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Presentation - 'Organized Pseudolegal Commercial Argument' (OPCA). Home Trust Company v. Campbell
In Home Trust Company v. Campbell (Ont CA, 2026) the Ontario Court of Appeal found defendant-filed materials "consistent with the illegitimate litigation tactics commonly referred to as “organized pseudo-legal commercial arguments”":[1] The moving party, Louise Miner[1], claims to be appearing as “sole living Executor and Beneficiary of the private estate styled LOUISE MINER” and as an “Authorized Representative for Secured Party the MINER EXPRESSED TRUST”. She has filed various documents on the authority of “Biblical Affirmations” and bearing a seal “Ab Initio De Jure Great Seal – Superior Covenant”. She brings a motion for an extension of time “to revoke and revest” within appeal file no. COA-25-CV-0815.
[2] The materials filed by Louise are incomprehensible. They are irrelevant to the legal issues in this proceeding, which is a simple mortgage enforcement action. For the reasons set out below, the motion is dismissed.
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[8] That decision was upheld on a panel review dated November 17, 2025 (M56132). The review panel’s endorsement made the following comments on the materials that Louise had filed:... [N]one of the additional and voluminous documents Louise has filed, bearing titles such as “bill of exchange”, “bill of lading” and “notice of recission for cause”, have any relevance to this matter. Also not relevant are her stated position as an executor and beneficiary of the estate of Louise Miner, her references to the IRS (the U.S. Internal Revenue Service), and her statement that the main account has been “reclaimed by the trust and discharged”. There is no evidence that the amount owing has been paid to the respondent or discharged. ....
Motion for Extension of Time to “Revest and Revoke”
[10] As noted above, the present motion is brought by Louise, purportedly in her capacity as “Executor and Beneficiary of the trust estate styled as Louise Miner”, for an extension of time to “revest and revoke”. In oral submissions Louise was not able to explain the purpose or subject matter of the motion, including what was to be “revested or revoked”, why an extension of time was necessary to accomplish these actions, or how any such actions were relevant to the Underlying Proceeding and her appeal. Instead, she referred to various documents such as a “SS-4 Form from Department of the Treasury and Certificate of Trust – funded date January 8th, 2005”, a “Security Agreement – Nune Pro Tunc February 8th, 1989” , various IRS Forms, a “UCC1 – public notice”, a “Writ of Fractural Consent Revocation” and a ”Writ of Rebuttal to Machine Law, Ethics, and Morality in the Age of Artificial Intelligence.”
[11] These materials and Louise’s submissions are consistent with the illegitimate litigation tactics commonly referred to as “organized pseudo-legal commercial arguments” (“OPCA”): see Meads v. Meads, 2012 ABQB 571, 543 A.R. 215. As Myers J. accurately observed in Jarvis v. Morlog, 2016 ONSC 4476, OPCA claims are frivolous, vexatious, and an abuse of process on their face. . R. v. Robinson
In R. v. Robinson (Ont CA, 2025) the Ontario Court of Appeal denied a motion for waiver of the duty to file a transcript on a criminal appeal. The appellant had non-LSO assistance, and the court referenced "pseudo-legal arguments". This 13-paragraph ruling is worth reading to get a flavour for the court's unusual patience with this unrepresented appellant.
. Royal Bank of Canada v. Francoeur
In Royal Bank of Canada v. Francoeur (Ont CA, 2023) the Court of Appeal considered (and dismissed) an appeal from a proponent of what some call an 'organized pseudolegal commercial argument' (OPCA), and ordered full indemnity costs against them. The Alberta Law Society has published an article on the phenomenon: OPCA Litigants – The Phenomenon of Freemen on the Land::[1] This is an appeal from four summary judgments granted by the motion judge relating to claims by the respondent against the appellant on various mortgages, charges, lines of credit, and a credit card. The motion judge found that the appellant had not advanced any legally tenable defence to the respondent’s claims.
[2] On appeal, the appellant, in essence, repeats the same arguments he advanced before the motion judge. These arguments all revolve around his effort, as an individual, to separate himself from his legal status as a person, and thus submit that he is not governed by, or subject to, any of the laws of this country. In this case, the appellant says that he returned his birth certificate to the Department of Finance Canada and thus, in some fashion, transferred his legal responsibilities to His Majesty the King/The Crown in Right of Canada.
[3] These efforts by certain individuals are well-known to all courts. The individuals who engage in this conduct have been referred to in some previous decisions as Organized Pseudolegal Commercial Argument litigants – a label that apparently emanated from the decision in Meads v. Meads, 2012 ABQB 571, [2013] 3 W.W.R. 419. While they use different techniques, and operate under different names, the central theme is the same.
[4] We do not see it as helpful or appropriate to label individual litigants in this manner. It is sufficient to recognize that there is a common technique employed by these individuals by which they attempt to avoid their legal responsibilities. They attempt to do so by creating a fictional characterization of the facts and, through this deception, suggest that they do not bear legal responsibility for their actions. It is a technique that consistently fails, and which accomplishes little, other than to take up court time, increase costs, and delay the inevitable result.
[5] The motion judge was correct in his conclusion that there were no facts or legal defences offered by the appellant to the respondent’s claims. The summary judgments were properly granted. The appellant’s argument that there was no admissible evidence from the Bank in support of its claims cannot succeed. The Bank filed an affidavit from an employee who attested to the facts about the appellant’s indebtedness drawn from the records of the Bank and produced the documents respecting that indebtedness signed by the appellant. Those business records are admissible under s. 35 of the Evidence Act, R.S.O. 1990, c. E.23.
[6] The appeal is dismissed. The respondent is entitled to its costs of the appeal fixed in the amount of $9,7712.35, inclusive of disbursements and HST, on a full indemnity basis as provided for in the debt agreements.
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