What changed?
On June 19, 2026, the Supreme Court of Canada released Resler v. Anglin, 2026 SCC 23, SCC file 41298. The Court dismissed the appeal from the Alberta Court of Appeal, with Chief Justice Wagner and Justices Karakatsanis and Martin dissenting in part.
The practical result is that most of former Alberta election candidate Joseph Anglin’s civil claim against Glen Resler, in his capacity as Alberta’s Chief Electoral Officer, may continue past the motion-to-strike stage. The Supreme Court did not decide whether the pleaded allegations are true or whether damages will ultimately be awarded.
Issue in brief
The case arose after Mr. Anglin’s unsuccessful 2015 Alberta re-election campaign. According to the SCC’s Case in Brief, the Chief Electoral Officer fined Mr. Anglin and had election signs removed because of sponsorship-information and former-MLA-status concerns, and also fined him over protection of an electors list.
Mr. Anglin accepted the election result, but brought a civil claim alleging misuse of public powers and seeking compensation, including for alleged loss of a chance to be re-elected. The Chief Electoral Officer sought to strike the claim, arguing among other things that it was an improper collateral attack or abuse of process and that statutory good-faith immunity barred the proceeding.
What the SCC held
Writing for four judges, Justice Moreau concluded that no legal barrier prevented the claim from proceeding on the pleaded facts. The reasons distinguish a damages claim that accepts the election result from a proceeding that asks a court to undo or alter the result of an election. The reasons also state that Alberta’s Election Act protects the Chief Electoral Officer for things done in good faith, but leaves room for civil proceedings where bad faith is pleaded.
Justice Rowe, joined by Justice Côté, concurred in the result. Justice Karakatsanis, joined by Chief Justice Wagner and Justice Martin, dissented in part and would have allowed the appeal in part.
Why it matters
The decision is important for Canadian election-law and public-law researchers because it addresses the boundary between finality of election results, civil accountability claims against election officials, collateral-attack and abuse-of-process doctrines, parliamentary privilege, and statutory immunity for public officials acting in good faith.
For CanadianJudges.ca readers, the key caution is procedural: this is a motion-to-strike decision. It allows a claim to go forward because the pleadings meet the legal threshold at this stage; it is not a final trial judgment on liability, bad faith, causation, or damages.
Sources
- Supreme Court of Canada: Judgment on Appeal news release, June 19, 2026
- Supreme Court of Canada reasons: Resler v. Anglin, 2026 SCC 23
- Supreme Court of Canada Case in Brief: Resler v. Anglin
- Supreme Court of Canada case information: file 41298
Caveats
This is a public-record research note, not legal advice. It summarizes official Supreme Court of Canada materials available at publication time. It does not assess the truth of any pleaded allegation, and the litigation may still be narrowed, defended, settled, or decided differently after further proceedings.