Author ORCID Identifier

Eric Tucker: 0000-0002-9958-4311

Document Type

Article

Publication Date

12-5-2025

Keywords

Canada; Labour Law; Constitutional Labour Rights; Underinclusive Legislation; Supreme Court of Canada

Abstract

In April 2024, the Supreme Court of Canada (SCC) unanimously ruled that the exclusion of managerial employees from Quebec’s main statutory collective bargaining regime, combined with a failure to provide them with access to any other statutory labour rights, did not violate their constitutionally protected freedom of association. This decision raises many questions about the future of constitutional labour rights at the Supreme Court. In this brief comment I address what is arguably the biggest takeaway for workers such as the casino managers whose freedom of association is poorly or entirely unprotected by statutory rights: that despite the majority judgment’s conclusion that the same test is to be used to adjudicate Charter claims based on underinclusion as is used for claims of direct state interference, excluded workers will have to take their chances with a set of untested and unpromising legal claims within a regime of liberal voluntarism, as the Court now finds this regime compliant with Charter-protected freedom of association.

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