An Ontario court has ordered strict communication limits for a condominium unit owner after finding he engaged in workplace harassment against property management staff, highlighting employers’ obligations to protect workers from third-party abuse.
The Superior Court of Justice granted a compliance order against C.L. after Peel Condominium Corporation No. 96 applied under the Condominium Act to stop his harassing behaviour toward building management and staff. The case demonstrates how employers must take action when customers or clients create hostile work environments for their employees.
Pattern of harassment emerges
The dispute began in early 2023 when C.L. complained about a neighbour smoking on a balcony. After the condominium corporation addressed his complaint and later retracted a warning letter as part of a settlement, C.L. launched an escalating campaign of harassment against staff and management.
Over 10 months, C.L. sent at least 119 emails to the corporation’s managers, lawyers and agents, “occasionally several in one day, to demand information and immediate answers while threatening to complain to regulators if his demands were not met,” the court found.
Property administrator D.C., who worked 23 hours per week at the building, became a primary target of C.L.’s behaviour. The court noted that C.L. engaged in “keyboard bullying” by sending “harassing emails with derogatory comment, personal insults, and unfounded complaints.”
Formal workplace harassment complaint
On Sept. 29, 2023, D.C. filed a formal workplace harassment complaint with the condominium board. She alleged C.L. had “harassed her persistently for months by keyboard bullying her with emails containing derogatory comments, personal insults, unfounded complaints, and an implicit allegation of theft.”
The complaint stated that D.C. felt “stressed and threatened” by C.L.’s behaviour and that his conduct made her “feel unsafe.”
Employer’s legal obligations
The court emphasized that condominium corporations have legal duties under the Occupational Health and Safety Act to protect workers from workplace harassment. Section 32.0.07(1) requires employers to “investigate and protect its workers from workplace harassment.”
The Act defines workplace harassment as “engaging in a course of vexatious comment or conduct against a worker in a workplace, including virtually through the use of information and communications technology, that is known or ought reasonably to be known to be unwelcome.”
The court found the condominium corporation “had a statutory duty to protect its workers from workplace harassment” and “was required to take remedial action and responsibly brought its application under s. 134 of the Act to have [C.L.] refrain from engaging in uncivil or illegal behaviour.”
Escalating intimidation tactics
Beyond the email harassment, C.L. engaged in other disruptive behaviour that affected the workplace environment. He impersonated the building superintendent to instruct contractors to stop work, called for D.C.’s dismissal, and made unfounded allegations of theft against her.
C.L. also disrupted a townhall meeting by “loudly interrupting the meeting chair, stating that the chair was acting for [the corporation] and not unit owners, announcing that the chair was not welcome, demanding that the chair leave, and interrupting the chair and a director who tried to speak.”
The court noted that during a phone call with police, C.L. stated he intended to respond to the corporation by “drowning them with their own rules and regulations.”
Court orders strict limits
Finding that C.L.’s behaviour violated sections 117 and 119 of the Condominium Act, which prohibit conduct likely to cause injury or illness including psychological harm, the court imposed several restrictions:
- C.L. cannot “harass or intimidate [the corporation’s] management, board, or staff, or make personalized attacks about their job security or tenure”
- His written communications are limited to two emails per month to a designated address
- He cannot contact third-party contractors working for the building
- Exceptions apply only for safety emergencies or property damage
Employer response praised
The court commended the condominium corporation’s handling of the situation, finding it “acted reasonably and appropriately in bringing this application to address [C.L.’s] conduct so that he discontinues engaging in antisocial or degrading communications or behaviour.”
The ruling noted the corporation took “appropriate steps to discharge its statutory obligation to address and remedy his inappropriate behaviour.”
Broader workplace implications
While this case involved a residential property management setting, it illustrates principles that apply across workplaces where employees interact with customers, clients or residents. Employers have clear obligations under occupational health and safety legislation to protect workers from harassment, regardless of whether it comes from colleagues or third parties.
The case shows that employers may need to seek legal remedies when internal measures prove insufficient to protect staff from persistent third-party harassment that creates an unsafe work environment.
For more information, see Peel Condominium Corporation No. 96 v. Leuzzi, 2025 ONSC 3492 (CanLII).
