Does Ontario’s New Street Racing Law Violate the Charter of Rights?
New Laws March 21st. 2008, 6:10amLast year, following a string of tragic incidents on Ontario’s roads, the province enacted a strict new law in October to curb street racing, constituting driving 50 km/h over the speed limit as street racing. At the officer’s discretion, the new law hits speeders with vehicle impoundments, immediate license suspension and hefty fines ($10, 000 plus) without a trail. The new law proved to be a financial windfall for Ontario in its first month alone, netting at least $2 million in fines.

The new law of course has proven controversial for its strictness and Tim Chisholm has written the polemical opinion piece “A Hard look at the ‘street racing’ law”, deriding the measures as being driven by knee-jerk reactions from provincial officials and in violation of Canada’s Charter of Rights.
Chisholm charts the development of Bill 203 from its inception as a proposal in 2006, prominently forged by Newmarket MP and former Minister of Transportation Frank Klees, with its focus on banning the use of nitrous systems on the streets. While Chisholm agreed with this aspect of the early proposal, he argues that the reliance on the officer’s discretion could wrongfully target car enthusiasts for merely modifying their vehicles.
“I had an argument over the phone with Klees in the spring of 2006 when a `safer roads’ bill was initially proposed. My argument was simple: the new law could sink a car enthusiast who is doing nothing wrong, other than simply driving his or her modified car.
It’s because the bill negatively profiles the modified car enthusiast and gives the officer full discretion, with no due process for the accused. Pretty simple, a copper having a bad day can screw a car enthusiast simply because he chooses to. When I suggested that this will happen often if 203 becomes law, Klees told me he `could live with that.’
While Bill 203 was initially shot down, the tragic deaths of Rob and Lisa Manchester of Newmarket in May 2006 brought the measures back into discussion, as the accident they were involved in was blamed on two other drivers who were accused of street racing, apparently traveling at 150 km/h in an 80 km zone.
Over the course of a year, after some more well publicized speeding fatalities, (again blamed on ‘street racing’) and public calls to action from Stephen Harper, Dalton McGuinty and OPP Commissioner Julian Fantino finally saw Bill 203 reach the forefront of public discussion.
Chisholm distances himself from heated rhetoric of these officials, and the emotional heartstrings pulled by the tragedies, to focus on the facts and political maneuverings surrounding the rising stigma of ‘street racing’.
“By June 2007, those of us in the enthusiast community were pointing out that only 0.12 per cent of traffic deaths are related to `street racing’, and `What the hell is the inspiration for these draconian proposals?’ And then whammo, Bill 203 gets royal assent. And funny, just before it received assent, the 50 km/h-over penalties were added.
In an interesting feat of timing, the boys charged in the influential accident that killed the Manchesters were due for sentencing right around the time that Bill 203’s provisions were to become official.
Then a few facts started coming out. The boys were not doing 150 km/h, but actually 112 km/h. Manchester was drunk, twice over the limit. The judge ruled that the boys were not street racing, and that Manchester’s alcohol level was a factor.
You have to wonder how Manchester’s condition was overlooked, considering his death was exploited as a result of `street racers’ for 14 months. When the fact is, had Manchester lived, he would have been facing serious DUI charges. I’m sure everyone involved will claim they didn’t know, but I will always be convinced that it was nothing more than politics at its worst.
I understand that, as of last week, more than 1,300 vehicles have been seized under the new legislation. I’m not sure how many were `street racing’ versus driving 50 km/h-over, but at $2,000 a judgment, it seems that Fantino might have just paid for that plane he wanted. And we will all be reminded how much safer our roads are now.
Chisholm goes on to argue that in rural areas, 80 km zones quickly become 50 km zones, and drivers going downhill, traveling just 10 to 20 km over the limit may find themselves 50 over the limit when they cross zones, landing in the net of a waiting police officer, anxious to drop lucrative fines on unsuspecting drivers. This, Chisholm states, goes against the Charter of Rights, as it transfers the role of the judge and jury on to said officers.
While programs like ERASE (Eliminate Racing Activities on Streets Everywhere) have been in effect to specifically target street racing, the new legislation, as Chisholm believes, expands the definition of street racing to expand police power and ultimately net lucrative sums of money for the province. Such a practice, Chisholm believes, will eventually be deemed as a violation of the law, as similar programs in the States have been stricken as being unconstitutional by state judges. It is only a matter of time before more Ontarians contest Bill 203.
At Legal Action, we strongly advocate responsible road safety and fair public policies. We also understand that our public officials, while possessing good intentions, may ultimately be targeting the wrong individuals, potentially placing unfair financial burdens on good and safe drivers.
