Prematurity: Challenges To The Hearing Tribunal's Jurisdiction

In Goodwin v Alberta College and Association of Chiropractors, 2022 ABQB 177, the Court of Queen's Bench provided a clear statement on prematurity and the timing of judicial reviews from administrative bodies. In this case, the regulated member brought a premature application for the Court to determine issues that would be key in his upcoming disciplinary hearing. This case is also significant as it is the first judicial consideration of the Health Profession Act's sexual abuse and sexual misconduct provisions.

Goodwin met Ms. W while providing her with chiropractic treatment, and in July 2019, the two began dating. Goodwin initially referred Ms. W to another chiropractor, but she was unhappy with her treatment and returned to Goodwin as a patient. According to Goodwin, he and Ms. W have been acting as "spouses" since July 2019.