Legal and Equality Rights (Unit 2 Set 5)
Published on Feb 19, 2017
These notes highlight the protections those who become entangled in the criminal justice system have and that everyone is equal before and under the law.
MORE DECKS TO EXPLORE
PRESENTATION OUTLINE
Legal and Equality Rights Overview
- Sec 7-11
- All areas of Criminal Law
- Sec 12-14
- Punishment and witness issues
- Sec 15
- Equality Rights
The legal rights of those accused of a crime are protected from the initial investigation through to sentencing. If the courts determine that the police, the crown attorney, or any other members of the criminal justice system have infringed on the legal rights of the accused, they may impose any number of remedies including a dismissal of all charges.
Section 7
- Section 7 guarantees the life, liberty and personal security of all Canadians. It also demands that governments respect the basic principles of justice whenever it intrudes on those rights. Section 7 often comes into play in criminal matters because an accused person clearly faces the risk that, if convicted, his or her liberty will be lost.
As an example of the effect of Section 7, the Supreme Court of Canada has ruled that individuals may not be sent to prison unless there is some proof that they did something wrong. To imprison a person who has acted reasonably would offend the principles of fundamental justice.
The term "Fundamental Justice" within section 7 can be thought of as the due process of the law, such as the presumption of innocence, the burden of proof, the right to a fair trial before an impartial decision maker, and the right of Habeas Corpus. It is important to note that fundamental justice is a balancing act between the rights of the accused and the rights of society to be protected from crime.
The Right To Life:
Infers rights that limit the ability of the government to either enact legislation that ends or extends your life.
(Capital Punishment / Physician Assisted Suicide)
The Right To Liberty:
This right is associated with criminal cases. Your right not to be imprisoned without due process (fundamental justice)
The Right to Security of the Person:
The right to be protected against certain forms of corporal punishment and physical suffering.
The term "Fundamental Justice" within section 7 can be thought of as the due process of the law, such as the presumption of innocence, the burden of proof, the right to a fair trial before an impartial decision maker, and the right of Habeas Corpus. It is important to note that fundamental justice is a balancing act between the rights of the accused and the rights of society to be protected from crime.
The Right To Life:
Infers rights that limit the ability of the government to either enact legislation that ends or extends your life.
(Capital Punishment / Physician Assisted Suicide)
The Right To Liberty:
This right is associated with criminal cases. Your right not to be imprisoned without due process (fundamental justice)
The Right to Security of the Person:
The right to be protected against certain forms of corporal punishment and physical suffering.
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Medically Assisted Death in Canada
- Currently legal in Canada. The Criminal Code was amended in 2016 as a consequence of the previous law being found to be unconstitutional.
- Conditions necessary to be eligible for physician assisted suicide are listed in the notes.
- It is not a criminal offence to commit suicide yourself. Should it be?
Section 7 is one of the most difficult sections of the charter for the courts to come to terms with.
THE TIMELINE TO DOCTOR-ASSISTED SUICIDE
Sep 30, 1993 - Supreme Court of Canada Decision
A BC woman named Sue Rodrigues has been suffering from amyotrophic lateral sclerosis (ALS) which is a debilitating terminal disease.
Sue wanted to be able to end her life at a time of her choosing but knew she would be physically unable.
The criminal code prohibited assisted suicide.
Sue argued that the specific section of the criminal code (241.b) violated her right to Security of the person under section 7 of the Charter of Rights and Freedoms
Sue lost her battle when the supreme court voted against her in a split 5-4 decision. They stated that the law is reflective of society’s values and this specific section of the criminal code was designed to protect life and those that are vulnerable.
Despite the court ruling, Sue committed suicide 4 months later with the help of an unnamed doctor.
June 2012 - BC Supreme Court Decision
B.C. Supreme Court Justice Lynn Smith, in a case that includes ALS patient Gloria Taylor, declares Canada's laws against physician-assisted suicide unconstitutional because they discriminate against the physically disabled.
In a 395-page ruling, Smith noted suicide itself is not illegal, and therefore the law against assisted suicide contravenes Section 15 of the Charter, which guarantees equality, because it denies physically disabled people like Taylor the same rights as able-bodied people who can take their own lives without fear of criminal sanction.
