Recognizing same-sex relationships: The evolution of recent federal and provincial policies

Canadian Public Administration

Volumn 45, Issue 1, 2002, Pages 1-23

  Smith, Miriam ^a  

^a CARLETON UNIVERSITY   (Canada)

Author keywords

[No Author keywords available]

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EID: 0038893593     PISSN: 00084840     EISSN: None     Source Type: Journal    
DOI: 10.1111/j.1754-7121.2002.tb01071.x     Document Type: Article

References (88)

1. The term "gay rights" is a shorthand often used by journalists. In fact, though, this term has been out of fashion since the late seventies/early eighties when it was challenged by lesbians, who did not wish to be called "gay" because they felt that the term "gay" was male. "Lesbian, gay, bisexual and transgendered" (LGBT) is usually used by formally organized, equality-seeking organizations such as EGALE, while "queer" is often favoured by those who wish to deconstruct the multiple identities of the communities, whether in political practice or scholarly activity. I use the terms "lesbian and gay" or "LGBT" throughout the article.
2. For example, some voices in the LGBT community in Canada are opposed to same-sex marriage, while others are strongly in favour of it. Jane Rule, a well-respected novelist and lesbian, has argued that "[t]o be forced back into the heterosexual cage of coupledom is not a step forward but a step back into state-imposed definitions of relationship. With all that we have learned, we should be helping our heterosexual brothers and sisters out of their state-defined prisons, not volunteering to join them there." Cited in Tom Yeung, "Lawlessness as lifestyle: Icon Jane Rule refuses to apply for survivor benefits. 5 April 2001, issue 429, " Xtra.ca [web site] ([Toronto]: [Pink Triangle Press], [2002]), at http://www.xtra.ca/site/ toronto2/arch/body429.shtm, p. 1. While the public policy debate may appear to have two sides, from the perspective of the LGBT communities, it is complex and many-sided.
3. st Century (Scarborough, Ont.: Nelson, 2000), pp. 217-50.
4. Alan C. Cairns, "The Politics of Constitutional Renewal, " in Alan C. Cairns, Disruptions: Constitutional Struggles, from the Charter to Meech Lake. Edited by Douglas E. Williams (Toronto: McClelland & Stewart, 1991), pp. 66-107.
5. EGALE has recently changed its name from the long form, Equality for Gays and Lesbians Everywhere/Egalité pour les gais et les lesbiennes (EGALE) to simply EGALE.
6. Provinces have jurisdiction over "solemnization" of marriage (B.N.A. Act, s. 92), while the federal government has jurisdiction over "marriage and divorce" (B.N.A. Act, s. 91), usually interpreted as the "capacity" to marry. For the legal details on how the jurisdictional division affects same-sex marriage, see John Fisher, Kathleen Lahey and Laurie Aaron, Division of Powers and Jurisdictional Issues Relating to Marriage (Ottawa: Law Commission of Canada, 2000).
7. Ironically, in view of his preference for strong central government authority, Pierre Trudeau argued that federalism afforded the opportunity for public policy experiments in the provinces that could then spread from one jurisdiction to another. See Pierre Trudeau, "The Practice and Theory of Federalism, " Federalism and the French Canadians (New York: St. Martin's Press, 1968), pp. 124-50.
8. nd edition (Boston: Twayne, 1995); Becki Ross, The House That Jill Built: A Lesbian Nation in Formation (Toronto: University of Toronto Press, 1995); Gary Kinsman, The Regulation of Desire: Homo and Hetero Sexualities, revised edition (Montreal: Black Rose Books, 1996); and David M. Rayside, On the Fringe: Gays and Lesbians in Politics (Ithaca, N.Y.: Cornell University Press, 1998).
9. nd edition (Boston: Twayne, 1995); Becki Ross, The House That Jill Built: A Lesbian Nation in Formation (Toronto: University of Toronto Press, 1995); Gary Kinsman, The Regulation of Desire: Homo and Hetero Sexualities, revised edition (Montreal: Black Rose Books, 1996); and David M. Rayside, On the Fringe: Gays and Lesbians in Politics (Ithaca, N.Y.: Cornell University Press, 1998).
10. nd edition (Boston: Twayne, 1995); Becki Ross, The House That Jill Built: A Lesbian Nation in Formation (Toronto: University of Toronto Press, 1995); Gary Kinsman, The Regulation of Desire: Homo and Hetero Sexualities, revised edition (Montreal: Black Rose Books, 1996); and David M. Rayside, On the Fringe: Gays and Lesbians in Politics (Ithaca, N.Y.: Cornell University Press, 1998).
