By: Jennalee Steadman, Associate

A recent Alberta decision determined that, in certain circumstances, embellishing academic qualifications may be grounds for a just cause dismissal.

In Tudor v Accurate Screen Ltd, 2026 ABKB 237, the individual applied for and received a Vice President position. On their resume, they stated that they expected to receive a Master of Business Administration (MBA) degree later that year, when in reality the individual had not applied to any MBA programs, was not enrolled in any MBA courses, and had never taken any MBA coursework.

The Court reaffirmed the established framework for assessing just cause dismissals, which involves consideration of:

  1. The nature and extent of the misconduct;
  2. The surrounding circumstances, including factors such as the employee’s age, seniority, role and responsibilities, the nature of the business, and the level of trust placed in the employee; and
  3. Whether dismissal is a proportional response.

Applying this framework, the Court concluded that the misrepresentation was neither an innocent mistake nor a lapse in judgment. Rather, it was an intentional act of dishonesty that “goes to the very heart of one’s moral compass and ultimately their abilities.”

The Court emphasized that, as an executive-level employee, the individual was expected to demonstrate a high degree of honesty and trustworthiness, and that by misrepresenting their qualifications, they breached a fundamental component of the employment relationship.

Takeaways:

  • This decision highlights the nuanced and contextual nature of just cause determinations, specifically when assessing dishonesty in the recruitment process.
  • In this case, several factors supported a finding of just cause, including:
    • The intentional nature of the misrepresentation;
    • The individual’s failure to come clean when asked about their qualifications; and
    • The executive nature of the role, which carries an expectation of honesty and trustworthiness.