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MacDonald Laurier Institute

Peterson’s case demonstrates where professional regulators have gone astray

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From the Macdonald Laurier Institute

By Stéphane Sérafin

Professional regulators are losing sight of the purpose their disciplinary authority is supposed to serve, to protect society by preserving professional competence.

Members of restricted professions – doctors, lawyers, accountants and psychologists, among others – are subject to the disciplinary authority of their respective professional regulators. This arrangement is intended to ensure a minimum level of professional competence and to protect those relying on these professional services.

This has obvious advantages over purely market mechanisms, at least in theory, owing to the fact that professional regulators can set standards for members that apply before a member has engaged in serious professional misconduct. However, professional regulators have attracted significant controversy in Canada over the past few years as attempts to police members’ off-duty speech and conduct have become a recurring news item.

The problem is that professional regulators are losing sight of the purpose their disciplinary authority is supposed to serve – to protect society by preserving professional competence – and are policing members values for the sake of perceived reputational interests.

While it is tempting to conclude that the difficulties in these controversial cases arise from straightforward regulatory overreach, the problem is more complex. The fact is that regulators have always had the ability to police off-duty conduct, and for good reason, since such conduct may bear directly upon member competence. It is not that regulators are suddenly policing off-duty conduct which used to fall entirely outside their purview, but that the kinds of expression they are trying to censor are no longer focused on protecting society from an incompetent professional but on protecting themselves and their colleagues from association with political views which they find distasteful.

Professional regulators should reverse course, return to their mandates, and focus on ensuring professional competence, not political alignment, among their members.

Consider the best-known Canadian controversy concerning former University of Toronto professor-turned-social-media-influencer Jordan Peterson. As a member of the College of Psychologists of Ontario, Peterson was ordered to undergo social media training following complaints that his social media posts were discriminatory and unprofessional. The College felt that it could make such an order against Peterson without subjecting him to a full disciplinary procedure. It also felt that it could do so solely on the basis of complaints that did not originate with his clients, but arose out of positions that he had publicly staked out on controversial political and cultural issues.

When Peterson challenged the decision through a judicial process, the Ontario Divisional Court found that the College’s decision was reasonable. The Court was of the view that professional regulators had always held the requisite jurisdiction to police member expression, even when that expression did not arise in the context of a member’s strict professional activities. This included the capacity to police expression considered “discriminatory”. Moreover, it was thought to be enough that the expression might adversely impact the reputation of the psychology profession.

The principles invoked by the Divisional Court in this case are difficult to contest in the abstract. To recognize the authority of a professional regulator over a given profession, rather than relying on market mechanisms to ensure basic competence, means that the professional regulator must take a broad view of the kind of conduct that could fall within its ambit.

It would be difficult to claim that the off-duty conduct of a member is entirely without interest for professional regulators, since such conduct can be relevant to determining whether a particular person is fit to remain a member in good standing. An individual who commits a sexual assault outside of work hours, for example, is probably not fit to act as a clinical psychologist, just as someone who embezzles funds in a context divorced from his or her work should probably not be allowed to operate a trust account as a lawyer. No doubt, certain forms of expression that are not directly connected to the member’s professional activities – defaming others, threatening violence, or airing confidential information other than client information – raise similar concerns.

Criminal and civil court processes are not designed to address these concerns, since their purpose is to establish a criminal infringement of community norms and civil liability towards another person, respectively. Not all criminal acts or civil wrongs necessarily impugn a member’s professional competence, and conversely, there may be grounds to sanction a member where the threshold for criminal or civil liability has not been met.

But to say that professional regulators ought to have jurisdiction over the off-duty conduct of their members is one thing; to determine what type of off-duty conduct, specifically, properly attracts their disciplinary jurisdiction is another. The trouble with the Peterson case, as with many of the other recent Canadian controversies, is that the justification offered for the exercise of professional regulatory jurisdiction does not fit the paradigm offered by the examples just referenced, in which the off-duty conduct, including off-duty expression, can be taken to cast doubt on the member’s ability to carry out his or her profession. Instead, these cases present the regulation of off-duty expression by regulators in a manner analogous to the employment context, where the concern is not with the protection of the public interest, but in allowing employers to preserve their own reputation and to avoid vicarious liability for the acts of subordinates.

