In Open Defiance: Unconstitutional prayers at municipal councils in Manitoba

March 28, 2022

In its 2015 decision in Mouvement laïque québécois v. Saguenay (City), the Supreme Court of Canada found the practice of opening a municipal council meeting with a prayer to be a violation the state’s duty of religious neutrality. Despite this ruling, several municipalities across Canada have continued the practice. This study examines the prevalence of prayers at municipal council meetings in Manitoba since the Saguenay decision. After investigating the practices at regular and inaugural meetings of every municipality in Manitoba, we found six municipalities opened their 2018 inaugural council meetings with a prayer and three continue to open regular meetings with a prayer. During the writing of the report, West St Paul agreed to discontinue prayers at its regular council meetings.

Municipalities with prayers in their council meetings

After reviewing the municipal website for all 101 municipalities in Manitoba, from which we were able to collect information, we found the following municipalities included prayers in their inaugural and regular council meetings. 'Inaugural meetings' were the first meeting held after the most recent local elections held in 2018. These meetings are often ceremonial in nature and include the swearing in of newly elected officials. The following municipalities are sorted by population.

Manitoba municipalities with prayer at inaugural and regular council meetings.
Municipality Inaugural Regular
West St Paul*
* West St Paul discontinued prayers at regular council meetings in 2021.

Municipal responses

Members of the BCHA research team wrote to every municipality that was found to have included prayer in their inaugural or regular meetings, specifically asking that future meetings be made compliant with Saguenay.

The Rural Municipality of Rhineland replied that councillors were no longer required to provide a prayer but "“sometimes councillors read Devotions/Short Stories/Prayers or fables (Any domination or faith) as part of the opening or sometimes comment of recent events or news in our region. Other councillors use the opening to recognize outstanding achievement of community members/organizations or sporting teams.”

The Rural Municipality of West St Paul agreed and replaced its invocation with "opening remarks" from the mayor in mid-February 2021.

The City of Winnipeg initially ignored our inquiry. After we requested a legal review that had been completed under the province's freedom of information law, the City eventually provided us with a completely redacted document.

Read the report


The Saguenay Project

This is the second in a series of reports that explore the compliance of municipalities with the Saguenay decision. The BC Humanist Association research team is compiling reports on compliance with Saguenay for Canadian provinces and territories. Each will follow a similar model and method but will explore issues specific to the practice in those jurisdictions. The first report found that 23 municipalities in British Columbia opened their 2018 inaugural meetings with prayers. All these prayers were delivered by members of Christian clergy, 73.9% of whom were men. No regular council meetings were found to open with prayer in this province. In compiling these reports, we aim to encourage municipalities into compliance with Saguenay, making their council meetings more accessible and welcoming to people of all beliefs.

Read the first report in the series, The Duty of Neutrality Beyond Saguenay: Unconstitutional prayers at municipal councils in British Columbia.

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