Smith also said the law deprives both people like Taylor and those who try to help them of the right to life and liberty guaranteed under Section 7 of the charter. The federal government appeals the ruling to the B.C. Court of Appeals. In March 2013 The B.C. Court of Appeal, in a split decision, affirms the law against assisted suicide. The BC Civil Liberties Association appeals the Taylor Case to the Supreme Court of Canada.
February 6, 2015
The Supreme Court of Canada unanimously overturns the ban on doctor-assisted suicide, ruling the law should be amended to allow doctors to help in specific situations.
This link provides you with a detailed timeline of Assisted suicide in Canada:
http://www.cbc.ca/news/health/timeline-assisted-suicide-in-canada-1.2946485
This link provides you with a current understanding of legislation related to medically assisted death in Canada:
https://www.canada.ca/en/health-canada/services/medical-assistance-dying.ht...
THE TIMELINE TO DOCTOR-ASSISTED SUICIDE
Sep 30, 1993 - Supreme Court of Canada Decision
A BC woman named Sue Rodrigues has been suffering from amyotrophic lateral sclerosis (ALS) which is a debilitating terminal disease.
Sue wanted to be able to end her life at a time of her choosing but knew she would be physically unable.
The criminal code prohibited assisted suicide.
Sue argued that the specific section of the criminal code (241.b) violated her right to Security of the person under section 7 of the Charter of Rights and Freedoms
Sue lost her battle when the supreme court voted against her in a split 5-4 decision. They stated that the law is reflective of society’s values and this specific section of the criminal code was designed to protect life and those that are vulnerable.
Despite the court ruling, Sue committed suicide 4 months later with the help of an unnamed doctor.
June 2012 - BC Supreme Court Decision
B.C. Supreme Court Justice Lynn Smith, in a case that includes ALS patient Gloria Taylor, declares Canada's laws against physician-assisted suicide unconstitutional because they discriminate against the physically disabled.
In a 395-page ruling, Smith noted suicide itself is not illegal, and therefore the law against assisted suicide contravenes Section 15 of the Charter, which guarantees equality, because it denies physically disabled people like Taylor the same rights as able-bodied people who can take their own lives without fear of criminal sanction.
Smith also said the law deprives both people like Taylor and those who try to help them of the right to life and liberty guaranteed under Section 7 of the charter. The federal government appeals the ruling to the B.C. Court of Appeals. In March 2013 The B.C. Court of Appeal, in a split decision, affirms the law against assisted suicide. The BC Civil Liberties Association appeals the Taylor Case to the Supreme Court of Canada.
February 6, 2015
The Supreme Court of Canada unanimously overturns the ban on doctor-assisted suicide, ruling the law should be amended to allow doctors to help in specific situations.
This link provides you with a detailed timeline of Assisted suicide in Canada:
http://www.cbc.ca/news/health/timeline-assisted-suicide-in-canada-1.2946485
This link provides you with a current understanding of legislation related to medically assisted death in Canada:
https://www.canada.ca/en/health-canada/services/medical-assistance-dying.ht...
Photo by Hindrik S
Sec 8 Unreasonable Search and Seizure
- The Charter protects everyone's reasonable expectation of privacy in their homes, private spaces and personal information. This includes protection against unreasonable searches and seizures by police and other government authorities.
- A judge-approved warrant is often necessary for police to take actions which interfere with your privacy.
The purpose of Section 8, according to the Supreme Court of Canada, is to protect a reasonable expectation of privacy. This means that those who act on behalf of a government, such as police officers, must carry out their duties in a fair and reasonable way. They cannot enter private property or take things from others unless they can show that they have a good reason. In most cases, they are allowed to enter private property to look for evidence or to seize things only if they have been given a search warrant by a judge. On the other hand, government inspectors may enter business premises without a warrant to check whether government regulations are being observed.
Police cannot use searches as "fishing expeditions"
to see if something else turns up that could be used against the suspect in court
Want to know more about your rights? Check out the arrest handbook by the BCCLA below and look at searches on page 24 (Chapter 6)
out
Police cannot use searches as "fishing expeditions"
to see if something else turns up that could be used against the suspect in court
Want to know more about your rights? Check out the arrest handbook by the BCCLA below and look at searches on page 24 (Chapter 6)
out
Photo by Cellblog1138
Sec 8 Unreasonable Search and Seizure
- The Charter protects everyone's reasonable expectation of privacy in their homes, private spaces and personal information. This includes protection against unreasonable searches and seizures by police and other government authorities.
