Our last installment of this series discusses where privacy law
torts are heading and what we can expect in the near future from
the courts and legislature alike.
1. Courts Country Wide Continue to Tackle "Revenge
Porn" Cases
In March of this year, a Manitoba court awarded Brittany Roque
$60,000 when her private intimate photos were maliciously shared
with the Brandon Police Service (BPS), her potential employer1. Years
prior, Roque had been in a relationship with a Brandon police
officer. The officer's then romantic partner, Terry Lynn
Peters, found Roque's images and shared them with the BPS.
Roque sued the BPS and Peters, who shared the images. The court
awarded Roque $45,000 in general damages, finding the BPS and
Peters jointly liable. The court specifically found Peters liable
for $15,000 in aggravated damages. Importantly, Roque's civil
suit was brought under Manitoba's Intimate Image Protection
Act, passed in 2016. Not all provinces have this kind
