York Condominium Corporation No. 444 v. Ryan (Condominium Authority Tribunal) June 16, 2023

16/06/2023 – Jurisdiction Ontario
Part 83 published on 01/09/2023
Owner’s complaints respecting a neighboring smoker constituted harassment and were an unreasonable noise and nuisance that contravened Section 117 (2) of the Condominium Act as well as the condominium corporation’s governing documents

The Tribunal found that the owner’s complaints respecting a neighboring smoker were not reasonably expressed. The Tribunal said:

 

Ms. Ryan has consistently and for an extended period, harassed Ms. Powell and her children and the management and staff of YCC 444. In the course of this, her conduct constituted a nuisance, annoyance or disruption. While I believe that Ms. Ryan genuinely feels threatened by the smoke and odour she alleges is coming from Ms. Powell’s unit, she has chosen a completely inappropriate course of action to deal with it.

 

The Tribunal held that the owner’s behaviour violated numerous provisions in the condominium corporation’s governing documents which were intended to prevent unreasonable nuisances or disturbances, and accordingly fell within the Tribunal’s jurisdiction to deal with such violations.  The Tribunal said:

 

I conclude that harassment can include conduct that is a nuisance, annoyance or

disruption. While harassment is not a prescribed and prohibited activity under

subsection 117 (2), harassing conduct may be prohibited in the governing

documents of a condominium. Depending on the wording of the provision and the

actual conduct in issue, the conduct may fall within the Tribunal’s jurisdiction.

 

The Tribunal ordered the owner “to cease and desist in that conduct which I have

found to be a nuisance, annoyance or disruption, specifically, the nuisance of

noise under subsection 117 (2), the verbal and written abuse to which she has

subjected Ms. Powell, her children and the management of YCC 444, in particular

the condominium manager and the on-site supervisor, the posting of abusive and

insulting notices on Ms. Powell’s door and on a common element bulletin board of

YCC 444 and the hanging of sheets over her front door and posting notices on the

sheet or front door.”

York Condominium Corporation No. 444 v. Ryan, 2023 ONCAT 81