Baselessly including “Metis peoples” in the section 35 definition of “aboriginal peoples”: a sad, illiberal recipe for folly, waste and social disharmony.

“The concrete life of the individual is destroyed in order that the abstract idea of the whole may drag out its sorry existence.” – Friedrich Schiller[1]

“I am always and at once on the defensive when people speak of races and nations as if they were personalities and had souls and destinies.” – Christopher Hitchens[2]


So prized are the rights and entitlements that can come with Aboriginal status that no mildly self-interested, dependency-mindsetted Canadian with the slightest trace of Indigeneity in his or her background – be it DNA, self-identifying and community acceptance, “sharing a native hereditary base” (see below) or otherwise- would want to leave home without it.

Over the past twenty years, notwithstanding the clear economic and social harm being caused to the country by doing so, our legislators and courts have been falling all over themselves to create new reasons for Canadians to claim and/or cling to Aboriginal status- to define themselves as Aboriginal first and Canadians second. The benefits are just impossible to resist.

The most bizarre and inexplicable “race”-type category created by our legislators and courts is that of the “Metis peoples”.

Section 35 of the Constitution Act, 1982, which recognized and affirmed “the aboriginal and treaty rights of the aboriginal peoples of Canada”, included the “Metis peoples” in the definition of “aboriginal peoples of Canada.”

But, in another stellar demonstration of reckless and irresponsible constitution making, just as the framers of section 35 had no idea what s. 35 meant when they drafted and included it in the Constitution Act, they had no idea what “Metis peoples” meant.

They knew it meant offspring and descendants of a union between an Aboriginal and a non-Aboriginal person, but that’s about all. What else defined “Metis”? Why “peoples”- plural? Did “Metis peoples” have to originate from a certain geographical area, or could they be from anywhere in Canada? Did they have to trace their origin to a particular event or series of events in Canadian history? Can “Metis peoples” come into being at any time in our history, including as the result of mixed-race unions in the present? What would the social and economic costs and consequences of declaring in the constitution that the “Metis peoples” of Canada have “aboriginal rights” which are “recognized and affirmed”? Exactly what Metis “aboriginal rights” was section 35 recognizing and affirming?

As to the answers to all these and many more such foundational questions, just like with respect to section 35 generally, our reckless, Panglossian framers had no idea.

The Supreme Court of Canada filled in a few blanks in this regard 21 years later. In R. v. Powley it upheld the acquittal of Sault Ste. Marie area residents Steve and Roddy Powley for shooting a bull moose without a hunting license on the ground that they were exercising their aboriginal right to hunt for food, and that the exercise of that right in the circumstances took priority over Ontario’s hunting regulations. The Court upheld the trial judge’s factual finding that the Powleys were part of a Metis “community” in and around Sault Ste. Marie. The Court wrote:

…Metis cultures by definition post-date European contact…The constitutionally significant feature of the Metis is their special status as peoples that emerged between first contact and the effective imposition of European control.

The Court adopted findings of the 1996 Royal Commission on Aboriginal Peoples:

Intermarriage between First Nations and Inuit women and European fur traders and fishermen produced children, but the birth of new Aboriginal cultures took longer.  At first, the children of mixed unions were brought up in the traditions of their mothers or (less often) their fathers.  Gradually, however, distinct Métis cultures emerged, combining European and First Nations or Inuit heritages in unique ways.  Economics played a major role in this process.  The special qualities and skills of the Métis population made them indispensable members of Aboriginal/non-Aboriginal economic partnerships, and that association contributed to the shaping of their cultures. . .. As interpreters, diplomats, guides, couriers, freighters, traders and suppliers, the early Métis people contributed massively to European penetration of North America. (Italics added.)

On the issue of who can validly claim membership in a Metis community the Court wrote:

The verification of a claimant’s membership in the relevant contemporary community is crucial since individuals are only entitled to exercise Métis aboriginal rights by virtue of their ancestral connection to and current membership in a Métis community.  Self‑identification, ancestral connection, and community acceptance are factors which define Métis identity for the purpose of claiming Métis rights under s. 35Absent formal identification, courts will have to ascertain Métis identity on a case‑by‑case basis taking into account the value of community self‑definition, the need for the process of identification to be objectively verifiable and the purpose of the constitutional guarantee. (Italics added.)

A person may be a Metis then if he self-identifies as one, has an ancestral connection to an historic Metis “community”, (no definition of “community”), and is currently accepted as a member of that “community”. These criteria are so vague and subjective, and currently often based on the purely sentimental “my feelings are my truth” principle, that they inevitably give rise to loose, often disputed claims of now-coveted “Metis” status, (for example see, and generally raise far more questions than give answers.

