Executive Summary: Key Legal and Evidentiary Issues

• Status and constraints of a declared vexatious litigant (plaideur quérulent) seeking prior authorization to institute multiple new civil proceedings.
• Adequacy and intelligibility of the proposed pleadings, many of which were largely incomprehensible and failed to allege clear, specific facts meeting the minimal pleading standard under art. 544 C.p.c.
• Impact of prior final criminal proceedings, including a jury conviction for intimidation of a justice-system participant and the Court of Appeal’s rejection of related appeals, on the plausibility of later civil claims alleging false accusations and perjury.
• Application of prescription periods under the Civil Code of Québec to bar claims based on events occurring several years earlier.
• Operation of judicial immunity protecting a judge from civil liability for acts performed in the exercise of judicial functions.
• Repetition of baseless allegations of racism, false testimony and conspiracy against numerous actors in the justice system, without supporting evidence, as a factor in denying authorization.

Background and prior proceedings

Anthony Clark is an individual who has been in prolonged conflict with various actors in the Quebec justice system, both in criminal and civil contexts. In 2020, the Court of Québec, per Thibodeau J., declared him a vexatious litigant (plaideur quérulent). That status means he can no longer freely introduce new proceedings: under the Code of Civil Procedure and the Court of Québec’s regulation, he must first obtain authorization from the Chief Judge or a delegate before filing any new claim or significant procedural act. The purpose of this regime is not to extinguish his right of access to the courts but to subject his initiatives to a filtering mechanism designed to restrain abusive, repetitive or plainly groundless litigation.

Parallel to his civil efforts, Mr. Clark was prosecuted criminally. In November 2023, a jury presided over by Justice André Vincent of the Superior Court found him guilty of attempting to intimidate a person associated with the justice system and of uttering threats to cause death or bodily harm, both arising out of a telephone call. In December 2023, Justice Vincent conditionally stayed proceedings on the threats count but imposed a six-month conditional sentence in the community and two years’ probation on the intimidation count. Mr. Clark sought to appeal both the conviction and sentence. In an October 2024 decision, the Court of Appeal summarized his appellate materials as largely incoherent and unintelligible, noting that his arguments consisted of a stream of disorganized complaints, including sweeping and extreme accusations of racism against several participants, especially the Crown prosecutor, and other individuals involved in the criminal process. The Court held that what little could be extracted from the submissions did not disclose any viable ground of appeal and refused authorization, thereby leaving the conviction and sentence intact.

Facts and procedural history of the present case

The December 2025 judgment in Clark c. Groleau is not itself a damages trial or a criminal proceeding. Rather, it arises because Mr. Clark, as a declared vexatious litigant, sought prior authorization from the Court of Québec to launch 14 separate civil actions against a broad range of defendants. The applications were heard and decided by Associate Chief Judge Martin Tétreault, acting under article 68 paragraph 3 of the Code of Civil Procedure as the delegate of the Chief Judge.

Mr. Clark targeted a wide spectrum of individuals and institutions: his former opposing party Me Lucie Groleau, Judge Luc Hervé Thibodeau, the Government of Québec, court clerks, municipal officials, multiple police officers, a probation officer, an alleged health professional, lawyers involved in various files, and court staff including a person associated with the Court of Appeal. For most of these proposed actions, he claimed damages in the range of CAD 14,900–15,000 per defendant. The claims were framed broadly as civil suits invoking such notions as false arrest, illegal search, theft of personal property and firearms, fraud, extortion, racist conduct, ethical violations, false testimony, reputation damage, and obstruction of his access to transcripts or appellate remedies.

Each proposed action was accompanied by a very short “demande” (statement of claim) and, in most cases, by a form letter styled as a “mise en demeure” (demand letter). The demand letters were largely boilerplate, often differing only in names and dates, and almost all referred back to alleged false testimony given during the November 2023 criminal jury trial and to supposed racist behavior or conspiracies against Mr. Clark. Many documents also contained handwritten annotations on previous judgments, for example marking the 2020 decision declaring him vexatious as “illegal, false, racist.”