Get the facts and know your rights with Legal Action’s Blog. We promise to keep you up-to-date on all the debates and developments surrounding Ontario’s traffic laws and how they effect your time on the road. Drive Safe.


May 14th, 2008 at 3:11 pm
Your article hit the nail on the head. I am a car enthusiast and my friends also are. We are always fearful that because we are enthusiasts we will be automatically targeted as Street racers by some cop under his quota and get hassled for nothing. I completely support Tim Chisholm?s views and hope to help get this unfair and vague law removed from our legal system. The experts report there have been 42 deaths due to street racing from 1999 until now. That?s less than 5 deaths per year. How many does smoking kill a year? Drunk driving? Murder? I?m willing to bet it?s a lot more than 5 per year. The OPP should be doing their job PROTECTING US!
Source: http://www.citynews.ca/news/news_22702.aspx
May 20th, 2008 at 1:30 pm
You are not alone in your feelings towards this law. Many people feel the police officers are being given too much discretion at the side of the road; as a result this law is now being challenged. We will continue posting updates as they occur.
September 30th, 2008 at 8:49 pm
The street racing legislation is not only unconstitutional, criminal acts such as fraud were used to enact the law. My book ABUSE OF POWER describes how the Ontario government broke a number of laws to create a law that could have been achieved using other means. This is a law that destabilizes all Ontario Legislation and creates an environment where racial and other forms of discrimination can proliferate.
ABUSE OF POWER is not about the cops being nasty, it’s about the legislative abuse. It contains information drivers need to know.
A quote from an e-mail from Tim Chisholm:
”
John has gone through every T and I….and his claim, is not just that the law violates your civil rights….but that the Ont. Gov’t literally broke the law to create the law, and are therefore breaking the law everytime they seize a car
I’ve read a quite a few pages and this guy is on the money here….it’s a good read, he doesn’t pull a punch.”
My book was submitted to the Ontario Legislature. Two days later a member of Durham Region’s Police dropped by to purchace copies of that book and another one I wrote about my adventures street racing. They will have a good read.
The sad part is that I’m right but unfortunately, I’m not bragging.
October 17th, 2008 at 2:54 pm
The law is unconstitutional for several reasons.
Section 172(5) requires an officer to have reasonable and probable grounds. This proves a hearing is required before punishment can be imposed. Reasonable and probable grounds bear a standard of proof and onus of proof.
Thus, when an accused is charged, it is neither proven nor presumed that the accused has committed an offence, but there are reasonable grounds for believing that this has occurred. The laying of charges in the legal process does not involve a determination of guilt, thus, the presumption of innocence under s. 11(d) as a principle of fundamental justice under s. 7 of the Charter still applies and sanctions cannot be imposed until a determination of guilt has been entered.
The burden is on the government and the standard of proof is beyond reasonable doubt. The governments burden can only be discharged by a trier of fact in a court proceeding. But no proceeding is provided violating ss. 7 and 11(d) of the charter.
The principles of fundamental justice under s. 7 incorporate due process and natural justice. S. 172 violate both of them as no hearing is provided. As no hearing is provided s. 172 also violates s. 11(d), the right to be presumed innocent until proven guilty according to the law. The charter is part of the constitution and the constitution is the supreme law of Canada.
Section 172 is not justified or saved by s. 1 of the Charter.
Moreover, s. 128(14)(d) directly conflicts with s. 172.
Section 128 provides for a fine of $9.75 per kms over the speed limit when the driver is doing more than 50 kms over the speed limit. There is no licence suspension, vehicle impoundment, prison term etc.
Section 172 provides for a minimum $2000 fine, maximum $10,000 fine, seven day licence suspension, up to two year suspension upon conviction, seven day vehicle impoundment, and six month prison term.
It is a universal principle that when two provisions conflict the one that is most favourable to the accused must be adopted.
Most critically, offences in Canada were classified 30 years ago. Offences are either mens rea, absolute or strict liability offences.
R. v. City of Sault Ste. Marie, [1978] 2 S.C.R. 1299
S. 172 is an absolute liability offence.
Twenty-three years ago, the Supreme Court of Canada determined that absolute liability offences that contain terms of imprisonment are unconstitutional as they violate s. 7 of the charter. The term of imprisonment does not have to be mandatory, it may be optional, as s. 172 provides.
B.C. Motor Vehicle Act, [1985] 2 S.C.R. 486
Thus, in accordance with s. 52 of the Constitution Act 1982 s. 172 is of no force and effect. In other words, it’s not a valid law.
