First Recognition of a Stand-Alone Tort of Harassment in Alberta

In Alberta Health Services v Johnston, the Court of King's Bench recognized — for the first time in Alberta — a stand-alone common law tort of harassment. The decision is significant because it provides a direct civil remedy for targeted, repeated, and harmful conduct that falls outside traditional torts.

The Court adopted a four-part test focused on outrageous conduct, intent or recklessness, fear/anxiety/emotional distress, and resulting harm.

The case has broad implications for employment, public-figure, and online-harassment disputes. Plaintiffs now have a clearer pathway; defendants need to take complaints seriously and respond early.

Our civil litigation lawyers advise on harassment claims for organizations, executives, and individuals across Alberta.