1. I would like to thank the Association of Ontario Midwives (AOM) for its assistance in accessing documentation, including the association’s application, opening statements, submissions, and appendices, as well as the factum of the respondent, analyzed herein. This work developed during a graduate seminar with Pat Armstrong, and I am grateful for her insights and support. Sincere thanks to Leah Vosko for her comments and guidance and to my CJWL reviewers for their thoughtful feedback.
2. AOM, “Schedule ‘A’ to Form 1 Application: Statement of Material Facts and Remedial Requests” at para 16 [AOM, “Statement of Material Facts”]; Human Rights Code, RSO 1990, c H.19 [OHRC].
3. See Association of Ontario Midwives v Ontario (Health and Long-Term Care), 2018 HRTO 1335 [AOM (Interim Decision)]
4. Association of Ontario Midwives v Ontario (Health and Long-Term Care), 2018 HRTO 1335 (Final Submission of the Association of Ontario Midwives, Part A - Evidence) at para 190 [AOM (Evidence)]
5. Paul Durber, "Examining the Issue of Equitable Compensation for Ontario's Midwives: An Expert Report Prepared for the Association of Ontario Midwives", Association of Ontario Midwives Hugh Mackenzie, "Midwives' Compensation in Ontario 1994 to 2013: Comparative Analysis and Implications of Pay Equity" (2013) [on file with author].