The view suggested by the Divisional Court in the Peterson case – that professional regulators are simply doing what they have always done – misses the widening focus of regulators beyond professional competence. This widening focus has been precipitated by at least two factors.

First, technological shifts have significantly altered the balance of power between professional regulators and individual members of the public. In an era of social media, an opinion that would have once been expressed to a small audience now finds itself exposed in some cases to an audience of millions. The possibility that someone, somewhere, will find offense, or decide to find offence, with the expression of opinions grows with the scope of the audience. Moreover, the nature of social media is such that any member of that audience can react, in real time, individually or in concert with others, to the opinion being expressed. This means that potentially every public utterance, whether reasonable or not, creates a reputational risk not just for the individual member, but also for the broader profession. Professional regulators are unsurprisingly concerned by this possibility, which affects their own vested interests.

Second, and perhaps more importantly still, broader cultural shifts have also significantly altered the kinds of expressive content that regulators are likely to treat as “unprofessional” or otherwise raising reputational concerns.

Consider another decision, Simone v. Law Society of Ontario, which was narrowly decided by the Law Society of Ontario Tribunal (the body charged with adjudicating complaints against Ontario lawyers and paralegals). In that case, Lisa Simone, an individual seeking membership in the Law Society of Ontario as a paralegal, was subject to “good character review” because of social media posts that she had made which were, among other things, critical of vaccine mandates, the Black Lives Matter organization, and “pride” events. While the Tribunal ultimately decided in favour of the candidate’s good character, and thus her admission as a paralegal, a majority did so apparently on the sole basis that the candidate had expressed remorse for the social media posts in question.

As with the Peterson case, the comments that landed Simone into trouble were associated with positions on the “right” of the political spectrum. They were also brought to the attention of the Law Society through complaints by members of the general public, and were used against her outside of a formal disciplinary proceeding. In other words, this was also not a classic case involving a disciplinary proceeding brought for off-duty conduct that undermined confidence in Simone’s ability to work as a paralegal. Rather, the concern was that the social media posts themselves reflected poorly upon the profession, not just because of their tone (though this was the formal argument made against Ms. Simone’s accreditation) but also, ostensibly, because of their content. This appears to be why the majority in that case repeatedly reaffirmed Ms. Simon’s obligation to comply with human rights laws, as though the mere expression of views critical of vaccine mandates, the Black Lives Matter organization, and “pride” events might infringe those obligations.

To say that professional regulators appear increasingly concerned with the reputational interest of their profession is, in this context, to say that professional regulators appear increasingly concerned with the appearance of complying with narrow cultural and political orthodoxies. These are “orthodoxies”, since they are views that are now largely taken for granted among much of the professional class, or at least among those individuals who are most likely to staff professional regulators and make decisions concerning member conduct.

Where a member of a restricted profession expresses personal viewpoints at odds with these admissible perspectives, the concern is not that the member lacks the requisite competence to exercise their role. Rather, the concern is that the mere expression of these views is “unprofessional”, in the sense that they are potentially damaging, or at least embarrassing, to the profession. That is, the expression of this views is “unprofessional”, owing to the fact that the member’s personal opinions are at odds with the values that the regulator thinks the profession should embrace.

That said, while the opinions that have run afoul of professional regulators have typically been associated with the “right” of the political spectrum – as in the Peterson and Simone cases – there have also been cases in which the authority of professional regulators has been invoked to punish those expressing views more typically associated with the “left”. In one particularly notable incident after the October 7 attacks on Israel by Hamas, students enrolled at the Faculty of Law at Toronto Metropolitan University (formerly Ryerson University) circulated a letter that purported to express solidarity with Palestinians, but also included language referencing a right of “resistance”. Many in the legal profession interpreted the letter as condoning the October 7 terrorist attacks. This prompted calls to deny the students articling positions (a requirement of lawyer licensing in Ontario) and potentially to deny them accreditation altogether.

This and similar cases that have arisen since October 7 may well suggest that the phenomenon that has until recently targeted mostly “right”-coded political opinions may now be weaponized by either side of the political spectrum.

What each of these cases undoubtedly serve to highlight, in any event, is a need to recover the importance of professional competence as the aim of regulators. Ensuring professional competence is the very reason for which professional regulation exists, and why determinations as to who can exercise these particular professions are not left solely to the market.

