A Saskatchewan Court of King’s Bench decision highlights the potential consequences of defamatory statements directed at municipal staff. In Parry v. Harper, 2026 SKKB 113, Justice Grant Currie awarded a municipal administrator $150,000 in general and aggravated damages following a series of defamatory Facebook posts.
Saskatchewan’s Court of King’s Bench teaches one Facebook user that defamation comes at a high cost. The reported rise in municipal staff being subjected to harassment has become a growing concern.
Although municipal staff are public servants, Justice Grant Currie has made it abundantly clear in the decision of Parry v. Harper, 2026 SKKB 113, that municipal staff are not the public’s punching bag and those who treat them as such might be in for an expensive surprise.
The Facts
In 2020, a Saskatchewan man named Jack Harper made a series of Facebook posts that contained malicious and untrue statements about Debra Parry, who was the administrator for the Rural Municipality of Pleasantdale at the time.
Mr. Harper publicly accused Ms. Parry of being a compulsive liar and a thief who was misallocating the municipality’s funds and of engaging in professional misconduct.
The Facebook Posts
On October 21, 2020, Mr. Harper wrote:
“The Tip of the Iceberg … The Reeve & administrator are proven fundamental liars. These two lie mercilessly even to themselves. They lie about everything. Meaning by everything literally ‘every single thing’. You can’t have a simple truth from either one of them. Even or [sic] the most insignificant thing. I guess there must be some psychiatric, anthropological and sociological explanations for that lying compulsive behaviour. We shall see ….”
Later, on November 9, 2020, Mr. Harper directly named Ms. Parry and posted to Facebook:
“I wonder what the ratepayers are going to say when they find out the administrator, Debra Parry, has taken it upon herself to spend ratepayers tax dollars (two times) hiring the RM’s lawyer threatening to sue me to cover up her own malfeasance? Council never spoke of nor voted on, sending me a letter from their lawyer on either previous occasion. This is an actionable event in Queens Bench & the RM could be on the hook for the entire bill.”
On the same day, Mr. Harper made a second post disparaging Ms. Parry by saying:
“What we need now is a forensic audit to root out the mis-allocated funds and outright theft”
What Is Defamation?
For Mr. Harper’s malicious statements to qualify as defamation in the legal context, Ms. Parry had to meet three criteria:
- that the words Mr. Harper used were published and communicated to another person other than Ms. Parry;
- that words used by Mr. Harper referred to Ms. Parry, who brought forth the claim of defamation; and
- that Mr. Harper’s impugned words were defamatory, in the sense that they would tend to lower Ms. Parry’s reputation in the eyes of a reasonable person.
For the third criterion to be met, it does not have to be proven that those who had read Mr. Harper’s statements now have a lower opinion of Ms. Parry. It only needs to be demonstrated that an ordinary member of the public could form a lesser opinion of Ms. Parry after having read and understood Mr. Harper’s statements.
Were the Posts Defamatory?
Justice Currie found that the statements Mr. Harper made about Ms. Parry were defamatory.
The first requirement was met since he posted the comments to Facebook, which is a social media platform that is effectively accessible to the world.
Secondly, it is clear Mr. Harper’s statements are referencing Ms. Parry since he refers to her in the first post as the administrator, which was her title at the time. It is evident Mr. Harper is talking about Ms. Parry in the second and third posts, as he refers to her by name in the second post, and the third post was made shortly after and continues his message from the second post.
Justice Currie also determined that the words Mr. Harper used would tend to lower Ms. Parry’s reputation in the eyes of a reasonable person. He found that after reading Mr. Harper’s statements a reasonable person would understand the statements to mean that:
- Parry lies about everything;
- she spent ratepayers’ tax dollars to fund her legal counsel for the purpose of covering up misconduct committed by her; and
- she is involved in the misallocation of the rural municipality’s funds, and a forensic audit is required to expose it.
Justice Currie concluded that the meaning of such statements as understood by a reasonable person would tend to lower their opinion of Ms. Parry’s reputation.
The Damage Has Been Done
Ms. Parry was greatly impacted by the defamatory statements Mr. Harper posted. The posts garnered the attention of members of her community, and she heard people talking about them. Consequently, she could no longer attend events in her community as she previously enjoyed, nor could she attend the church she had belonged to since childhood and was an active member of, because she now felt ostracized and as though people were watching and judging her.
She experienced stress due to the events of the comments being posted, shared and gossiped about, and had to take time off work to address stress-induced symptoms, such as elevated blood pressure, which came about in the aftermath of the posts.
Justice Currie concluded that Ms. Parry was entitled to $125,000 in an award of general damages.
He also concluded that Ms. Parry was entitled to an additional award of $25,000 for aggravated damages due to the elevated mental distress and humiliation she suffered because of Mr. Harper’s actions.
What This Means for the Future
This case sets a strong precedent for future cases of defamation against municipal workers and sends a clear message to the public that municipal workers should not have to endure harassment and humiliation simply for doing their job.
This case also serves as a warning to the public to be cautious about what they post on social media. Those who choose to make malicious and defamatory statements about municipal workers may be required to pay substantial damages for the harm they cause.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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