- A judge-approved warrant is often necessary for police to take actions which interfere with your privacy.
The purpose of Section 8, according to the Supreme Court of Canada, is to protect a reasonable expectation of privacy. This means that those who act on behalf of a government, such as police officers, must carry out their duties in a fair and reasonable way. They cannot enter private property or take things from others unless they can show that they have a good reason. In most cases, they are allowed to enter private property to look for evidence or to seize things only if they have been given a search warrant by a judge. On the other hand, government inspectors may enter business premises without a warrant to check whether government regulations are being observed.
Police cannot use searches as "fishing expeditions"
to see if something else turns up that could be used against the suspect in court
Want to know more about your rights? Check out the arrest handbook by the BCCLA below and look at searches on page 24 (Chapter 6)
out
Police cannot use searches as "fishing expeditions"
to see if something else turns up that could be used against the suspect in court
Want to know more about your rights? Check out the arrest handbook by the BCCLA below and look at searches on page 24 (Chapter 6)
out
Photo by Cellblog1138
Sec 9 Arbitrary Detention or Imprisonment
- Everyone has the right not to be arbitrarily detained or imprisoned.
This section says that government officials cannot take individuals into custody or hold them there without a good reason. A police officer, for example, must have reasonable grounds for detaining a person. However, courts have stated that laws allowing officers to stop drivers for breath tests are reasonable and do not violate the Charter.
In 1989 in Ontario, Gerald Ladouceur was stopped at a roadblock (There were no reasonable grounds for unlawful conduct) However, the police discovered his license was suspended. He was convicted of this offence.
Gerald appealed to the Supreme Court saying that the random traffic checks violated his charter rights under sections 7, 8 & 9
The Supreme Court determined that although random stops by police do violate Sec. 9, they can be justified under Sec. 1 of the Charter.
In 1989 in Ontario, Gerald Ladouceur was stopped at a roadblock (There were no reasonable grounds for unlawful conduct) However, the police discovered his license was suspended. He was convicted of this offence.
Gerald appealed to the Supreme Court saying that the random traffic checks violated his charter rights under sections 7, 8 & 9
The Supreme Court determined that although random stops by police do violate Sec. 9, they can be justified under Sec. 1 of the Charter.
Photo by Dazzie D
Sec 10 Arrest and Detention
- Everyone has the right on arrest or detention:
- to be informed promptly of the reasons therefor; to retain and instruct counsel without delay and to be informed of that right; and to have the validity of the detention determined by way of habeas corpus and to be released if the detention is not lawful.
The rights in section 10 apply when a person is arrested or detained. They ensure that people under arrest have a chance to challenge the lawfulness of their arrest. The police must tell them immediately the reasons for their arrest. These people also have the right to talk to a lawyer to get legal advice about their situation, and the police must tell them what legal aid services are available in their area. Persons under arrest also have the right to ask a judge to decide whether their arrest was legal and, if it was not, to order their release.
The police cannot withhold the reason for the arrest or detention and give it to the accused only at the police station or at a later date. If the police fail to provide a reason promptly, then the arrest or detention is unlawful, and the judge will be compelled to dismiss the charges.
Promptly is a relative term so its meaning may depend on the circumstances.
The accused must be provided with a reasonable opportunity to contact a lawyer in order to obtain legal advice as soon as possible. Not being able to get in touch with a lawyer after a reasonable period of time will not be construed as a breach of S.10 rights, however.
Once an arrested person decides to talk to a lawyer, the police must stop their questioning until the accused and the lawyer has a chance to talk privately. If the police listen in on the conversation between the accused and the lawyer, the charges may be dismissed in court.
The police cannot withhold the reason for the arrest or detention and give it to the accused only at the police station or at a later date. If the police fail to provide a reason promptly, then the arrest or detention is unlawful, and the judge will be compelled to dismiss the charges.
Promptly is a relative term so its meaning may depend on the circumstances.
The accused must be provided with a reasonable opportunity to contact a lawyer in order to obtain legal advice as soon as possible. Not being able to get in touch with a lawyer after a reasonable period of time will not be construed as a breach of S.10 rights, however.
Once an arrested person decides to talk to a lawyer, the police must stop their questioning until the accused and the lawyer has a chance to talk privately. If the police listen in on the conversation between the accused and the lawyer, the charges may be dismissed in court.