Canadians need professional regulators to return to their mandate: ensuring a minimum level of professional competence and protecting those relying on professional services. Regulators should not concern themselves with whether the opinions expressed by members are potentially embarrassing because they happen to fall outside the “values” that regulators believe professionals should embrace.

Stéphane Sérafin is an assistant professor in the French Common Law Program at the University of Ottawa.

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armed forces

Federal government “not serious about defence,” warn Canadian military leaders

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From the Macdonald Laurier Institute

J.L. Granatstein for Inside Policy

“The current prime minister of Canada is not serious about defence. Full stop. A large number of his Cabinet members are not serious about defence. Full stop.”

The Communist regime in China ramps up its aggression against Taiwan, while actively interfering in the political processes of Western democracies – including Canada. In Europe, Russia wages a brutal full-scale war against Ukraine, while sabre-rattling about nuclear strikes on our NATO allies. Meanwhile, Russian President Vladimir Putin’s Arctic ambitions threaten our sovereignty in the North.

With danger all around, one would think Canada’s federal government, led by Prime Minister Justin Trudeau, would be sounding the klaxon – rallying the country and steeling its citizens for looming conflicts with authoritarian regimes while bolstering our military for 21st-century warfare.

Alas, that seems to be far from the case, according to a pair of senior Canadian military leaders who warned recently about the federal government’s lack of commitment to and support of the military.

Over the course of four media reports that were published between May 12 and June 30, 2024, we heard the opinions of Lieutenant General (Ret’d) Andrew Leslie, and General Wayne Eyre, the Chief of Defence Staff who is retiring later this summer. Leslie, a former Liberal MP, was featured in the National Post on May 12 and again on June 30. As for Eyre, he appeared in an Ottawa Citizen article on June 20, and then in an end-of-term interview with the National Post on June 30 – just two days after the federal government announced the beginning of construction planning for the Royal Canadian Navy’s proposed fleet of fifteen destroyers.

Of these four articles, Leslie’s were by far the most important. The former Chief of Land Staff had retired from the Canadian Armed Forces to run for the federal Liberals in 2015. Elected to Parliament, he served four years – but then decided not to run for re-election. If Leslie was disillusioned, and he was, he kept silent in public until his National Post interviews. His remarks were extraordinarily blunt, but they seemingly failed to attract the public notice they deserved. Here in point form are some of his comments from his first interview:

  • “The current prime minister of Canada is not serious about defence. Full stop. A large number of his Cabinet members are not serious about defence. Full stop.”
  • “Our NATO allies are despairing. Our American friends are frustrated.”
  • “[T]he Liberal government has no intention of meeting [the NATO standard of] two per cent (by 2030) and no intention of meeting 1.76 per cent [of GDP] (as promised in the April 2024 budget) because they rest confident in the smug knowledge that the Americans will always defend us.”
  • “Since 2015, the Trudeau government has not spent, re-profiled, re-allocated, deferred, or lapsed $20 billion that was promised for defence. The impact of that is that ship fleets have not been replaced, aircraft are extraordinarily old, as are helicopters; the army is in a state of despair.”

These remarks from a former senior officer are, to my mind, devastating – much more so than those from Opposition politicians or academic experts. So too were the remarks Leslie offered on June 30:

  • “According to the numbers I have 72% of the army’s vehicles and trailers are offline…. I think the big issue is, right now, the men and women in uniform don’t see any demonstrable proof that the federal government is actually seized of the issue of trying to get them the capabilities they need to better defend Canadians.”
  • “The Liberal government sees defence spending as discretionary… They believe there’s a whole host of societal funding requirements, ranging from increases in healthcare, to day care, to children getting breakfast at school – and a bewildering array of boutique allocations of funds to cater to voter-sensitive initiatives. And defence comes after all of that.”

One area of special concern, Leslie maintained, was artillery shells, one of the many military items Ukraine needs in huge quantities. Canada, he stated, was falling down in producing them: “Canada has a tiny stockpile of 155-mm ammo…. One to two years prior to Russia’s latest invasion of Ukraine in 2022, a bunch of idiots decided to cancel the standing offer [with the two Canadian manufacturers of 155-mm artillery shells] because there was no business case for Canada to continue investing in the production of ammunition.”

