the pain of an almost-total shutdown of the economy will more effectively curb viral transmission than a partial shutdown.

Canadian courts have consistently held that elected politicians, not judges, should have the final say regarding how governments should respond to a novel situation or make decisions when the available research is inconclusive or emerging. Judges will also be deferential when governments are acting to protect vulnerable groups.

As all three of these yield signals are present in the case of COVID-19, judges would defer to political decision-makers unless their decisions were manifestly disproportionate.

It is really a matter of common sense that elected officials, civil servants, public-health experts and economists vigorously debating around a table will make better decisions about what measures are proportionate to the harm than a single judge who may have no training in public health or economics.

Moreover, elected officials are more nimble in responding to new evidence and local conditions than a judge bound by cumbersome procedural and evidentiary rules.

She agreed to spend six months consulting across campuses to come up with a plan. Eleven years later, Busby is stepping down as founding director of the university’s Centre for Human Rights Research, formally established in 2012.

She will continue to teach and research full-time in the Faculty of Law while supporting the centre’s new director Dr. Adele Perry, whose term starts July 1.

The Centre for Human Rights Research co-ordinated proposals that brought the National Centre for Truth and Reconciliation to the University of Manitoba in 2015 and established Canada’s first interdisciplinary Master of Human Rights program in 2019. Busby also co-edited the first book inspired by the museum.

No wonder she has a reputation for getting things done.

The Centre for Human Rights Research, started by the faculties of Law, Arts, Education and Social Work, fosters the kind of interdisciplinary research that is too complex for individual professors to manage. Its most ambitious research project has been on the human right to drinking water and safe wastewater disposal in First Nations. Busby brought together Indigenous and non-Indigenous scientists, social scientists and community partners who raised almost $2 million from Canada’s three main research granting agencies.

“We were really instrumental in keeping the issue on the table – not letting it get lost,” she says. “At the same time, we helped build capacity in non-Indigenous scholars to work with Indigenous scholars and community workers and vice versa.”

Psychology professor Dr. Kathryn Starzyk’s research explored which types of advocacy messages are most likely to encourage Canadians to care about First Nations water issues. She believes she wouldn’t have been able to progress with that research nearly as quickly without Busby’s support. “The university is so lucky to have had her in this role,” Starzyk says.

“She provides people an opportunity to do work that has relevance outside of academia – to connect people to their community. It’s exactly what a university should be.”

Busby is thrilled that the centre’s research on surrogate mothers and water rights is now being used to help prepare court cases that may advance human rights.

“You don’t publish research and suddenly the law changes,” she says. “You publish an opinion column and that gets an idea out there and other people are attracted to the idea and then other people coalesce around it and come up with new strategies.”

She also recently co-authored a guidebook on how to handle campus sexual violence complaints.

Most years, the Centre for Human Rights Research hires half a dozen part-time student research assistants, while other students volunteer through the centre’s Student Speakers Bureau to deliver human rights presentations in high schools.

“I think we helped train a lot of students,” Busby says.

The centre’s first research assistant, Dayna Steinfeld, is now a lawyer at one of Winnipeg’s top firms. She puts Busby’s human rights training into practice in employment law and with sexual assault complainants, as well as teaching a course on the Canadian Charter of Rights and Freedoms at the Faculty of Law.

“Karen really took the time when I was her research assistant to talk through her thinking with me,” Steinfeld says. “She has just done so much to make an impact for me and I think for so many others at the university.”

*****

It’s no surprise that former University of Manitoba provost Dr. Joanne Keselman turned to Busby for advice in 2009 on how to co-ordinate and grow the university’s human rights expertise.

She already had a national reputation as a human rights scholar and advocate.

Busby’s passion for justice was born in a Winnipeg junior high school where she was streamed into non-academic classes because of assumptions based on her family’s circumstances. Her mother had moved the family from Edmonton to Winnipeg to avoid schoolyard bullying after Busby’s father was charged with armed robbery.

The mistaken belief that Busby had little academic potential “made me really aware of systemic inequalities from the tender age of 13 and it also made me a fighter,” she says.

Busby worked part-time to pay for university, including in research assistant positions that were “super influential.”

While in Ottawa clerking for federal Court of Appeal judges, Busby volunteered for the rape crisis centre, giving talks about sexual assault law reform to high schools, Rotary clubs and nursing associations.

