Hryniak Comes to Manitoba: The Evolution of Manitoba Civil Procedure in the 2010s
Bibliographic record
Abstract
This article investigates whether the Supreme Court of Canada’s 2014 decision Hryniak v Mauldin has led to changes in Manitoba procedural law, largely in the summary judgment context. After introducing Hryniak and civil procedure reform’s place in the context of Canada’s access to justice crisis, the author turns to Manitoba. In addition to exploring the regulatory history of explicit changes to Manitoba’s Court of Queen’s Bench Rules, the author delves into Manitoba case law to determine their jurisprudential consequences and whether they have had effects in terms of the frequency that particular rules are used. Ultimately, it is concluded that, despite some potential to be bolder, by and large, Manitoba has prudently charted its own path in this important area of facilitating access to justice.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.002 | 0.005 |
| Meta-epidemiology (narrow) | 0.000 | 0.001 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.002 | 0.003 |
| Science and technology studies | 0.022 | 0.011 |
| Scholarly communication | 0.007 | 0.001 |
| Open science | 0.002 | 0.005 |
| Research integrity | 0.003 | 0.005 |
| Insufficient payload (model declined to judge) | 0.006 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".