A journalist wrote an article about a union organizing campaign at a department store.
Shortly after, several employees were terminated, prompting the union to file an unfair labour practices claim.
The journalist was summoned to testify before the Labour Relations Board regarding her sources.
She objected, claiming a qualified privilege at common law and under section 2(b) of the Charter.
The Board ordered her to testify, and her applications for judicial review were dismissed by the lower courts.
The Supreme Court of Canada dismissed the appeal, finding that the journalist did not meet the Wigmore criteria for common law privilege and failed to provide evidence that compelling her testimony would detrimentally affect the ability of the press to gather information under the Charter.