Also, and this is a more significant fact that emerges from Powley, which fact totally defeats the suggestion that there is anything particularly “Aboriginal” about being a Metis: past and present Metis culture, by definition, was founded in and is inextricably tied to and defined by assimilative Euro-Canadian capitalist/mercantile culture!

Powley taught all Canadians who lacked an Indian Act status card, but who had a smidgen of Indian or Inuit “blood” in their veins, that there was potential gold in them thar aboriginal hills, and, through the courts, they went looking for it. In 2016 they were able to announce a promising strike when the Supreme Court of Canada released its decision in the case of Daniels vs. Canada (Indian Affairs and Northern Development) (“Daniels“). 

In Daniels the Supreme Court rather briefly and breezily, on somewhat flimsy legal and historical grounds, declared that Canada’s 400,000 Metis and 200,000 non-status Indians are now all “Indians” under federal jurisdiction, at least for the purpose of being eligible to claim Indian Act- “honor of the Crown”- type benefits from the Canadian taxpayer.

The Court reasoned that because Metis and non-status Indians “have been deprived of significant funding for their affairs”, and “have no one to hold accountable for an inadequate status quo,” that that was a reason, in and of itself, why they should be granted such eligibility status, seeming to ignore or forget the fact that all non-Indigenous Canadians are so “deprived”, and that all  Canadians, Aboriginal  and non-Aboriginal, in fact have their elected representatives to be held accountable for whatever they perceive to be their “inadequate status quo.” 

They’re not “deprived” any more than any other Canadians. They’re simply equal under the law– a state that our Supreme Court, in this area of Canadian life, to its great discredit, does not seem to feel is a worthy or acceptable default position, or a situation to aspire to or work towards.

The Court made no effort to define what a Metis or non-status Indian is. “There is no consensus on who is considered a Metis or a non-status Indiannor need there be… This is “a fact-driven question to be decided on a case-by -case basis in the future” (!) 

By its decision in Daniels the Court has potentially almost doubled the potential financial burden on Canadian taxpayers for the consequences of this decision, and yet it made zero effort to define these newly entitled racial categories of Canadians. This constitutes failing in their fundamental duty to properly define and explain this new law to Canadians.

The Court made or adopted numerous “unargued persuasion” assertions, that fall below the high standards normally expected of the highest court in the land.


– “The threat that (the Metis) posed to Canada’s expansion was real.” (Really? A couple of minor, military skirmishes, and Metis opposition was all over.)

-Canada could not have opened up the prairies to agriculture and settlement “without Metis intercession and legal presence.” (No details provided, and simply historical balderdash in any event.)

-If a person possesses “sufficient racial and social characteristics to be considered a “native person”, that individual will be regarded as an “Indian”. (Considered by whom? – What might those “racial and social characteristics” be? No details provided.)

– “There is no doubt that the Metis are a distinct people,” who are “widely recognized as a culturally distinct Aboriginal people living in culturally distinct communities. (Really?  “Widely recognized”? By whom? Where’s the evidence? How are they “culturally distinct”? What is one such “culturally distinct community”?)

The Daniels decision highlights one of the great contradictions of our age. The author of the decision, Justice Rosie Abella, is a Holocaust descendant. That event was a horrific but logical end-result of the irrational, perverse and racist blood/race myth that permeated Europe at the time, epitomized by the Nuremberg Laws- by the pernicious notion that, depending on your “race”- your “bloodstock”-your “innate personality”[3]was given at birth, and not acquired by merit or life circumstances!

Similarly, but with the best of intentions, Daniels defines legal rights based on considerations of “mixed ancestry” and “Native hereditary basis”- racist race terms! There’s even an uncritical reference to “Indian blood”, as if it were a biological fact, when in fact it is scientifically nonsensical.

Here is the great Israeli intellect and humanist Amoz Oz, from his book Dear Zealots-Letters From a Divided Land, [4] an argument and plea for principled and practical reconciliation between Jews and Palestinians in Israel, on what he regards as the “monstrous concept of “Jewish blood” being proffered by right wing Jewish orthodox fanatics… a central concept in the Nuremberg laws…”:

“Jewish blood” does not appear anywhere in Jewish sources. Not once. We do not have Jewish blood as a concept. In the Bible there is “clean blood.” There is “the voice of thy brother’s blood crieth unto Me from the ground.” There is “Whoso sheddeth man’s blood, by man shall his blood be shed.” Later, we have the saying “Your blood is no redder,” meaning, no redder than anyone else’s blood, for we were all created in the image of God.”