Beyond the present authorization applications, the judgment notes that Mr. Clark has previously attempted to file numerous similar applications, many of which were never even adjudicated because they failed to comply with basic procedural requirements, such as attaching the original vexatious-litigant order.

Legal framework applied by the court

Associate Chief Judge Tétreault began by emphasizing the legal constraints that apply once a person is declared a vexatious litigant. Under article 55 of the Code of Civil Procedure and the Court of Québec’s procedural regulation, such a litigant must file a written request for authorization, attach the order declaring him vexatious, and include the projected pleading. Crucially, because the litigant’s initiatives are presumed vexatious, he bears the burden of showing that the proposed proceeding, on its face, raises a serious, arguable claim that is not abusive or devoid of merit. The authorization stage is thus a screening process: the judge does not adjudicate the merits but must decline authorization where the claim is incomprehensible, frivolous, prescribed, barred by legal immunities, or fails to allege an actionable fault even if all facts were assumed to be true.

The court also recalled that this was not Mr. Clark’s first attempt to revisit old grievances against many of the same targets. Prior decisions, including the judgment declaring him vexatious and the Court of Appeal’s 2024 decision, had already documented a pattern: repeated accusations of racism and perjury against judges, prosecutors, police officers, court staff and others, almost always unsupported by clear factual particulars and often accompanied by highly inflammatory language. The present set of applications followed the same pattern.

Analysis of specific proposed actions

The judgment then reviewed each of the 14 proposed civil actions in turn, assessing whether any could meet the threshold for authorization.

The first proposed claim, against Me Lucie Groleau, Judge Thibodeau and the Government of Québec, sought to challenge the 2020 judgment by Thibodeau J. and his conduct in court, while also alleging racist conduct by both the lawyer and the judge in earlier small-claims proceedings. The judge held that any such claim would in any event be prescribed, as the hearing took place in February 2020 and the judgment was rendered in June 2020, exceeding the three-year prescription period for extra-contractual liability under the Civil Code of Québec. In addition, a sitting judge enjoys judicial immunity for decisions rendered in the exercise of judicial functions, barring any civil suit on that basis.

A second set of claims, against court clerks Chantal Page, Katy Rodrigue and Sabrina Lucie, blamed them for allegedly discarding exculpatory material that Mr. Clark says he filed before he was declared vexatious, thereby depriving any judge of the opportunity to see his “proof of innocence.” The court noted that even taking his account at face value, the acts complained of pre-dated the 2020 vexatious-litigant judgment and were therefore prescribed. The judge also considered that Mr. Clark’s own supporting letter from another judge merely stated that Judge Thibodeau could not correct the alleged error, not that the clerks had committed a civil fault.

Several other proposed actions, against various municipal actors and lawyers, were deemed unintelligible. For example, the request targeting Me Annie Thivierge and Mayor Andrée Bouchard appeared to relate to a dispute over towing expenses of CAD 1,142 and alleged failures to respect a prior court judgment. The judge found the narrative incomprehensible and insufficient to identify any specific fault that could ground liability.

A group of proposed actions against police officers followed a similar pattern. Against Dany Tremblay, Tom Bradley, Andrée Anne Laramée, Caroline Gerbeau, Marie Josée Moreau, Francis Jackson, Daniel Lalande, Isabelle Beaupré and Michel Hébert, Mr. Clark variously alleged false arrests, illegal searches, failure to act on theft complaints, theft of firearms, and racist behavior. In nearly all of these, the attached demand letters focused instead on supposed lies under oath during the November 2023 criminal trial and on generalized accusations of racism and conspiracy. The judge pointed out that these allegations closely mirrored those already documented in the earlier vexatious-litigant judgment and that they did not meet the minimal requirement in article 544 C.p.c. to set out the facts on which the claim is based in a clear and coherent manner. In some instances, even if one accepted the described events—such as being telephoned to come in for fingerprinting in connection with another suspect—there would still be no actionable civil fault by the officer.

