B.C.’s Civil Resolution Tribunal has dismissed a claim by an HR consultant who sought $1,650 in payment from a First Nation community, finding there was no valid contract and no benefit received for the work performed.
In Gallis v. High Bar First Nation, 2025 BCCRT 400, the tribunal ruled that W.W.G., a human resources consultant, did not have an enforceable agreement with High Bar First Nation to perform a reverse evaluation or provide other HR advisory services.
At the heart of the dispute was whether a series of email exchanges and unsigned letters amounted to a binding contract for HR management work—including the development of performance review forms and other materials—that W.W.G. claimed to have completed in May and June 2023.
High Bar First Nation denied there was any finalized agreement or that it received any HR documents or deliverables from W.W.G.
“I find the parties did not have a meeting of the minds on all essential terms of the contract,” the tribunal wrote.
Proposal lacked clarity and signature
W.W.G. submitted a proposal to High Bar on May 4, 2023, offering to conduct a “reverse evaluation,” also referred to as a 360 review. He followed up with two letters of agreement on May 23: one covering general HR advice, and another for the 360 review.
The 360 review letter listed an hourly rate of $150, with an alternate project rate of $100 per hour. It also required an initial $2,500 instalment upon signing. However, the tribunal noted it was unclear whether the $2,500 was a deposit or a separate fee.
On May 31, a High Bar council member, identified as J.F., emailed W.W.G. instructing him to proceed with the review. W.W.G. responded by asking which position the evaluation was for, but it is unclear whether J.F. answered that question. Neither of the two letters of agreement were signed, and High Bar did not pay the requested instalment.
“It is not clear if High Bar agreed to [W.W.G.’s] $150 hourly rate or the reduced $100 hourly rate set out in the 360 review letter,” the tribunal stated.
Lack of deliverables and mutual understanding
On June 9, J.F. emailed W.W.G. requesting a summary of work completed to date and an estimate of hours required to finish the project. J.F. also noted that the agreement needed review by High Bar’s legal department before it could be signed.
After further correspondence, High Bar informed W.W.G. it would not be proceeding with the services. In response, W.W.G. submitted a log showing he had spent 16.5 hours between May 31 and June 9 developing evaluation forms, procedures, and related documentation. He issued an invoice for $1,650.
However, there was no evidence that the forms or materials were delivered to High Bar.
“High Bar says it never received any forms or documents,” the tribunal noted. “Mr. Gallis included in evidence copies of the forms that he worked on. But Mr. Gallis did not include any emails showing that he forwarded these forms to High Bar. Mr. Gallis said he would have provided the forms if High Bar paid the invoice.”
No quantum meruit award due to lack of benefit
The tribunal considered whether W.W.G. might still be entitled to payment under the legal principle of quantum meruit, which allows compensation for services provided when no contract exists, if the receiving party benefits.
But it found no evidence that High Bar gained any benefit from the consultant’s work.
“Entitlement to quantum meruit damages is based on the value of the benefit obtained by the benefitting party, not the loss to the deprived party,” the decision said. “I find that High Bar received no benefit from Mr. Gallis’ work.”
The tribunal dismissed the $1,650 claim and declined to award reimbursement of tribunal fees to W.W.G. under standard rules, since he was the unsuccessful party. No dispute-related expenses were claimed by either side.
For more information, see Gallis v. High Bar First Nation, 2025 BCCRT 400 (CanLII).