If there is no “Jewish blood”, why would Justice Abella so foolishly posit the concept of “Indian blood”?

“Metis” Professor Chris Anderson, agreeing, wrote of the “deeply racist logic” of Daniels.[5]

We justly decry the white racist, Ku Klux Klan-type assertion that possessing “white blood” makes a person somehow superior to or uniquely different in some positive way from others of different (impliedly inferior) “blood.”

When Stephen Douglass, the 19th century, American Black racial equality activist died, referring to his mixed- race ancestry, the New York Times suggested that Douglass’ “white blood” accounted for his “superior intelligence.”[6] 

Had Justice Abella been around at that time and read that, she would have been greatly and properly offended.

Yet the notion that this well-meaning jurist inadvertently propagated in the Daniels decision-that there is such a thing as “Indian blood” and that this “blood” could account for innate, collective personality characteristics embedded at and by the accident of birth, deserving of special, different treatment by the law many years later- is the same racist idea in reverse, and is equally and fundamentally repellent.

The inadvertently “racist” Daniels decision, and similar recent Supreme Court decisions granting Canada’s Aboriginals new, special rights and entitlements based solely on their so-called distinct blood and race, ironically and inexplicably, given the great humanity of their authors, like Justice Abella, are all antithetical to the lessons of the Holocaust!

Ordinary Metis Canadians who foolishly buy into this Trojan Horse ruling and get themselves registered on some future race-Registry, no doubt based on ingeniously complex, genealogical race-parsing and “community acceptance”- this race-Registry presumably to be constructed at great expense to the Canadian taxpayer- will only see themselves regress from a state of self-supporting independence to a culture and state of dependency and economic stagnation, totally reliant upon government pork barrel largesse, the latter of which, as evidenced below, is already happening in a big way.

In June of 2019, prompted by Daniels, the ever-Panglossian Trudeau government, which never misses a chance to further divide Canadians on the basis of “race” and blood, announced that it had signed “self-government agreements with three provincial branches of the “Metis Nation” in Ontario, Alberta and Saskatchewan. (Manitoba has one as well.) These agreements were stated to be “an upfront recognition of the Metis right to self-government, (again, totally financed by Canadian taxpayers), with further agreements on specific areas of jurisdiction to follow”, such as “childcare, language and the administration of justice”.[7]

Yet, despite what the framers of the constitution, the Supreme Court and the Trudeau government say, there are no distinct Metis “peoples”; there is no distinct Metis race, “community”, language or culture. None exist. The emperor has no clothes. It’s all in peoples’ heads.

People who “self-identify” as Metis are usually just ordinary, assimilated Canadians who, on the aforesaid mainly subjective “my truth” principle, may, based on the natural human need to feel that they “belong” to something bigger than themselves, and pushed along and supported by contemporary social and political currents, come to feel that they are Metis, but this despite any underlying objective basis in fact for that belief. Often as well, understandably, they want to get in on a good thing: free money and benefits.

There’s no way that the Canadian taxpayer should have to pay for these sentimental, self-identification journeys, because basically, as Christopher Hitchens wrote of this sad phenomenon in Letters to a Young Contrarian, (see Note 2), “it’s just more familiar old garbage about tribe and nation.”

The only real significance and consequence of “Metis” and of what the framers of the constitution, the Supreme Court and the Trudeau government have done relating to the fantasy “Metis peoples”, is that they have created a separate, Metis-claimant branch of the Indian Industry, the sole purpose of which is to perpetuate the Metis fantasy and the government funding for the insider jobs and the phony, essentially worthless programs that the holders of these jobs need to create in order to keep the Metis fantasy wheel spinning.

The core reality of “Metis” in 21st century Canada is that consistent with the capitalist/mercantile origins of the Metis, it’s all about money- long ago, money for actual work performed- now, money in the form of government funding for essentially sitting around and dreaming up fake work. And it’s now about who gets to control and play with that funding. This is a factual and an intellectually and emotionally empty core reality- an amoral core reality devoid of public good or public purpose. It’s also a total waste of taxpayers’ dollars.

In such circumstances, when, boiled down, an organization has no valid, higher mission to perform that tends to conscientiously occupy and discipline its insiders- when it has no mission other than to ensure its own continued existence and the make-work jobs of its insiders- then inevitably internal squabbles arise amongst those insiders, (who have nothing more worthwhile to devote their time and mental energies to), over those jobs, the money and the perks.

