This case concerned whether the use of symbols and representations of white supremacy were discrimination under Alberta’s Individual Rights Protection Act

With the Canadian Congress of Black Women, LEAF intervened before the Board of Inquiry. 


The Church of Jesus Christ Christian Aryan Nations in Alberta sponsored a meeting that later came to be known as the “Aryan Fest”. The meeting featured a number of different symbols and representations of White Supremacy. Several individuals filed complaints, arguing that the use of such symbols discriminated against them. The Church and other defendants argued that the Individual Rights Protection Act violated their freedom of expression rights under s. 2(b) of the Charter


LEAF and the Canadian Congress of Black Women argued that the use of symbols and representations discriminated against racialized persons and Jewish persons. Racialized women and Jewish women suffered exponentially greater damage as they were targeted based on gender as well as race or religion.  

Freedom of expression was not a defense to the actions, as the use of signs was not a protected form of expression under s. 2(b). If it was, however, the limitation on free expression advanced the equality of disadvantaged groups and was justified under s. 1 of the Charter


The Board of Inquiry found that there were reasonable limits on free speech, and that human rights protections required an understanding of the political and social realities faced by marginalized groups. 

LEAF is grateful to Patricia Paradis, counsel in this case. 

Download the factum here.

Our records are imperfect, but we are doing our best to update them – if you were involved with LEAF on this case but your name is not reflected here, please email us at [email protected].