11. nd edition (Boston: Twayne, 1995); Becki Ross, The House That Jill Built: A Lesbian Nation in Formation (Toronto: University of Toronto Press, 1995); Gary Kinsman, The Regulation of Desire: Homo and Hetero Sexualities, revised edition (Montreal: Black Rose Books, 1996); and David M. Rayside, On the Fringe: Gays and Lesbians in Politics (Ithaca, N.Y.: Cornell University Press, 1998).
12. David M. Rayside and Evert A. Lindquist, "AIDS activism and the state in Canada, " Studies in Political Economy 39 (Autumn 1992), pp. 37-76.
13. Miriam Smith, "Social movements and equality-seeking: The case of gay liberation in Canada, " Canadian Journal of Political Science 31, no. 2 (June 1998), pp. 285-309.
14. "Two-spirited" is a term used by some aboriginal lesbians, gay men, transsexual and transgendered people to describe themselves. In some aboriginal communities, the term originally referred to visionaries who shared in both female and male spirit (hence "two-spirited"). For a recent discussion, see Wayne van der Meide, The Intersection of Sexual Orientation & Race: Considering the Experiences of Lesbian, Gay, Bisexual, Transgendered People of Colour & Two-Spirited People (Ottawa: EGALE Canada, 2001).
15. Gerald Hunt, "No longer outsiders: Labor's response to sexual diversity in Canada, " in Gerald Hunt, ed., Laboring for Rights: Unions and Sexual Diversity Across Nations (Philadelphia: Temple University Press, 1999), pp. 10-36.
16. Deborah McIntosh, "Appendix I: Court cases in which sexual orientation arguments under section 15 of the Charter were raised, " in Miriam Smith, Lesbian and Gay Rights in Canada: Social Movements and Equality-Seeking, 3972-1995 (Toronto: University of Toronto Press, 1999), pp. 157-63. Cases after 1996 are based on my own ongoing count of reported cases. For similar results in case counting; see Foundation for Equal Families, "Taking it to the courts [various court decisions], " Foundation for Equal Families [website] ([Toronto]: Foundation, [2002]). Note that none of these counts include the important area of tribunal decisions.
17. Deborah McIntosh, "Appendix I: Court cases in which sexual orientation arguments under section 15 of the Charter were raised, " in Miriam Smith, Lesbian and Gay Rights in Canada: Social Movements and Equality-Seeking, 3972-1995 (Toronto: University of Toronto Press, 1999), pp. 157-63. Cases after 1996 are based on my own ongoing count of reported cases. For similar results in case counting; see Foundation for Equal Families, "Taking it to the courts [various court decisions], " Foundation for Equal Families [website] ([Toronto]: Foundation, [2002]). Note that none of these counts include the important area of tribunal decisions.
18. Mary C. Hurley, Sexual Orientation and Legal Rights (Ottawa: Library of Parliament Research Branch, 1999), p. 4 .
19. Ibid., p. 7.
20. David Rayside, "Gay rights and family values: The passage of bill 7 in Ontario, " Studies in Political Economy 26 (Summer 1988), pp. 109-47.
21. For an excellent overview of recent Charter jurisprudence in the area of family law, including same-sex relationship recognition, see Susan B. Boyd, "The impact of the Charter of Rights and Freedoms on Canadian family law, " Canadian Journal of Family Law 17, no. 2 (2000), pp. 293-331. For overviews of homosexuality and law in Canada, see Kathleen Lahey, Are We Persons Yet? Law and Sexuality in Canada (Toronto: University of Toronto Press, 1999); and Bruce MacDougall, Queer Judgments: Homosexuality, Expression and the Courts in Canada (Toronto: University of Toronto Press, 2000).
22. For an excellent overview of recent Charter jurisprudence in the area of family law, including same-sex relationship recognition, see Susan B. Boyd, "The impact of the Charter of Rights and Freedoms on Canadian family law, " Canadian Journal of Family Law 17, no. 2 (2000), pp. 293-331. For overviews of homosexuality and law in Canada, see Kathleen Lahey, Are We Persons Yet? Law and Sexuality in Canada (Toronto: University of Toronto Press, 1999); and Bruce MacDougall, Queer Judgments: Homosexuality, Expression and the Courts in Canada (Toronto: University of Toronto Press, 2000).
