Alberta Court Rejects "Boilerplate" Release Language In Proposed Class Action Settlement

In Walter v WHL, the Alberta Court of Queen's Bench refused to approve the settlement of three related class actions where the proposed release contained what is often considered "standard" or "boilerplate" language pertaining to claims that "could have been raised or advanced in the Class Actions, whether known or unknown, or by reason of any cause, matter or thing whatsoever."

Background

The class actions concerned whether major junior hockey players in the Ontario Hockey League, the Western Hockey League and the Québec Major Junior Hockey League should be treated as employees and, thus, entitled to minimum wages prescribed by employment standards legislation in the applicable province.