She learned how to explain legal concepts in plain language – a skill that keeps her in high demand as a media commentator.

“I think we have an obligation as academics to get our work out there in the public domain,” Busby says, encouraging other researchers to get media training if they’re nervous.

After she became a law professor in 1988, Busby developed a taste for strategic litigation by helping with a feminist intervention in an obscenity case. That set the direction for a career pursuing law reform on emerging and controversial human rights issues.

In 1999, the Supreme Court of Canada quoted Busby’s research on discriminatory use of complainants’ personal records in sexual violence cases. That same year, she argued before the Supreme Court on behalf of a feminist organization challenging censorship of queer literature. Busby then helped win the fights for same-sex marriage in Canada and broad legal recognition of same-sex partners in Manitoba. Those achievements have been recognized by a string of awards.

Starzyk says Busby is a role model for how to be both assertive and graceful in academic spaces that are not always welcoming to women. “I just really admire her.”

Busby is leaving her position as director of the Centre for Human Rights Research before the end of her term to focus on teaching and completing her own research. She is a co-investigator on three large grants funded by the Social Sciences and Humanities Research Council, including one on why so few sexual assault cases result in convictions. Her energy level has diminished since she was diagnosed with Parkinson’s disease about a decade ago, so she decided to hand over the idea-generating and network-building work of running the research centre.

Busby is pleased to see the Centre for Human Rights Research taken over by another feminist who already has strong relationships with Indigenous communities and scholars. She expects more Arts students will become involved under Perry’s leadership.

“Anyone drawn into decision-making on a campus sexual violence complaint faces a steep learning curve,” the book description reads, summarizing that the authors “take readers through the procedural, evidentiary, substantive and discretionary legal issues that can arise when these complaints are made.”

The authors explore the interface between the legislative requirements to adopt stand-alone sexual violence policies and other norms, including common law principles and other legislation especially privacy laws. Their survey of 25 sexual violence policies from across the country reveals widely divergent approaches to issues such as the availability of interim measures; whether to suspend campus proceedings if a criminal charge is laid; complainants’ right to participate in the process; and, privacy issues related to disclosure of the existence of a complaint, investigation and other reports and outcomes, and the right to cross examine.

More fundamentally they explore whether the objectives animating sexual violence policy complaint-based processes may be in conflict. Most would say that these policies should be about challenging gender-based violence, encouraging a culture of response, restoring or creating safety, and ensuring that complainants’ needs are met. These are human rights objectives. But, is discussed throughout the book, especially where these policies are grafted onto student discipline policies and focus on individual wrongdoing, their focus becomes disciplinary. Disciplinary objectives may encourage a culture of denial and focus on the procedural rights of respondents.

Next, the Faculty learned that Professor Karen Busby has contributed a chapter to LGBTQ2+ Law: Practice Issues and Analysis recently published by Emond, edited by Joanna Radbord. Also just recently, Richard Jochelson and University of Regina, Justice Studies colleague, James Gacek have co-edited a book on Sexual Regulation and the Law: A Canadian Perspective published by Demeter Press, featuring papers by Robson Hall law students and recent graduates.

Jochelson and Ireland’s new book Privacy in Peril: Hunter v Southam and the Drift from Reasonable Search Protections from UBC Press, was third place on McNally Robinson’s Bestseller list for Paperback Non-Fiction last week. 

During its visit, the SCC heard two cases,  K.G.K. v. The Queen, a criminal law appeal as of right from Manitoba, and Conseil scolaire francophone de la Colombie-Britannique, Fédération des parents francophones de Colombie-Britannique, et al. v. Her Majesty the Queen in Right of the Province of British Columbia, et al., a language rights appeal from British Columbia. After their formal business had concluded, all nine judges visited Robson Hall on their last day in Winnipeg.

“The Robson Hall community was honoured to welcome the Supreme Court Justices to the University campus, and to have them spend time with our students,” said Dr. Jonathan Black-Branch, Dean of the Faculty of Law.  “Throughout the history of Canadian legal scholarship and education, the entire legal community, from students to lawyers to academics, has looked to Supreme Court of Canada decisions for guidance as we constantly seek ways to improve justice for all Canadians.  It was very inspiring and meaningful to our law faculty community to have a chance to hear from these very learned individuals in person.” 