This is precisely the kind of shameful, enervating situation- a situation evidencing such easy, self-entitled, profligacy with public funds- that has been created by the framers of the constitution, the Supreme Court and the Trudeau government and that is extant amongst Canadian Metis elites.

The Metis National Council (MNC) is now suing the Manitoba Metis Federation (MMF) for millions of dollars. The lawsuit arises out of a philosophical difference between the two organizations relating to many of the ignored questions around “who can claim to be a Metis” mentioned at the beginning of this article. The MMF essentially claims that Metis claimants should be restricted to the descendants of the Metis from the “Metis Homeland” in Western Canada, rooted in the Red River area of Manitoba and the areas generally of the Riel rebellions, (being essentially the “National Definition” referred to below.)  The MNC has adopted a broader, “pan-Indigenous” definition based on “self-identification and a connection to the territories outside the “Metis Homeland” i.e., anywhere in Canada, and history be damned.

The MNC is willing to permit more fingers in the government-provided pie. The MMF wants less fingers in there, so naturally, there will be more pie for them.

The lawsuit alleges misappropriation of millions of dollars by the MMF and its insiders, conflict of interest and non-arms-length dealings all in favor of the MMF, who, after these insiders allegedly secretly did all this while working as insiders for the MNC, all as part of a midnight dash-type “scheme”, quit the MNC and immediately thereafter went to the MMF to exploit the spoils of their allegedly wrongful actions. The MMF, in their Court filing, denies it or these insiders did anything wrong. As an alternative argument, in another classic capitalist/mercantile evasion of blame tactic, the MMF and their insiders blame their lawyers for a lot of it.

The pleadings in the lawsuit, which are linked to above, speak for themselves, and there is no need for this writer to go through them. The writer recommends the reader to read them, just to see the eye-popping largesse heaped upon these questionable organizations by the Canadian taxpayer and the shocking manner generally in which this largesse has been dealt with.

But both sets of pleadings, in addition to revealing organizations rife with patterns of dealing with astonishing large amounts of taxpayer dollars in an amateurish, casual, irresponsible way, with little government or internal oversight and little regard for established corporate, business, and professional requirements, standards and practices, contain telling admissions that deserve mention.

Paragraph 5 of the MNC claim avers that there is a basic argument between the organizations over who should have the “paramount authority to speak on behalf of Canada’s Metis Nation.” (That is, which organization should receive and control the bulk of the government money.) In this regard, at paragraph 60, the MNC claims that the MMF considers itself, (by MNC standards, wrongfully of course), the only one which can “stand tall as the only true Metis Government…”

At paragraph 51 the MNC claims: “Since at least 2017 there has arisen among the governing members of MNC a dispute concerning the identification and recognition of citizens of the Metis Nation…”. That is, since the “deeply racist” Daniels. (Note the highfalutin misuse of the word “citizens” and the pretentious puffery of capitalizing “Metis Nation.” If they are “citizens” of the “Metis Nation”, why are they fighting over dollars supplied by the citizens of the nation of Canada?)

The MMF, in paragraph 4 of its Statement of Defence, claims that the MNC lawsuit is “the latest salvo from the MNC against the MMF and David Chartrand in a broader political dispute over the representation of the Metis people”, and at paragraph 50, a broader dispute “over what it means to be Metis”.

The MMF claims in paragraph 11 of its Defence that once Ms. Cassidy Caron was elected president of the MNC on September 29, 2021, the MNC formerly embraced the more expansive definition of “Metis” advanced by the Metis Nation of Ontario. Specifically:

Since her election the MNC has continued to grant memberships to individuals who do not meet the National Definition. The MNC has instead granted memberships on the basis on “new historic Metis communities”.

So, on the same day that Ms. Caron was elected President, September 29, 2021, the MMF quit the MNC and, having allegedly secretly and pre-emptively prepared for this, took a lot of MNC taxpayer supplied monies and taxpayer funded programs with them back to their own exclusive Manitoba Metis fantasy shop, and since then has operated on its own, and largely with allegedly misappropriated MNC monies and programs.

In paragraph 47 of its Defence the MMF boasts, like in a dynamic, capitalist, company’s press release to the market, that it “was a primary driver of the MNC’s growth and success in procuring billions of dollars in funding from the federal government and other sources for the benefit of the Metis Nation”. In paragraph 134 they peg that figure for the period 2017-2021, from the federal government alone, at $3.4 billion!