Leslie ended the second interview by talking of those leaders he admired: “I had the privilege and honour to be in close proximity to three consecutive prime ministers who made the system work such that we bought tanks, artillery ammunition, small arms ammunition, helicopters, guns, armour-protective vehicles, new weapons systems, the list goes on. And those were Prime Minister [Jean] Chrétien, Prime Minister [Paul] Martin, and Prime Minister [Stephen] Harper.”

The general had been a member of the Trudeau government and had worked in drafting the Liberals’ defence platform in the 2015 election. But nothing had been done to implement it in a timely fashion. In Leslie’s list of prime ministers who took defence and national security seriously, Trudeau was notably absent.

The Ottawa Citizen article, by veteran defence reporter David Pugliese, was not a direct interview with General Eyre, but rather, a report on comments Eyre made behind closed doors in a speech to senior officers. Pugliese did not have a copy of Eyre’s speech but learned of it from an audience member.

According to Pugliese, Eyre, who only had a few weeks left as Chief of the Defence Staff, sounded almost optimistic about the Liberals’ 2024 budget that pledged $8 billion in new defence spending by 2030 and $73 billion more over twenty years.

Eyre reportedly told the officers, “Yeah, this policy was not as fast as we wanted it to be. And it did not give us everything we needed. But I will tell you it’s more than I expected, much more than I expected…. The prime minister told me that defence spending is only going in one direction and that is up.”

The general also reportedly spoke of creating a small team to work out an implementation plan for the new defence policy initiatives, and that he wanted some “quick hits… I see ammunition production as one of those quick hits that we absolutely have to get on with.”

In his interview with the National Post on June 20, Eyre was at times both pessimistic and positive in his assessment of the Canadian military: “[The world has entered a] pre-wartime security environment… If you’re in uniform, you learn to be pessimistic about the security situation because you’re trained for the worst case… Given the indicators and the trends that we see, I am pessimistic about the security situation…. Is this a 1938 moment? Is this a 1912 moment? The world has seen this before, with ebbs and flows, and we’re back in a multi-polar dangerous moment where the structures that have kept us generally at peace are fraying.”

If Eyre is right, Canada should be preparing for a war that is certain to affect Canada and its allies. But the Canadian procurement system for munitions and equipment is broken – a fact that Eyre freely acknowledges: “We are applying peacetime processes and peacetime mentalities to what could be considered a wartime or immediate pre-wartime security environment. So, what did we do in 1939? What did we do in 1914? We certainly didn’t take 10 or 15 or 20 years to get capabilities in place, because the war would be over by that point…. We have to deliver, and we have to deliver fast.”

The Chief of Defence Staff then spoke optimistically about Canada’s role in Latvia, where the Canadian Armed Forces leads the NATO brigade stationed there, and where the commitment is supposed to be increased in the next few years.

“We are very well respected in that part of the world,” Eyre said. “Do they want more of us? Yeah, absolutely, but for me it drives home that we produce a pretty good product…. [Canada] has and can do so much on the world stage. Compared to the majority of countries out there, we have got so much going for us.”

On June 28, 2024, Minister of National Defence Bill Blair and Angus Topshee, the Chief of the Naval Staff, announced the government’s plans to replace Canada’s Halifax-class frigates. Fifteen new destroyers would be constructed at the government’s estimate of $56 billion to $60 billion, Blair said. The Parliamentary Budget Officer earlier had estimated the construction cost at $84 billion with a “life-cycle” cost to operate and maintain the vessels at $306 billion. In reality, Blair’s announcement was not for the beginning of construction of the ships but only for a “test module.”

Some background is needed here. The Harper Conservative government in 2010 approved the National Shipbuilding Program, but it was not until 2018 that the Trudeau government, in power for three years, selected the as yet (and still) unproven British Type 26 ship as its choice. The vessels were to be constructed in Halifax at the Irving shipyards that first had to build the Arctic Offshore Patrol Ships, only completed this year (late and over-budget). Now in 2024, work at last can begin on the new destroyers.

The plan is that the first of the ships will be completed and ready for sea trials in 2033, 9 years from now and 23 years after the Harper government announced the shipbuilding program; presumably the first destroyer will not be deemed fully ready for service until at least 2034. (HMCS Halifax, the first of the frigates, went to sea in 1992, and by the time the first replacement is ready, Halifax will be 42 years old.)