Photo by Thomas Hawk
Sec 11 (a - c)
- Any person charged with an offence has the right
- (a) to be informed without unreasonable delay of the specific offence;
- (b) to be tried within a reasonable time;
- (c) not to be compelled to be a witness in proceedings against that person in respect of the offence
Section 11 sets out several important rules that protect anyone charged with an offence under federal or provincial law.
Persons accused of a crime must be told promptly what offence they are charged with (s. 11(a)); their trials must take place within a reasonable time (s. 11(b)); and they cannot be forced to testify at their own trials (s. 11(c)).
Persons accused of a crime must be told promptly what offence they are charged with (s. 11(a)); their trials must take place within a reasonable time (s. 11(b)); and they cannot be forced to testify at their own trials (s. 11(c)).
Photo by EyadHainey
Sec 11 (d -e)
- Any person charged with an offence has the right
- (d) to be presumed innocent until proven guilty according to law in a fair and public hearing by an independent and impartial tribunal;
- (e) not to be denied reasonable bail without just cause;
Section 11 sets out several important rules that protect anyone charged with an offence under federal or provincial law.
Anyone accused of breaking the law is presumed to be innocent until proven guilty. This means that the prosecution must prove beyond a reasonable doubt that the person committed the offence before he or she can be found guilty. The trial must also be conducted fairly before a court which is unbiased and independent of political or any other influence (s. 11(d)).
A fair trial ensures that the rights of the accused are properly protected.An accused person is entitled to reasonable bail (s. 11(e)).
Anyone accused of breaking the law is presumed to be innocent until proven guilty. This means that the prosecution must prove beyond a reasonable doubt that the person committed the offence before he or she can be found guilty. The trial must also be conducted fairly before a court which is unbiased and independent of political or any other influence (s. 11(d)).
A fair trial ensures that the rights of the accused are properly protected.An accused person is entitled to reasonable bail (s. 11(e)).
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Sec 11 (f)
- Any person charged with an offence has the right
- (f) except in the case of an offence under military law tried before a military tribunal, to the benefit of trial by jury where the maximum punishment for the offence is imprisonment for five years or a more severe punishment;
Section 11 sets out several important rules that protect anyone charged with an offence under federal or provincial law.
Despite how long-winded this section is, it essentially says that you have the right to be tried by jury for more serious charges that will have an impact upon your liberty for an extended period of time.
Despite how long-winded this section is, it essentially says that you have the right to be tried by jury for more serious charges that will have an impact upon your liberty for an extended period of time.
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Sec 11 (g)
- Any person charged with an offence has the right
- (g) not to be found guilty on account of any act or omission unless, at the time of the act or omission, it constituted an offence under Canadian or international law or was criminal according to the general principles of law recognized by the community of nations;
Section 11 sets out several important rules that protect anyone charged with an offence under federal or provincial law.
A court cannot convict a person of a crime unless the law in force at the time of the offence specifically stated that the actions in question were illegal (s. 11(g)).
A court cannot convict a person of a crime unless the law in force at the time of the offence specifically stated that the actions in question were illegal (s. 11(g)).
Photo by lydia_shiningbrightly
Sec 11 (h)
- Any person charged with an offence has the right
- (h) if finally acquitted of the offence, not to be tried for it again and, if finally found guilty and punished for the offence, not to be tried or punished for it again;
- This section prevents against "Double Jeopardy"
Section 11 sets out several important rules that protect anyone charged with an offence under federal or provincial law.
If a person is tried for an offence and found not guilty, he or she cannot be tried on the same charge again. Moreover, if the person is found guilty and punished for the offence, he or she cannot be tried or punished for it again (s. 11(h))
Double Jeopardy:
the prosecution of a person twice for the same offence.
If a person is tried for an offence and found not guilty, he or she cannot be tried on the same charge again. Moreover, if the person is found guilty and punished for the offence, he or she cannot be tried or punished for it again (s. 11(h))
Double Jeopardy:
the prosecution of a person twice for the same offence.
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Sec 11 (i)
- Any person charged with an offence has the right
- (i) if found guilty of the offence and if the punishment for the offence has been varied between the time of commission and the time of sentencing, to the benefit of the lesser punishment.
Section 11 sets out several important rules that protect anyone charged with an offence under federal or provincial law.