Critically, the Province might wish to claim it was unaware of B.C. Motor Vehicle Act, [1985] 2 S.C.R. 486 until now but that is simple untrue. The Attorney General of Ontario intervened in R. v. Kanda, 2008 ONCA 22 and is well aware of the offence classifications and that a term of imprisonment is not permissible when attached to an absolute offence, which s. 172 is.
More than 8,000 people to date have be charged under s. 172 and up to 8,000 vehicles impounded, thus up to 24,000 criminal offences of thefts, mischeif and fraud have been committed by agents of the Province.
More importantly, the Attorney General argued in the case that the triggering words “no person shall,” evince a clear intention to create an absolute liability offence. The court determined otherwise stating it is a strict liability offence. The court also cited the B.C. Motor Vehicle Act case. Therefore, the Attorney General has been aware since January, 2008 that s. 172 is unconstitutional and of no force or effect yet the Province continues to illegally charge citizens and impound vehicles.
In order to be reasonable, seizures and impoundments must be authorized by law. Here, impoundment is not reasonable or authorized by a valid law. The reason for this requirement is clear: under both the Charter and the common law, agents of the state can only enter onto or confiscate someone’s property when the law specifically permits them to do so. Otherwise, they are constrained by the same rules regarding theft as everyone else.
R. v. Caslake, [1998] 1 S.C.R. 51
Therefore, the police are not operating under any valid law when they impound a vehicle and are not are not operating in the execution of any valid power or duty. What they are doing is stealing cars under s. 322 of the Criminal Code, committing mischief under s. 430, and fraud under s. 380.
A person is having their vehicle stolen and the police are allowing a third party to place a lien on your property. You cannot get your stolen property back unless you pay money, which is fraud.
If you are subject to an impoundment you are empowered under s. 494 of the Criminal Code to arrest the police office on the spot the second he acts to impound your vehicle.
Section 19 of the Criminal Code articulates that Ignorance of the law is no excuse and the police cannot blame the government for any wrong doing an officer commits.
A police officers duty and powers are articulated under s. 42 of the Police Service Act.
Section 42(3) of the Police Service Act states;
Powers and duties of common law constable
(3) A police officer has the powers and duties ascribed to a constable at common law.
At common law, these duties include “the preservation of the peace, the prevention of crime, and the protection of life and property.”
Dedman v. The Queen, [1985] 2 S.C.R. 2.
The common law is no more immune from Charter scrutiny than is statute law, as the Supreme Court has repeatedly held, see RWDSU v. Dolphin Delivery Ltd., [1986] 2 S.C.R. 573; B.C.G.E.U. v. British Columbia (Attorney General), [1988] 2 S.C.R. 214; R. v. Swain, [1991] 1 S.C.R. 933; R. v. Daviault, [1994] 3 S.C.R. 63, and R. v. Stone, [1999] 2 S.C.R. 290.
Common law is made up of decisions of the court. The police officer are required to be aware of all decisons, as they are governed by them. Thus, as the court determined 23 years ago that absolute liability offences that contain terms of imprisonment are unconstitutional, the police officer who steals a car commits 3 criminal offence per incident.
You can also sue the officer for breach of duty of care for are damages you incur.
Hill v. Hamilton Wentworth Regional Police Services Board, 2007 SCC 41
Moreover, Section 50(1) of the Police Service Act expressly states;
Liability for torts
50(1) The board or the Crown in right of Ontario, as the case may be, is liable in respect of torts committed by members of the police force in the course of their employment.
The failure of a public officer to perform a statutory duty also constitutes misfeasance in a public office. Police Services Act s. 41(1) imposes on all Chiefs and Commissioners a freestanding statutory obligation to ensure that the members of the force carry out their duties in accordance with the provisions of the Police Services Act and the needs of the community. This includes an obligation to ensure that members of the police force do not injure members of the public through misconduct in the exercise of police functions.
The public complaints process allows the public to complain in respect of the conduct of a police officer. What an accused seeks, though, is not the opportunity to file a complaint that might result in the imposition of disciplinary sanctions, but, rather, compensation for the damage they have suffered as a consequence of the Chief and/or Commissioners inadequate supervision and misfeasance in office. The public complaint process is no alternative to liability in negligence.
A plaintiff cannot sue government for a policy decision; however, enforcement of that policy is an operational decision which gives rise to a duty of care.
Odhauji Estate v. Yoodhouse 120031 3 S.C.R ,263.
Section 1 of the Police Service Act articulates the principles Police are to respect and follow. The drivers whose vehicles are stolen by the police are victims of crime. They are being dumped at the side of the road when their vehicle is stolen and they are being smeared in the media when the police release their names and/or allow video of their car or the person themselves to be aired.
