Lacking The Right Stuff, Sylvio Langevin finds his Galaxy Quest over just as he launched his Mission to Mars. With the prospect of A New Hope subject to leave of the Men (and women) in Black, perhaps he should seek Serenity, abandon his quest and make The Voyage Home.
In a Langevin (Re), a decision released last week but published on CanLII just yesterday, the Quebec Superior Court declared Langevin a “quarrelsome litigant” and barred him from bringing any further action without leave.
That order alone, though infrequently issued and a factually and legally interesting part of the judgment, was not the reason the decision became – in a matter of hours – the most consulted case on CanLII for 2012. No, the reason for the instant notoriety was the pleadings filed by Langevin that prompted the Court's action.
In a nutshell, Langevin claimed ownership of Earth.
And Mercury, Venus, Jupiter (and its four largest moons), Saturn and Uranus as well.
Recognizing a gap in his request, he sought at the hearing, to amend his pleading to include a claim for Neptune, Pluto and all the space in between each planet across the galaxy.
Finally, he invited the Court to take the opportunity to overturn a 19 December 2011 ruling wherein his prior claims of ownership over Mars and the moon were found to lack legal basis and summarily rejected.
Despite being unopposed (Langevin submitted that the only suitable respondent, God, being incorporeal, was not “invitable” as a respondent), the Court denied the appeal and dismissed all the new claims.
Finally, as these were but the latest in a long line of “vexatious or quarrelsome” applications (to borrow from the language of Quebec's Code of Civil Procedure), the Court found no difficulty in barring Langevin from instituting further proceedings.
For me to continue to summarize the case would not do it justice so I invite others to share their impressions and analysis in the comments section below.
Captivating content aside, how did word of the case spread?
Langevin (Re) had been racking up page views on CanLII all day. One thousand by 2:00 p.m., nearly three thousand by 4:00 p.m. It ended the day with a remarkable 9,007 page views! In 2011, that would have been sufficient to make it the 4th most consulted case of the year.
Last night after dinner, I turned to the task of preparing this article, convinced that in addition to discussing the highlights of M. Langevin's efforts to secure dominion over our solar system, I would also cast a light on the role Twitter played in spreading awareness of the decision. Earlier in the week, I was able to trace nearly one third of Richard v. Time Inc. 2012 SCC 8 (CanLII) page views to twitter links, so surely it had to be a factor here.
Making use of online toys Revisit and Screencast-o-matic, I created this 2 minute video demonstrating how 6 hours worth of tweets (27), retweets (12) and mentions (9) containing links to the decision contributed to the public's enormous interest. [Note: 10 seconds of the video gives you the idea]
But when I looked at CanLII's internal referrer site and page view stats, the facts didn't bear out the theory. Despite attaining “tweet” levels between 1:00 p.m. and 7:00 p.m. generally only seen for the hottest Supreme Court of Canada decisions, actual page views of the decision were several orders of magnitudes higher than growth in referrals from twitter would suggest.
Then I remembered Hubert David's piece in Slaw from couple months ago discussing Educaloi's social media experience. Hubert pointed out that Twitter usage in Quebec is well below national levels and that Facebook reigns supreme. Sure enough, that was the key.
In all of January 2012, there were 2,851 CanLII page views attributable to Facebook page referrals. Between 7:00 p.m. and 11:00 p.m. last night, 2,201 CanLII page views were derived from people clicking links from within Facebook. Over that same time period total views of Langevin increased by 2,691. Coincidence?
Unlikely. Facebook was a major, if not the single most important factor in spreading awareness of the decision.
So in the final analysis Langevin (Re) taught us the following:
- You can't claim ownership of the solar system.
- At the very least, should you attempt to do so, try a common law jurisdiction where you might be able to base your case on equity. Alberta, perhaps? Try the Judicature Act, ss. 8 or 15.
- If you poke a Court enough times, they will poke back.
- Social media in general and Facebook in particular can play a significant role in spreading legal information and awareness.