23. For an excellent overview of recent Charter jurisprudence in the area of family law, including same-sex relationship recognition, see Susan B. Boyd, "The impact of the Charter of Rights and Freedoms on Canadian family law, " Canadian Journal of Family Law 17, no. 2 (2000), pp. 293-331. For overviews of homosexuality and law in Canada, see Kathleen Lahey, Are We Persons Yet? Law and Sexuality in Canada (Toronto: University of Toronto Press, 1999); and Bruce MacDougall, Queer Judgments: Homosexuality, Expression and the Courts in Canada (Toronto: University of Toronto Press, 2000).
24. Correctional Services of Canada v. Veysey, [1990] 109 N.R. 300; Haig and Birch, [1992] 9 O.R. (3d) 495, 94 D.L.R. (4th) 1, 16 C.H.R.R. D/226, 57 O.A.C. 272, 10 C.R.R. (2d) 287; Mossop v. Dept. of Sec. State, [1989] 89 C.L.L.C. 16, 041 (C.H.R.T.); [1993] 1 S.R.C. 554 (S.C.C.); and Egan v. Canada, [1995] S.C.J. No. 43, File No. 23636.
25. Geoffrey Yorke, "Ottawa accepts court ruling on gay rights, " The Globe and Mail (Toronto), 31 October 1992, p. A10.
26. Karen Patrick, "Spousal benefits, " Capital Xtra (Ottawa), 20 September 1996, p. 7.
27. Vriend v. Alberta, [1998] 1 S. C. R. 493; Rosenberg v. Canada (Attorney General), [1998] 38 O. R. (3d) 577; and M v. H, [1999] S. C. J. No. 23.
28. During the time-period covered in this article, the Reform Party reconstituted itself as the Canadian Alliance. I use the term Reform/Canadian Alliance throughout the article to signify the party in transition.
29. Norma Greenaway, "Reform takes aim at Supreme Court activism: They say the court has used the Charter for a power grab, " The Ottawa Citizen, 6 December 1999, p. A11.
30. Philip Hannon, "Challenging an archaic system, " Capital Xtra (Ottawa) 19 November 1993, p. 1.
31. CUPE, "Winning Out at Work: Partner Recognition Litigation, " [n.d.], pp. C-15-16.
32. Susan B. Boyd, "Best friends or spouses? Privatization and the recognition of lesbian relationships in M. V. H., " Canadian Journal of Family Law 13, no. 1 (1996), pp. 321-41.
33. Same-sex partnering ceremonies have been performed in some Canadian churches since the sixties. The idea of using banns to marry same-sex partners is not new either, although it is sometimes claimed to be so. In fact, the first gay marriage by means of the reading of banns was that of Richard North and Chris Vogel on 11 February 1974. See Peter Carlyle-Gordge, "Vogel and North pioneering partners, " Outlooks (March 2001), p. 28.
34. th) 214 (Ont. Ct. of Justice, Gen. Div.).
35. John Fisher, executive director, EGALE. Interview, 6 February 2001.
36. See, for example, Yeung, "Lawlessness as lifestyle, " Xtra.ca [web site].
37. R. Brian Howe and David Johnson, Restraining Equality: Human Rights Commissions in Canada (Toronto: University of Toronto Press, 1999), pp. 91-5. Although provincial governments show a clear-cut distinction between right and left on lesbian-and gay-rights issues, it is evident from the schisms on the right in federal politics that parties of the right may in turn be subdivided between the social conservatives (e.g., Canadian Alliance) and social liberals (a majority of the federal Tory caucus in spring 2000 as measured by the 10-4 vote in favour of Bill C-23).
38. Irène Demczuk and Frank W. Remiggi, "Un demi-siècle de changements, " in Irène Demczuk and Frank W. Remiggi, eds., Sortir de l'ombre: Histoires des communautés lesbienne et gaie de Montréal (Montreal: VLB Éditeur, 1998), pp. 13-23.
39. Of the many criticisms of the Klein government's actions by socially conservative groups, see REAL Women of Canada, "REALity: Mr. Klein and the Supreme Court." vol. 16, no. 7 (January/February 1998) newsletter, Real Women of Canada [web site] ([Toronto]: [Real Women of Canada], [2002]), at www.realwomenca.com/htmlnewsletter/1998_jan_Feb/ Article_10.html. On the Vriend debate in Alberta, see Brian Laghi, "Debate on gay rights polarizes Albertans, " The Globe and Mail (Toronto) 2 April 1998, p. A1.