Lots of taxpayers’ monies to fight over!

Interestingly, the MMF admits in their pleading that a lot of what they did, in later years mainly through David Chartrand, was not authorized by the MNC’s corporate by-laws. At paragraph 45 the MMF and Chartrand state:

The MNC has always operated in accordance with Metis Nation traditions, practices and procedures, which are well known and accepted by the Metis Nation…even though (its) by-laws do not provide for that governance and administrative structure.

As MMF pleaded, their explanation for this was essentially that it and Mr. Chartrand had been doing things their own allegedly “Metis” way since 2003, and no one ever objected, so what’s the problem?

In the opinion of this writer, just based on the pleadings, the MMF and its insiders have a weak legal case.  To me, they flunk the “smell test.”

A well-known feature of a weak legal case is the presence of “Hail Mary” arguments in the pleadings. MMF’s aforesaid “Metis Nation traditions, practices and procedures” argument is an example of a minor Hail Mary argument. (I would love to see the cross-examination in Court on that one. Propagandists hate being asked for specifics.)

MMF adds to the entertainment factor generally of Hail Mary arguments by making a major one. MMF pleads in effect, (paragraph 76), that holding Metis organizations to the same legal, fiduciary and ethical standards as non-Aboriginal business organizations would frustrate “reconciliation” between Aboriginal and non-Aboriginal Canadians and run counter to section 35 of the Constitution Act! The exact wording of this audacious argument is as follows:

Furthermore, the MNC’s claim improperly reduces itself to a corporate entity. The MNC is an Indigenous representation body and properly viewed through the lens of recognition, reconciliation, and affirmation. In this, the MMF and David Chartrand plead and rely on section 35 of the Constitution Act, 1982. Strict compliance with corporate law requirements, and a failure to recognize and affirm the MNC’s long-standing traditions, practices and governance structures, frustrate and run counter to section 35.[8] (Italics added)

The writer reminds the reader again. Metis culture, such as it was and is, is a mixed-race child of capitalism and mercantilism. How could their genuine “traditions, practices and governance structures” be anything other than a reflection of capitalist traditions, practices and governance structures, of which compliance with corporate law requirements is an essential feature?

As illustrated above, affording constitutional rights to such as nebulous group of Canadians as the “Metis peoples” just plays into the weak and purposeless hands of economic opportunists.

But there’s the more important moral argument as well, already partially discussed above as well, against this having been done.

 Professor Tom Flanagan of the University of Calgary wrote of the dangerous and unhealthy tendency, for the seemingly best of motives, using the Metis as an example, of “defining groups of people in racial terms and putting them under the paternalistic control of the state”, as follows: [9]

The rationale…is that Metis have missed out on the benefits that First Nations receive as aboriginal peoples. Ironically, however, the Metis are better off than First Nations precisely because they have always been independent and self-supporting, the “free people”, as they have often called themselves. It is no accident that Metis do better than First Nations on every indicator that Statistics Canada measures, including employment, income, housing and education.

…Individual prosperity comes from developing human capital and participating in the economy, not from building government-funded organizations that tend to separate people from other people. Ethnic groups such as the Chinese, Japanese and Jews have achieved prosperity in Canada despite enduring periods of discrimination.  Would they have done better, or even as well, if their efforts had been devoted to getting their names on a registry to receive compensation for wrongs done to their ancestors? (Italics added)

The Mexican equivalent of Metis and non-status Indians (as stated, no definition given by the Supreme Court for either, the Court preferring to let these petty details, for all 600,000 people, be worked out on a “case by case” (!) basis), are the “mestizaje”- mixed blood Mexicans. They have no special legal, racial status and aspire to none. They’re just “ordinary” Mexicans.

If anything, they are exalted as representing the positive, future-oriented, creative intermingling of the Indigenous and European “races” and cultures that make up the rich, diverse and colourful human human tapestry that characterizes that country – Octavio Paz’ culturally fused “creative participation”[10]– neither the indigenous side nor the European side being regarded as superior to the other.

Not so in rather grim, humorless, Nuremberg laws-like, racially parsing Canada.

Here, Metis, instead of all being regarded as paragons of diversity and racially indifferent living- as the ultimate, positive, personifications of the human benefits and blessings of egalitarian, assimilationist living- of the Nelson Mandela ideal- and thus as an inspiring moral example to us all, (What could be more creatively assimilative and integrationist than the child of a racially mixed union?)-are racially pigeon-holed as of an “Aboriginal” sub-category of sorts,  whose non-Aboriginal side is completely (and rather insultingly) downplayed or ignored.