But the planned completion of construction of all fifteen vessels will be glacial. Defence Minister Blair told Global TV  on June 28 that the first nine ships would not be completed until 2040 and the remaining six not until 2050. In other words, it will take a quarter century for Irving to build fifteen ships – if it is able to maintain even that production schedule. The one certainty is that the ships will cost more to build – the rate of inflation for military construction is at least 6 percent higher than national inflation. The costs will be so high for these ships that it is all but certain that fewer than fifteen will ever be launched. Will any of the destroyers still be combat effective by 2050? That seems highly unlikely.

Remember what Eyre told the National Post: “We are applying peacetime processes and peacetime mentalities to what could be considered a wartime or immediate pre-wartime security environment…. We have to deliver, and we have to deliver fast.” And don’t forget Leslie’s damning comment: “The current prime minister of Canada is not serious about defence. Full stop. A large number of his cabinet members are not serious about defence. Full stop.”

At the July NATO summit in Washington, American leaders increased the heat on Trudeau to reach the 2-percent-of-GDP benchmark for military spending. “Welcomed @CanadianPM Trudeau to the U.S. Capitol today,” U.S. Senate Republican Leader Mitch McConnell wrote on X on July 9. “Shared values and close economic ties have always been the strength of the U.S.-Canada relationship. But it’s time for our northern ally to invest seriously in the hard power required to help preserve prosperity and security across NATO.”

The Trudeau government will be long gone by the time the first of the new destroyers puts to sea, and it will be completely forgotten by the time the last one sets sail. We must hope that no war intervenes in the next quarter-century because Canada certainly will not be ready – and not only with its navy. “Not serious about defence”– let’s hope we will not pay a high price for the neglect of this country’s most vital national interest.


J.L. Granatstein taught Canadian history, was Director and CEO of the Canadian War Museum, and writes on military and political history. A member of MLI’s Research Advisory Board, Granatstein’s most recent book is Canada’s Army: Waging War and Keeping the Peace. (3rd edition).

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MacDonald Laurier Institute

Anti-Jewish campus protests reveal ugly double standard when it comes to policing “free speech”

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From the Macdonald Laurier Institute

By Kelsie Walker for Inside Policy

Despite encampments trespassing on private property, and thus being, by all definitions, illegal, they’ve seen practically no disciplinary action.

Following widespread pro-Palestinian protest encampments popping up on American campuses, there was an influx of copycat encampments across major Canadian university campuses, including at the University of Toronto, McGill University, the University of British Columbia, the University of Calgary, the University of Ottawa, and Western University, among others. These encampments are demanding that universities divest from entities associated with Israel, accusing them of supporting apartheid and being complicit in genocide. The protests, intended to express solidarity with Palestinians but also rife with antisemitism and calls for violence against Jews, have sparked intense debates about the limits of free speech and the legal boundaries of protests on campuses.

What began as a story of peaceful activism has quickly turned into lawmakers, universities, and the police selectively enforcing the law on partisan lines, displaying both hypocrisy and inaction when it comes to handling protests associated with the left.

A new poll from the Angus Reid Institute found that two-thirds of Canadians (64 per cent) say the police give preferential treatment to certain groups when dealing with protests. Canadians of all political affiliations largely feel that police response and engagement at protests is not applied consistently, with three-in-five past Conservative (68 percent), Liberal (60 percent), and NDP (73 percent) voters saying so. While they differ on the question of who receives preference, given the recent events at Canadian universities, it is undeniable that left-leaning causes, and more specifically, pro-Palestinian protests, are given unfair leeway in comparison to causes deemed to be right-leaning.

While some have tried to frame the campus encampments as an issue of free speech, in many cases, the protesters are breaking clearly defined and communicated laws. Students are certainly free to protest. However, they must also comply with university policies and Canadian laws. Free speech allows individuals to express their opinions, even controversial or unpopular ones. However, when the expression of an opinion crosses into illegal activity, such as vandalism, trespassing, or the incitement of violence, it is no longer protected under the banner of free speech. Yet, pro-Palestinian protestors are demanding that their protests be held above the law, and such demands are being met.