Jonathan Black-Branch, Dean of Law (centre) greets all nine Judges of the Supreme Court of Canada as they arrive on campus to meet with law students. Left to right: the Hon. Rosalie Silberman Abella, the Right Hon. Richard Wagner, P.C. Chief Justice of Canada, the Hon. Michael J. Moldaver, the Hon. Suzanne Côté, Dean Black-Branch, the Hon. Russell Brown, the Hon. Sheilah L. Martin, the Hon. Malcolm Rowe (behind), the Hon. Andromache Karakatsanis, and the Hon. Clément Gascon

Three groups of three judges each met with each of the three years of law students. Speaking to full rooms, the judges answered questions, and shared stories and laughter, revealing the human faces behind the important, precedent-setting judgements that every law student in Canada must study.

Questions included “Do you ever doubt yourself when writing your judgements?” and “What career advice would you give to law students?” The answers were candid and inspiring, with judges encouraging the students to carry on with their career pursuits despite any hardships life brings.

The Hon. Justice Moldaver answers a law student's question in the Common Room at Robson Hall. Left to right: Prof. Karen Busby, Director of the Centre for Human Rights Research; the Hon. Freda Steel, Manitoba Court of Appeal; the Hon. Michael J. Moldaver; the Hon. Malcolm Rowe; the Hon. Sheilah L. Martin

While the sessions were for law students only, some advice shared that everyone can benefit from included wise words from the Honorable Justice Rosalie Abella, who said, “My advice to you is, don’t listen to anyone’s advice,” and added that students should “do what is right for you.”

Along the same lines, Chief Justice Richard Wagner said, “You have to trust yourself. That’s the best advice I can give you.” As other members of the legal profession can appreciate, he further admonished students that, “Lawyers speak truth to power – lawyers also have to be careful with the power they wield.”

Now that the Supreme Court is back in Ottawa, members of the public can watch their hearings live on the Court’s website.

Related:

• News Release – Judges of the SCC arrived in Winnipeg – September 22, 2019
• News Release – Judges of the SCC have concluded their visit to Winnipeg – September 25, 2019

Professors Richard Jochelson and David Ireland have, for a second time in a row, been part of a successful SSHRC) Insight Grant team for more research on jury work. The project on which they are co-investigators is entitled “Jury Representativeness in Canada: Representative or Not?” and has received a $174,260 grant. Dr. Michelle Bertrand, a psychologist in the Criminal Justice Department at the University of Winnipeg, is leading the project, which will be studying issues of representativeness in the Canadian jury context in relation to participation in justice-making by vulnerable communities including Indigenous persons and Persons with Disabilities.  The study has a three-year term and coincides with the same research team’s other five-year-long SSHRC on jury work entitled “Understanding justice: Jury comprehension of Canadian judicial charges in the criminal law.” The Robson Crim team is focusing on making Robson Hall a leading site for the academic study of jury work in Canada.

Professor Ireland, together with Professor Karen Busby, Director of the Robson Hall-based Centre for Human Rights Research, was also a co-applicant on a successful Insight Grant team led by Dr. E. Jane Ursel, a professor in the University of Manitoba’s Department of Sociology and Criminology on a project titled, “Impervious to Change? A Mixed Methods Analysis of Criminal Sexual Assault Complaint Attrition Rates.” The project received $268,50 in SSHRC support.

Professor Lorna Turnbull was a co-applicant on two successful SSHRC Insight Grant projects, one titled, “Indigenous Youth Aging out of the Child Welfare System in Manitoba: Where do we go from here?” which received $373, 539, and is led by Dr. Roberta Woodgate of the University of Manitoba’s College of Nursing, Rady Faculty of Health Sciences. The other project, “Quantifying Social Disparities in Youth Justice System Trajectories – Evidence to Inform Policy Change” received $252, 756 and is led by Dr. Marni D. Brownell, Associate Director, Research, and a Senior Research Scientist at the Manitoba Centre for Health Policy.

A full listing of the most recent SSHRC Insight Grant Recipients is available to read on the Government of Canada website.

Related:

Robson Hall Faculty of Law professor leads major SSHRC-funded research on improving Canada’s criminal justice system

Addendum:
Professor Busby is also a co-applicant on a successful SSHRC Insight Grant project titled “Surrogates’ Voices: Exploring Surrogates’ Experiences and Insights,” which received $260,000 and is led by Vanessa Gruben, an Associate Professor of property and family law and Vice Dean of the English Program at the University of Ottawa.