Executive Summary: Key Legal and Evidentiary Issues

• Central issue is whether the plaintiff unlawfully split one underlying claim into multiple small claims actions, contrary to article 538 C.p.c.
• All proceedings arise from a single factual matrix: the plaintiff’s destitution as administrator and vice-president of La Maison du Pharillon.
• Use of different defendants (board members, the organization, the CIUSSS, the executive director) to seek compensation for the same harm is treated as division of a single “créance.”
• Small claims jurisdiction is challenged because the true scope and value of the dispute exceed what may properly be brought via multiple small claims.
• Prior related small claims decisions involving the same events are relied on to show a common “ensemble contractuel” and a single claim.
• The court resolves the matter on procedural grounds and never reaches the substantive merits of the alleged wrongful destitution or Charter-based damages.

Facts of the dispute

The case stems from governance conflicts at La Maison du Pharillon, a Montreal organization whose board included the plaintiff, André Christian Reeves, as administrator and vice-president. Between late November 2020 and February 2021, Reeves was removed from his board position and progressively excluded from decisions, entries in the enterprise register, and invitations to annual general meetings.
Reeves claimed that on 2 December 2020, the board’s president, vice-president and treasurer validly adopted resolutions—under the organization’s by-laws—to destitute at least two directors and the executive director, Steeve Thomassin. In his view, those individuals could not thereafter act as lawful directors, making all subsequent meetings, resolutions and appointments invalid.
He alleged that despite being informed of these internal decisions and his objections, the Centre intégré universitaire de santé et de services sociaux du Centre-Sud-de-l’Île-de-Montréal (CIUSSS), which oversees and certifies the organization, ignored his correspondence and continued to deal only with the former executive director. Reeves invoked specific by-law clauses meant to guarantee that an administrator be informed of the allegations against him and be heard before an impartial decision is taken, arguing that these protections were disregarded.
He further accused the former executive director of mounting unfounded allegations to engineer his forced and illegal destitution and to influence both the board and the CIUSSS during emergency meetings, particularly on 3 December 2020 and 12 February 2021. As a result, he said, he was shut out of board decisions and effectively erased from the organization’s corporate records and assemblies in 2021–2022.

Claims and reliance on the Charter

In a demand letter dated 24 November 2023, Reeves asserted that the CIUSSS, as “contrôleur et valideur” of the organization’s governance, had endorsed illegal acts by ignoring the by-laws and the law. He characterized its conduct as a serious, intentional, bad-faith violation of his rights to dignity, moral integrity and honor under the Quebec Charter of human rights and freedoms, particularly article 49, and claimed both compensatory and punitive damages (12,000 dollars in compensatory damages and 3,000 dollars in punitive damages).
No insurance policy or commercial contract was in issue; the relevant “terms” were the organization’s internal regulations (by-laws) on destitution of directors, validity of meetings and resolutions, and the right to notice and a hearing. Reeves treated those provisions as binding governance rules that should have guided both La Maison du Pharillon and the CIUSSS in its oversight function.

Parallel small claims proceedings

On 30 November 2023, the same day he sued the CIUSSS, Reeves launched multiple small claims actions, each for 15,000 dollars in compensatory and punitive damages, against individual board members, La Maison du Pharillon itself, the former executive director, and other persons linked to the same events. Every claim was anchored in the same narrative: his wrongful destitution and the allegedly illegal governance process surrounding it.
On 29 May 2024, Judge Nathalie Drouin of the Cour du Québec (Small Claims Division) disposed of most of these parallel actions. Several were rejected as improper attempts to divide a single small claim under article 538 of the Code of Civil Procedure, because they targeted members of the board for decisions or statements connected to Reeves’s role. Others were dismissed for lack of jurisdiction or on the basis of res judicata.

Legal framework and the division of a single claim

In the present decision (Reeves c. CIUSSS, 2025 QCCQ 7641), Judge Eliana Marengo focused on article 538 C.p.c., which prohibits the division of a single “créance” into several small claims to fit within the simplified procedure. Quebec jurisprudence, including Chery c. Ly and Lajeunesse c. A.P.C.H.Q., confirms that the rule applies even where the defendants differ, as long as there is one underlying claim arising from a common set of facts or an “ensemble contractuel.”
The objective is to prevent litigants from artificially fragmenting a substantial dispute to stay in small claims court and to avoid the risk of contradictory judgments in multiple proceedings. Where such division occurs, there is simply no right of action for the split-off portion of the claim in small claims, and the judge must reject the action ex officio or on request, since the rule is of public order.

Court’s reasoning and outcome

Judge Marengo held that all of Reeves’s proceedings—including the one against the CIUSSS—rested on the same cause of action: the harm he alleges from his destitution as administrator and vice-president of La Maison du Pharillon and the surrounding governance events. The fact that he sued different people and entities did not change that he was seeking redress for one unique harm and one underlying “créance.”
By filing multiple small claims, each for 15,000 dollars and each based on the same factual matrix, Reeves had divided a single claim among several defendants, contrary to article 538 C.p.c. In line with the earlier decisions and the cited case law, the court concluded that no valid right of action existed in small claims for this divided claim and that the matter had to be resolved on procedural grounds without examining the substantive merits of the alleged illegal destitution or Charter violations.
The court therefore rejected Reeves’s action against the CIUSSS and did so “sans les frais de justice.” The CIUSSS is the successful party, and no compensatory or punitive damages were awarded to the plaintiff. The total monetary award in favor of the successful party is zero, and the decision does not fix any recoverable costs or other monetary amounts beyond confirming that no sums are ordered to be paid.