Section 1 states;
Declaration of principles
1. Police services shall be provided throughout Ontario in accordance with the following principles:
1. The need to ensure the safety and security of all persons and property in Ontario.
2. The importance of safeguarding the fundamental rights guaranteed by the Canadian Charter of Rights and Freedoms and the Human Rights Code.
…
4. The importance of respect for victims of crime and understanding of their needs.
The Police core services are articulated under s. 4 and indicate they are to prevent crime, not commit it, and they are to assist victims of crime, yet in stead, they dump them off at the side of the road after stealing their vehicles.
Core police services
4(2) Adequate and effective police services must include, at a minimum, all of the following police services:
1. Crime prevention.
2. Law enforcement.
3. Assistance to victims of crime.
4. Public order maintenance.
5. Emergency response.
The Province and the police operate under colour of law, but the law is not colour blind and no one is exempt from the law.
R. v. Mann, [2004] 3 S.C.R.59, 2004 SCC 52.
One of the most fundamental responsibilities of a government is to ensure the security of its citizens. In a constitutional democracy, governments must act accountably and in conformity with the Constitution and the rights and liberties it guarantees. It is one of the proud accomplishments of the common law that everybody is subject to the ordinary law of the land regardless of public prominence or governmental status. As was explained in Reference re Secession of Quebec, [1998] 2 S.C.R. 217, at p. 240, the rule of law is one of the “fundamental and organizing principles of the Constitution”, and at p. 258, it was further emphasized that a crucial element of the rule of law is that “[t]here is … one law for all.”
Thus, a provincial Premier is held to have no immunity against a claim in damages when he caused injury to a private citizen.
The following sections of the Highway Traffic Act are also unconstitutional.
Section 107(1), (2), (3), (4), (11) and (13). Section 107(15) states;
…”or to imprisonment for a term of not more than six months, or to both.”
Section 112 (3).
…“or to imprisonment for a term of not more than three months, or to both”
Section 171(4).
…”or to imprisonment for a term of not more than six months, or to both.”
Section 172.1(3).
…”or to imprisonment for a term of not more than six months, or to both.”
Section 175(17).
…”or to imprisonment for a term of not more than six months, or to both.”
Section 177(4).
…”or to imprisonment for a term of not more than six months, or to both.”
Section 190(8).
…”or to imprisonment for a term of not more than six months, or to both.”
Section 200(2).
…”or to imprisonment for a term of not more than six months, or to both
January 27th, 2009 at 4:52 pm
Hi, As of 7 32pm last night monday jan 26th 2009 i was pulled over on a dark highway outside of arnprior for going 144 in a 90 which i presumed was 100, i was threatened by the officer that he could arrest me and at one point he got mouthy, my car was impounded and i was left to find a way home and that it wasnt his problem, I have a court date comming up march 27th i was wondering how can i beat them and the system? by the way i enjoyed the info. Any words of advice would be great
March 24th, 2009 at 4:50 pm
Most drivers would qualify themselves as “good and safe” yet 800 drivers, passengers, cyclists and pedestrians get KILLED on Ontario’s road every year, 3000 across Canada. The majority of these are attributed to speeding, aggressive driving, and driver error.
Speed kills. The laws of physics can’t be ‘overturned’. Penalties for for speeding have to be commensurate with the very real consequences of this behaviour.
May 21st, 2009 at 2:59 pm
As a legal representative and an auto enthusiast and human rights advocate, I find these laws draconian, and enacted in haste without proper discussion or consideration of its impact on people who are not racing but in fact simply speeding. More and more cases are popping up where simple folk who happen to be late for church, or going home to see thier kids etc are falling into this dragnet. There IS a viable constitutional challenge available for anyone that runs afoul of this new law. If you have been and are interested in having your day in court, contact me! rjanjua@pacelawfirm.com
August 16th, 2009 at 10:21 am
So you think this law is unconstitutional? Will it be constitutional when one of your family members is killed by these morons that believe it’s their god given right to terrorize our roads? OR Will you throw up your hands and say ‘Give this idiot a $500 fine and 6 points off his licence, that should teach him a lesson\.
December 1st, 2009 at 11:59 pm
It has been proven unconstitutional, like it or not. No, it will not magically become constitutional no matter what pain and heartache is caused directly or indirectly to me or my family, by another road user. We have and have had laws, already on the books, which deal with these. We even have the option of going to the Criminal Code if the circumstances dictate we should.
What we should NOT do is let misrepresentation, disproportionate and selective reporting, scare tactics, purposely confusing rhetoric (by the government, the legislators, the enforcers and the media) allow us to be OKAY with any law(s) that are not only illegal, but go against our basic freedoms and liberties guaranteed by the Canadian Charter of Rights and Freedoms!