Despite encampments trespassing on private property, and thus being, by all definitions, illegal, they’ve seen practically no disciplinary action. The majority of Canadian universities are either placating protestors’ demands by offering a list of concessions, or, they are simply letting protests proceed practically unchecked. Police did recently disperse the encampment at McGill University on June 6 – but only after protesters there escalated the situation by illegally occupying an administration building. While most protestors have good intentions, illegal and alarming activity is frequently occurring in protest sites. Encampments have, at times, seen physical conflicts with counter-protesters, the presence of anti-Canadian and anti-police slogans, the refusal of numerous orders to leave, have issued calls to incite violence, and in one instance, have even displayed shocking imagery depicting the lynching of Jews.

Consider McGill’s “peaceful” protest. Launched in late April, it quickly turned into a hotbed of intolerance. Protestors rejected the university’s offer of concessions (despite the offer being similar to those that have led to conflict resolution at other universities) and sent masked individuals to follow and harass senior administrators at their homes and offices. The encampment displayed profane graffiti, and even featured a hanging effigy of Israeli Prime Minister Benjamin Netanyahu  donning a striped outfit that resembled the uniforms that Jews wore in concentration camps during the Second World War. Are these truly displays of free speech, or something far more sinister?

Many of the encampments are demonstrating a striking intolerance to differing opinions and an unwillingness to reach a compromise with universities, with many protestors refusing to leave until all their demands are met. If the situation was reversed, would a pro-Israeli encampment be met with the same tolerance?

Well, the University of Toronto clearly says no. Recently, a pro-Israel encampment, created in counter-protest to the pro-Palestinian encampment on campus, was removed by campus security within minutes of being established. The justification? Unlike the fully fenced-in and untouchable “Little Gaza” that has existed and grown steadily on the campus for over a month, the counter-protest was simply small enough to remove. So, it turns out, universities are in fact able to remove encampments, but only when they are on the wrong ideological side (or, in this case, the “right” side). This double standard is alarming. Why are universities and the police so afraid to stand up to left-wing protests when they blatantly break the law? If encouraging “free speech” is the justification, then that very speech cannot be encouraged selectively.

While encampments at the University of Calgary and the University of Alberta have been disbanded by police, most Canadian universities are not taking any action against illegal encampments. Indeed, some universities have reassured protesters that there will be no punitive actions taken towards them. The University of Toronto, the same university that was so quick to remove pro-Israeli protestors, even began its convocation ceremonies to the backdrop of a large pro-Palestinian encampment.

To be clear, I am not advocating for the forced end of protests. However, the inconsistent application of the law is troubling. This is part of a much wider issue in Canadian society, where there is a clear double standard on this issue. Just look at how the federal government reacted to the “Freedom Convoy” that gridlocked Ottawa in January 2022. In response to the anti-vaccine-mandate protest, the Trudeau government invoked the Emergencies Act and forcibly brought it to an end. Some Freedom Convoy organizers were arrested and their bank accounts frozen. A federal court ruling later declared the use of the Emergencies Act “unreasonable” and a violation of the protesters’ Charter rights.

Ironically, the same people who applauded the crackdown on the Freedom Convoy protesters are crying foul at the very thought of the police disbanding left-wing protest encampments on university campuses. As Sir Winston Churchill once said, “Everyone is in favour of free speech. Hardly a day passes without its being extolled, but some people’s idea of it is that they are free to say what they like, but if anyone says anything back, that is an outrage.”

While free speech is protected, it is not without limits. And it certainly shouldn’t be used as a phony justification for inaction, especially pro-Palestinian encampments make other students and staff feel unsafe on campus. The mobs are especially concerning for Jewish students, faculty, and staff who have suffered instances of anti-Semitic rhetoric, harassment, and exclusion on campus. In the face of such blatant anti-Jewish hate, how can they feel safe, respected, and valued by their institutions?

Protests are often intended to create discomfort; however, universities are sitting by idling while atmospheres of hatred and racism are being strengthened with each passing day. It is so severe that some Jewish students in the United States are taking legal action against their universities, under the claims that the institutions are failing to protect them from discrimination and harassment. If such hostility is allowed to continue unchecked, it is only a matter of time until legal battles emerge on Canadian campuses too. Universities are legally and ethically obligated to ensure that all students feel secure and respected, not allow a select few to run rampant all over university rules. There must be a principled, consistent approach to free speech and legal enforcement – one that transcends political affiliations and ensures that the rights and responsibilities of all citizens are respected equally.


Kelsie Walker is a project manager at the Macdonald-Laurier Institute where she primarily assists with the Defending the Marketplace of Ideas project.

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