40. Of the many criticisms of the Klein government's actions by socially conservative groups, see REAL Women of Canada, "REALity: Mr. Klein and the Supreme Court." vol. 16, no. 7 (January/February 1998) newsletter, Real Women of Canada [web site] ([Toronto]: [Real Women of Canada], [2002]), at www.realwomenca.com/htmlnewsletter/1998_jan_Feb/ Article_10.html. On the Vriend debate in Alberta, see Brian Laghi, "Debate on gay rights polarizes Albertans, " The Globe and Mail (Toronto) 2 April 1998, p. A1.
41. Of the many criticisms of the Klein government's actions by socially conservative groups, see REAL Women of Canada, "REALity: Mr. Klein and the Supreme Court." vol. 16, no. 7 (January/February 1998) newsletter, Real Women of Canada [web site] ([Toronto]: [Real Women of Canada], [2002]), at www.realwomenca.com/htmlnewsletter/1998_jan_Feb/ Article_10.html. On the Vriend debate in Alberta, see Brian Laghi, "Debate on gay rights polarizes Albertans, " The Globe and Mail (Toronto) 2 April 1998, p. A1.
42. CBC News Online staff, "CBC News: Anti-gay marriage bill passes. 16 March 2000, " cbc.ca [web site] ([Toronto]: CBC, 2002), at http://cbc.ca/cgi-bin/templates/view.cgi?category= Regional&story=/news/2000/03/16/gay000316.
43. Brenda Cossman, "Ignoring the courts: Putting minority rights to majority votes. 16 December 1999, issue 395, " Xtra.ca [web site] ([Toronto]: [Pink Triangle Press], (2002)), at http:// www.xtra.ca/site/toronto2/arch/body395.shtm.
44. Amendments Because of the Supreme Court of Canada Decision in M v. H, S.O. 1999, c. 6.
45. EGALE Canada, "Press release, October 25, 1999: Ontario introduces omnibus legislation, refuses to extend definition of 'spouse, '" EGALE Canada [web site] ([Ottawa]: [EGALE Canada], [2002]), at http://www.egale.ca/pressrel/991025.htm.
46. CLGRO [Coalition for Lesbian & Gay Rights in Ontario], "A statement from CLGRO: Ontario's "same-sex partner" law - Not what we asked for - but as good as we can get [Press release]. October 26, 1999, " CLGRO [web site] ([Toronto]: CLGRO, [2002]), at http://www.web.net/ ˜clgro/frames.htm.
47. McIntosh, "Appendix 1, " in Smith, Lesbian and Gay Rights in Canada, p. 163.
48. Carle Bernier-Genest, "Divorce en perspective. 18 août 1998 [from RG (Montreal), a gay news and cultural magazine], ColbaNet [web site] (Ville Saint-Laurent: ColbaNet, 1998-99), at http://www.colba.net/˜carleb/articles/mariage.html; [n.a.], "Conjoint de même sexe, " RG (Montreal), July 1998.
49. Sarah Binder, "Gay couple launch court battle to legalize same-sex marriage, " The Globe and Mail (Toronto) 15 September 1998, p. A6. Quebec's human-rights legislation had prohibited discrimination based on sexual orientation since 1977.
50. EGALE Canada, "Press release, June 11, 1999: Quebec changes the definition of "spouse" in 39 laws & regulations and becomes the first province in Canada to treat same-sex spouses equally with common-law spouses, " EGALE Canada [web site] ([Ottawa]: [EGALE Canada], [2002]), at http://www.egale.ca/pressrel/990611.htm.
51. Eleanor Brown, "You'd better really love each other - Because once achieved in Quebec, gay marriage is forever. 30 December 1999, issue 396, " Xtra.ca [web site] ([Toronto]: [Pink Triangle Press], [2002]), at http://www.xtra.ca/site/toronto2/arch/body396.shtm; and Ann Robinson, "Le marriage pour les gaies et lesbiennes." May 2000, Fugues [web site] ([Montreal]: Erico, 1995-2001), at http://www.fugues.com/mariage.html.
