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[Human Rights Damage Awards: Summary: Manitoba]
Human Rights Damages: Manitoba Summary
| Case | Year | Summary | Award |
 | Manitoba | ||
| T.M. v Manitoba | harassment due to sexual orientation | this was the highest award made in Manitoba. It was effectively reversed by legislation which limited the award for injured feelings to $25,000. | $75,000 |
| Dec 2019 | |||
| Emslie v Doholoco | 2014 | The applicant was subject to physical contact by the owner of the business which caused severe emotional harm, including "anxiety, depression, flashbacks and panic attacks which continued for several years". | $15,000 compensatory and $5,000 punitive |
| The Manitoba Code allows for punitive damages of up to $5,000 against an individual and up to $25,000 against a corporation. This order was made against the owner personally. The panel noted the Ontario law which suggested a range of $12,000 to $50,000 and stated that awards in other provinces have been higher than that of Manitoba. Nothing was done to correct that. The facts in this case were said to support an award in the high end of the range. | |||
| Issue was taken to the use of Ontario cases in Emslie | |||
| Garland v. Tackaberry (c.o.b. Grape & Grain), [2013] MHRBAD 5. | 2013 | Abusive comments and conduct towards a young woman by a customer upon which the company refused to act. | $7,750. This was the highest award prior to Emslie. |
| Metaser v Jewish Community Campus of Winnipeg Inc | Oct 2013 | Inappropriate sexual jokes and sexual solicitations. | $5,250 |
| Jedrzejewska v A+ Financial Services Ltd | 2016 | unwelcome sexual solicitations; adverse treatment due to sex; “prolonged and vile conduct” | $20,000 to each complainant |
| Non-Employment Case | |||
| Pruden v Manitoba | 2020 | Denial of health care to young boy and his mother due to ancestry; | $30,000 to child and $12,500 to mother |
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David Harris — Canadian Employment Law
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