Additional proposed actions were directed at lawyers involved in Mr. Clark’s prior criminal proceedings or private prosecutions, such as Me Jean Caron and Me Magalie Provost. He accused them of fraud, fabrication of documents and communicating improperly with witnesses, or of having falsely told judges that his status as a vexatious litigant entirely prevented him from defending himself. The court again found these narratives to be difficult to follow and devoid of the kind of concrete, specific factual allegations that could support a civil claim. They were broad accusations of serious misconduct, but presented without necessary detail, coherence or supporting context.

Mr. Clark also sought to sue a person he described as a medical professional, Juliette (or Julie) Germain, claiming that she lied in court, purported to be a physician, neurologist or psychologist when the medical college had supposedly said she was not, and thereby damaged his reputation through “assassination de character.” Here too, beyond Mr. Clark’s flat assertions, no clear factual foundation was offered. The judge held that the proposed claim failed to meet the minimal pleading standards and could not reasonably be expected to succeed.

Finally, a proposed action against a court-related staff member, Catherine Lemire, alleged extortion, fraud, ethics violations and racism, based on a claim that she demanded a CAD 4,000 cash “deposit” to obtain transcripts and allegedly told clerks to give nothing to “this [racial slur].” No supporting documents were produced. The judge considered these serious allegations but noted that they were of the same nature as the many unsubstantiated accusations of racism that had already featured heavily in Mr. Clark’s earlier litigation and had been canvassed in the Thibodeau judgment and in the Court of Appeal decision. Without coherent particulars or corroboration, the proposed action had no realistic prospect of success.

In a final proposed claim against Carolina (Caroline) Gerbeau, Mr. Clark did not even articulate any factual basis in the demand itself. The absence of any alleged fault made it impossible to discern a viable cause of action.

Overall assessment of evidence and pleading sufficiency

Across all 14 proposed proceedings, the court discerned a consistent pattern. The documents were, in many respects, “difficilement compréhensibles,” mixing French and English, fragmentary references to various hearings and judgments, and heavy reliance on generalized accusations of racism, perjury and criminality. Despite the seriousness of the terms used, Mr. Clark rarely set out a coherent sequence of facts—who did what, when, in what context, and how that conduct caused him compensable harm. Where dates or prior proceedings could be identified, many of the events were several years old and therefore prescribed under the three-year limitation for civil liability.

The court was also influenced by the existing criminal record and appellate determinations. The Court of Appeal had already described Mr. Clark’s appellate submissions as essentially an incoherent diatribe and had refused leave to appeal, thereby confirming the guilty verdict and sentence in the intimidation case. That context undercut his repeated civil claims that he had been the victim of false accusations and fabricated evidence in that same criminal file.

From an evidentiary perspective, the judge was not weighing conflicting evidence on a developed record, because the case had not reached trial. Instead, he had to decide whether, even on their face, the proposed pleadings and attached letters disclosed an arguable case. He concluded they did not: the combination of unintelligible text, lack of factual detail, apparent prescription and the existence of immunities (such as judicial immunity) rendered each proposed suit devoid of any reasonable chance of success.

Outcome and implications

Having reviewed each of the 14 proposed civil actions, Associate Chief Judge Tétreault refused authorization for all of them. He formally rejected Mr. Clark’s applications to institute proceedings against: Me Lucie Groleau, Judge Luc Hervé Thibodeau and the Government of Québec; the three court clerks; Me Annie Thivierge and Mayor Andrée Bouchard; the various police officers and probation-related actors; the lawyers Me Caron and Me Provost; the alleged medical professional Juliette Germain; the court-related staff member Catherine Lemire; and Caroline Gerbeau. The judgment also reiterated a prior directive prohibiting Mr. Clark from contacting the Associate Chief Judge’s assistant or any person within the Court’s administration except for the sole purpose of filing a procedurally compliant authorization request under the applicable regulation.

In terms of financial consequences, the court did not award any damages because none of the proposed actions was authorized to proceed, and therefore no merits decision or assessment of liability took place. The judge ordered that the judgment be placed on the court record and specified that all was done “sans frais de justice.” As a result, the successful parties—the would-be defendants to these 14 proposed actions—obtained complete relief at this preliminary stage, with no monetary award in Mr. Clark’s favour and no costs ordered against them, so the total amount ordered in favour of the successful parties was zero.