52. Eleanor Brown, "You'd better really love each other - Because once achieved in Quebec, gay marriage is forever. 30 December 1999, issue 396, " Xtra.ca [web site] ([Toronto]: [Pink Triangle Press], [2002]), at http://www.xtra.ca/site/toronto2/arch/body396.shtm; and Ann Robinson, "Le marriage pour les gaies et lesbiennes." May 2000, Fugues [web site] ([Montreal]: Erico, 1995-2001), at http://www.fugues.com/mariage.html.
53. EGALE Canada, "Press release. May 29, 2000: B.C. makes history: supports same-sex couples' right to marry, " EGALE Canada [web site] ([Ottawa): [EGALE Canada], [2002]), at http:// www.egale.ca/pressrel/000529.htm.
54. Kevin Cox, "Nova Scotia gay couples given legal recognition, " The Globe and Mail (Toronto), 5 June 2001, p. A5.
55. Gilles Marchildon, "Legislation introduced to comply with Supreme Court ruling in M v. H, " Winnipeg Free Press, 30 May 2001, p. A3; and Murray Mandryk, "Government amends laws relating to gay couples, " The StarPhoenix (Saskatoon), 31 May 2001, p. A3.
56. Gilles Marchildon, "Legislation introduced to comply with Supreme Court ruling in M v. H, " Winnipeg Free Press, 30 May 2001, p. A3; and Murray Mandryk, "Government amends laws relating to gay couples, " The StarPhoenix (Saskatoon), 31 May 2001, p. A3.
57. R. Kent Weaver, "The politics of blame avoidance, " Journal of Public Policy 7 no. 4 (October-December 1986), pp. 371-98.
58. Foundation for Equal Families, Notice of Application ([Toronto]: Foundation, 1999).
59. Foundation for Equal Families, "Equal Families Canada Court Challenge: Winning Equality for our Families in the Courts, " Foundation for Equal Families [web site] ([Toronto]: [Foundation], [2002]), at http://www.ffef.ca; and EGALE Canada, "Gay Community Launches Historic Federal Legal Challenge to Recognize Same-Sex Families, Press release, January 7, 1999, " EGALE Canada [web site] ([Ottawa]: [EGALE Canada], [2002]), at http://www.egale.ca/ pressrel990107.htm.
60. Foundation for Equal Families, "Equal Families Canada Court Challenge: Winning Equality for our Families in the Courts, " Foundation for Equal Families [web site] ([Toronto]: [Foundation], [2002]), at http://www.ffef.ca; and EGALE Canada, "Gay Community Launches Historic Federal Legal Challenge to Recognize Same-Sex Families, Press release, January 7, 1999, " EGALE Canada [web site] ([Ottawa]: [EGALE Canada], [2002]), at http://www.egale.ca/ pressrel990107.htm.
61. EGALE Canada, "PM waffles on same-sex equality, Press release, January 20, 1999, " EGALE Canada [web site] ([Ottawa]: [EGALE Canada], [2002], http://www.egale.ca/ pressrel990120.htm.
62. Shawn McCarthy, "Tax act to recognize same-sex couples, " The Globe and Mail (Toronto), 29 March 1999, pp. A1, A6.
63. EGALE Canada, "House of Commons votes May 25, 1999 on same-sex survivor benefits. Press release, May 25, 1999, " EGALE Canada [web site] ([Ottawa]: [EGALE Canada], [2002]), at http: //www.egale.ca/pressrel/990525.htm.
64. Kathryn May, "Pension reform raises spectre of 'sex police, '" The Ottawa Citizen, 28 April 1999, p. A1.
65. Sheldon Alberts, "Reform wants marriage to mean man and woman, " National Post (Toronto), 16 June 1999, p. A1.
66. Tim Naumetz, "Justice minister backs Reform: Marriage is union of man and woman, " The Ottawa Citizen (Ottawa), 9 June 1999, p. A3.
67. John D. Whyte, "Clouding equality: The rights bill comes with a subtext, " The Globe and Mail (Toronto), 9 May 1996, p. A23.
68. Cited In Alberts, "Reform wants marriage to mean man and woman, " National Post.
69. Randall Palmer, "Canadian House says marriage is man and woman, " Reuters, 9 June 1999.
70. Jim Bronskill, "Canadians support same-sex benefits, survey reveals, " The Ottawa Citizen, 26 January 1999, p. A3.
71. EGALE Canada, "Separate is unequal! No separate definition for those in same-sex relationships. Press release, November 3, 1999, " EGALE Canada [web site] ([Ottawa]: [EGALE Canada], [2002]), at http://www.egale.ca/pressrel/991103.htm.