On the other hand, their Aboriginal side is emphasized, even made to appear to be their sole, defining, almost homogeneous racial characteristic, celebrated, and said, (never demonstrated), to be culturally distinct.

An example of this is Jody Wilson-Raybould, said to be the first Aboriginal person to serve as federal justice minister. Well, not quite. She’s of mixed racial heritage. Her father was Indian and her mother a white schoolteacher. Her husband is a white physician. She was born and raised in Vancouver. She epitomizes the richness and success of the integrationist, assimilationist model! But it’s au courant (and was personally and politically advantageous for her) to be wholly defined as “Aboriginal”.

It’s puzzling.

Our elites are using the positive phenomenon of racial intermixing as something to further legally divide us along racial lines, instead of something that should unite us in egalitarian fashion!

It’s also ironic.

Many of our elites are now pushing the idea that gender is an elastic, subjective concept.

Why aren’t they applying the same principle to the concept of race, which scientists would argue, makes a lot more sense?

Ordinary Canadians don’t buy what the Supreme Court and the rest of our elites are doing- don’t buy this almost-sick obsession with “Indian blood” (an actual phrase from Daniels)- this puffing up the Aboriginal half (or often, the much less than Aboriginal half) and downplaying or outright erasing the non-Aboriginal part- this fabricating “Metis” into a separate, homogeneous race-type category, when in fact it’s the opposite! When in fact it’s the embodiment of racial diversity- of dual or multiple racial (in the social sense) identities.

Seemingly unlike our Supreme Court and the Trudeau government, ordinary Canadians know that we’re all “metis”-we’re all of mixed blood- we’re all human mongrels of one variation or another- and that this mixed biological reality creates the opposite of a state of dependency. And, as we don’t expect special treatment from the government or anyone else because of it, neither should the “Metis peoples” of Canada.

And, even more importantly, we also know that being of mixed or indeterminate “blood”- being a “mongrel”- being biracial or multi-racial- is better and healthier, individually and for society, than being of a homogeneous racial group. We know that being “mixed” in this way:

…makes it harder to fall back on the tribal identities that have guided (disastrously) so much of human history, and that are now resurgent. Your background pushes you to construct a worldview that transcends the tribal…You’re also accustomed to the idea of having several selves, and of trying to forge them into something whole, this task of self-creation (being) a defining experience of modernity.

Focusing on our multiple social identities imparts mental flexibility…and forces one to think more deeply about the world. It’s linked to economic prosperity and creativity.

…The difficulty of diversity is like the power of exercise, where you push yourself to grow your muscles.[11]

The framers of section 35, the Supreme Court of Canada and the Trudeau government take all these wonderful, positive things, demean and negative them and then turn them into causes and sources of petty corruption and instruments of illiberal legal division and social disharmony.

Peter Best

June 7, 2022

[1] Quoted by Lewis Lapham in his essay “Them”, in Lapham’s Quarterly, Winter, 2015

[2] From Letters to a Young Contrarian, Basic Books, New York, 2001

[3] Phrase “innate personality” and idea from Hannah Arendt’s brilliant meditation on the origins of anti-Semitism, The Origins of Totalitarianism.

[4] Dear Zealots- Letter From a Divided Land, Houghton Mifflin Harcourt, Boston, 2018

[5] The Supreme Court Ruling on Metis- A Roadmap to Nowhere, The Globe and Mail, April 14, 2016

[6] From Randall Kennedy, The Confounding Truth About Frederick Douglass, The Atlantic Magazine, December 2018

[7] Maura Forrest, National Post, June 28, 2019

[8] The MMF lawyers may have method behind their seeming madness here. There’s a worrisome trend on the part of some Judges to infantilize Indigenous litigants and, based on their alleged “Indigenous culture”, not hold them to the same adult legal standards as non-Indigenous litigants. For instance, in the Ginoogaming case, referred to in the “infantilize” link, the Judge ridiculously ruled that the Ginoogaming band’s culture was too pre-literate for the band members to understand written communications!

[9] Tom Flanagan, Why the Isaac report on Metis goes in the wrong direction, The Globe and Mail, August 8, 2016

[10] From Octavio Paz, The Labyrinth of Solitude, Grove Press, Inc. 1961

[11] Moises Velasquez-Manoff, What Biracial People Know, The New York Times, March 4, 2017

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