In a situation where a person commits an offence and, before he or she is sentenced, a new law alters the fine or term of imprisonment that applies, that person must be sentenced under whichever law is the more lenient (s. 11(i)).
In a situation where a person commits an offence and, before he or she is sentenced, a new law alters the fine or term of imprisonment that applies, that person must be sentenced under whichever law is the more lenient (s. 11(i)).
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Sec 12 Cruel and Unusual Punishment
- Everyone has the right not to be subjected to any cruel and unusual treatment or punishment.
- What constitutes cruel and unusual?
Section 12 means that governments cannot treat individuals or punish them in an excessively harsh manner. This includes torture, excessive or abusive use of force by law enforcement officials and sentences of imprisonment which are "grossly disproportionate" to the seriousness of the crime committed.
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Sec 12 Cruel and Unusual Punishment (Cont)
- To determine whether a punishment is grossly disproportionate one needs to consider:
- Gravity of the offence
- Personal Characteristics of the Offender
- Circumstances of the Case
- Punishment is then assessed using the "Most Innocent Possible Offender Test"
Example:
The Gravity of the offence:
Harsher treatment for murder over a theft.
Personal Characteristics of the Offender:
A young person would be treated differently than an adult.
Circumstances of the case:
Deliberate versus an act that had foreseeable consequences.
Definition: the Most Innocent Possible Offender (MIPO)
Can the punishment still stand as not being cruel and unusual for even the most minor offences that would be caught under it. This makes it challenging for laws to have mandatory sentences attached to them.
The Supreme Court has said there is an appropriate balance between the effects of the punishment and the reasons for its imposition. Although many argue that these provisions in the Charter would prevent legislation such as Dangerous Offender legislation, the Supreme Court of Canada disagrees. They have determined that as long as offenders are given access to parole hearings, the legislation passes all of the Charter tests. The Court also found that the Dangerous Offender provisions are "perhaps the most detailed and demanding in the Criminal Code”.
The Gravity of the offence:
Harsher treatment for murder over a theft.
Personal Characteristics of the Offender:
A young person would be treated differently than an adult.
Circumstances of the case:
Deliberate versus an act that had foreseeable consequences.
Definition: the Most Innocent Possible Offender (MIPO)
Can the punishment still stand as not being cruel and unusual for even the most minor offences that would be caught under it. This makes it challenging for laws to have mandatory sentences attached to them.
The Supreme Court has said there is an appropriate balance between the effects of the punishment and the reasons for its imposition. Although many argue that these provisions in the Charter would prevent legislation such as Dangerous Offender legislation, the Supreme Court of Canada disagrees. They have determined that as long as offenders are given access to parole hearings, the legislation passes all of the Charter tests. The Court also found that the Dangerous Offender provisions are "perhaps the most detailed and demanding in the Criminal Code”.
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Rights of Witnesses in Court
- Sec 13
- A witness who testifies in any proceedings has the right not to have any incriminating evidence so given used to incriminate that witness in any other proceedings, except in a prosecution for perjury or for the giving of contradictory evidence.
This section states that witnesses who give evidence in court cannot have their testimony used against them in other proceedings. In other words, if the testimony of a witness shows that he or she has committed a crime, that evidence cannot be used by the prosecution to prove that the witness committed an offence. The exception is where a witness commits the crime of “perjury” which is the offence of lying to the court. In that case, the testimony of the witness may be used to show that he or she lied in court.
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Rights of Witnesses in Court
- Sec 14
- A party or witness in any proceedings who does not understand or speak the language in which the proceedings are conducted or who is deaf has the right to the assistance of an interpreter.
Persons who are deaf or do not understand or speak the language being spoken in court have the right to be assisted by an interpreter. This right applies regardless of which language is involved.
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Equality Rights
- Sec 15(1) of the Charter says that every individual is equal before and under the law and has the right to equal protection and benefit of the law without discrimination.
- Sect 15(2) programs set up by the government to ameliorate the conditions of certain disadvantaged groups are permissible even if they are seen as discriminatory to the majority.
Equality rights are at the core of the Charter. They are intended to ensure that everyone is treated with the same respect, dignity and consideration (i.e. without discrimination), regardless of personal characteristics such as race, national or ethnic origin, colour, religion, sex, age, or mental or physical disability, sexual orientation, marital status or citizenship.
The words: "every individual" versus "every person" were used in section 15 to highlight that this section does not apply to corporations.