72. An Act to Modernize the Statutes of Canada in Relation to Benefits and Obligations [Bill C-23], S.C. 2000, c. 12.
73. EGALE Canada, "Omnibus federal law recognizes same-sex couples. InfoEGALE, a newsletter for EGALE Canada [Summer 2000], " EGALE Canada [web site] ([Ottawa]: [EGALE Canada], [2002]), at http://www.egale.ca/documents/infoEGALE_Summer2000.
74. Valerie Lawton, "Same-sex legislation due this week, " The Toronto Star, 8 February 2000, p. A3.
75. EGALE Canada, "The Modernizing Benefits and Obligations Bill, analysis. February 11, 2000, " EGALE Canada [web site] ([Ottawa]: [EGALE Canada], [2002]), at www.egale.ca/documents/omnibus_analysis.htm.
76. For background on these issues see Kinsman, The Regulation of Desire, pp. 267-78; and Miriam Smith, "Reluctant Recognition: The Liberal Government and Lesbian and Gay Rights, " in Leslie A. Pal, ed., How Ottawa Spends, 1998-99: The Post-Deficit Mandate (Toronto: Oxford University Press, 1998), pp. 293-314.
77. For background on these issues see Kinsman, The Regulation of Desire, pp. 267-78; and Miriam Smith, "Reluctant Recognition: The Liberal Government and Lesbian and Gay Rights, " in Leslie A. Pal, ed., How Ottawa Spends, 1998-99: The Post-Deficit Mandate (Toronto: Oxford University Press, 1998), pp. 293-314.
78. Canada, Department of Justice, "Child Victims and the Criminal Justice System: A Consultation Paper, " November 1999.
79. EGALE Canada, "EGALE'S Age of Consent Questionnaire. [1 March 2000], " Island.com [web site] ([n.p.]: Islandnet AMT Solutions Group Inc., 2001), at www.islandnet.com/˜egale/ questionnaire.htm.
80. There is also the problem of proving the bona fides of a same-sex relationship for immigration purposes in the absence of a legal marriage. In many countries, lesbians and gay men cannot live openly. It may be difficult for a same-sex couple to provide documentation of their relationships or evidence that they have lived together.
81. EGALE Canada, "EGALE submissions to the House of Commons standing committee on justice and human rights: Bill C-23 - The Modernization of Benefits and Obligations Act, " EGALE Canada [web site] ([Ottawa]: [EGALE Canada], [2002]), at http://www.egale.ca/documents/ C23submission.htm, p. 5.
82. Garry Breitkreuz, Canadian Alliance M.P. (Yorkton-Melville), "News Release, 2 March 2000, Breitkreuz renames Bill C-23, The Death of Marriage Act, " Garry Breitkreuz [web site] ([Ottawa]: [Canadian Alliance], [2002]), at http://www.garrybreitkreuz.com/breitkreuzg-press/marriage2.htm.
83. Cited in Philip Hannon, "Destroying Innocent Lives: Blood-sucking homos continue to stymie family values politicians. 18 April 2000, issue 404, " Xtra.ca [web site] ([Toronto]: [Pink Triangle Press], [2002]), at http://www.xtra.ca/site/toronto2/arch/body505.shtm.
84. Ibid.
85. nd session, vol. 53, 21 February 2000 (Ottawa: Public Works and Government Services, 2000), pp. 1705-710.
86. Foundation for Equal Families, "Feds legitimate discrimination in equity bill on same-sex benefits. 18 June 2000, " Foundation for Equal families [web site] ([Toronto]: [Foundation], [2002]), at www.ffef.ca; and EGALE Canada, "Bill C-23: No marriage amendment [Press release, April 2000], " EGALE Canada [web site] ([Ottawa]: [EGALE Canada], [2002]), at http:// www.egale.ca/documents/marriage.htm.
87. Foundation for Equal Families, "Feds legitimate discrimination in equity bill on same-sex benefits. 18 June 2000, " Foundation for Equal families [web site] ([Toronto]: [Foundation], [2002]), at www.ffef.ca; and EGALE Canada, "Bill C-23: No marriage amendment [Press release, April 2000], " EGALE Canada [web site] ([Ottawa]: [EGALE Canada], [2002]), at http:// www.egale.ca/documents/marriage.htm.
88. The NDP has supported all of Ottawa's lesbian-and gay-rights measures. The BQ and the PCs have been divided but have offered no significant public opposition to gay rights.