When discussing the prohibited areas the phrase “in particular” means that the listed prohibited areas of discrimination are merely examples.
Ie/ Sexual orientation may also be considered a protected area.
This usually means that everyone should be treated the same by law and that everyone is entitled to the same benefits provided by laws or government policies. However, the Charter does not require that government always treat people in exactly the same way. For example, sometimes protecting equality means that rules or standards must be reasonably adapted to take account of people's differences, including by allowing people to observe different religious holidays without losing their job, or putting specific supports in place to enable people with visual disabilities or hearing impairments to access government services.
It is also constitutional to create special programs aimed at improving the situation of individuals who are members of groups that have historically experienced discrimination in Canada, including on the basis of the grounds listed above.
The words: "every individual" versus "every person" were used in section 15 to highlight that this section does not apply to corporations.
When discussing the prohibited areas the phrase “in particular” means that the listed prohibited areas of discrimination are merely examples.
Ie/ Sexual orientation may also be considered a protected area.
This usually means that everyone should be treated the same by law and that everyone is entitled to the same benefits provided by laws or government policies. However, the Charter does not require that government always treat people in exactly the same way. For example, sometimes protecting equality means that rules or standards must be reasonably adapted to take account of people's differences, including by allowing people to observe different religious holidays without losing their job, or putting specific supports in place to enable people with visual disabilities or hearing impairments to access government services.
It is also constitutional to create special programs aimed at improving the situation of individuals who are members of groups that have historically experienced discrimination in Canada, including on the basis of the grounds listed above.
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Equality Rights (Cont) Discrimination Defined
- A distinction whether intentional or not but based on grounds relating to personal characteristics of the individual or group, which has the effect of imposing burdens, obligations , or disadvantages on such individuals or group not imposed on others or which withholds limits access to opportunities, benefits, and advantages available to other members of society.
The Supreme Courts of Canada had to determine what is meant by the word discrimination in section 15
It did this in the case Andrews v. Law Society of BC in 1989.
The test for discrimination:
(1) The complainant must show that he or she has been treated unequally and that the effect of the unequal treatment was discriminatory.
(2) The government must then try to demonstrate that the law is "demonstrably justified" under s. 1 of the Charter as a reasonable limit.
For example:
7-year-olds can’t buy cigarettes yes discriminatory but reasonable.
In addition to the textbook the content of these notes comes from:
Abortion in Canada - The Canadian Encyclopedia. (n.d.). Retrieved from http://www.thecanadianencyclopedia.ca/en/article/abortion/
Doctor-assisted dying bill restricted to adults facing 'foreseeable' death - Politics - CBC News. (n.d.). Retrieved from http://www.cbc.ca/news/politics/canada-physician-assisted-death-law-1.35351...
Rights and freedoms in Canada - About Canada's System of Justice. (n.d.). Retrieved from http://www.justice.gc.ca/eng/csj-sjc/just/06.html#dr
Your Guide to the Canadian Charter of Rights and Freedoms - Canada.ca. (n.d.). Retrieved from http://canada.pch.gc.ca/eng/1468851006026
It did this in the case Andrews v. Law Society of BC in 1989.
The test for discrimination:
(1) The complainant must show that he or she has been treated unequally and that the effect of the unequal treatment was discriminatory.
(2) The government must then try to demonstrate that the law is "demonstrably justified" under s. 1 of the Charter as a reasonable limit.
For example:
7-year-olds can’t buy cigarettes yes discriminatory but reasonable.
In addition to the textbook the content of these notes comes from:
Abortion in Canada - The Canadian Encyclopedia. (n.d.). Retrieved from http://www.thecanadianencyclopedia.ca/en/article/abortion/
Doctor-assisted dying bill restricted to adults facing 'foreseeable' death - Politics - CBC News. (n.d.). Retrieved from http://www.cbc.ca/news/politics/canada-physician-assisted-death-law-1.35351...
Rights and freedoms in Canada - About Canada's System of Justice. (n.d.). Retrieved from http://www.justice.gc.ca/eng/csj-sjc/just/06.html#dr
Your Guide to the Canadian Charter of Rights and Freedoms - Canada.ca. (n.d.). Retrieved from http://canada.pch.gc.ca/eng/1468851006026
Photo by Daniela Hartmann (alles-schlumpf)
