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Running head: Métis Nation

Name:

Course:

Tutor:

March 7th, 2011

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INTRODUCTION

Background of Powley case

On the dawn of October 22, 1993, a father and his son (Steve Powley and Roddy), went

away hunting. They set out to the north of Sault Ste. Marie where they were inherent in, and at

around 9 a.m., they fired and killed a male moose close to Old Goulais Bay Road1. Following the

killing of bull moose near Old Goulais Bay Road, the two carried it to their home in Sault Ste.

Marie. None of them had a legitimate Outdoor Card, a legal hunting warrant to hound moose, or

a legalization tag given by the Ministry of Natural Resources, Ontario (Bolaria & Hier 9). As a

replacement for these credentials, Steve Powley attached a manually written tag to animal’s ear.

As mandated by the hunting policies, the tag specified the day, time, and site of the kill. It

affirmed that the moose was to supply meat for the cold season. Steve Powley signed the label,

and inscribed his Ontario Métis and Aboriginal Association membership number on it2.

Later on that day, two conservation executives went to the Powleys’ home and the

Powleys informed them that they had shot the moose. After one week, the Powleys were indicted

with illegally hunting moose and intentionally owning game hunted in infringement of the Game

and Fish Act (Isaac 23). However, they pleaded not guilty in the court hearing. With the

technique of providing absolute political and financial backing all through, the Ontario’s Métis

State resolved to employ the alleges in opposition to the Powleys as a experiment case. On

behalf of the entire Métis Nation, the MNC (Métis National Council) interceded in favor of the

case and offered financial support at both the Court of Appeal in Ontario as well as the Supreme

Court of Canada (Belcourt 65).

1
Olive P. Dickason. & David, T. McNab. Canada's First Nations: A History of Founding Peoples
from Earliest Times. Oxford, Oxford University Press, 2008. Pp 13-397
2
Herb, Belcourt. Walking in the Woods: A Métis Journey. Calgary. Brindle and Glass, 2006. pp 2-184
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In 1998, the court judge declared that the accused (Powleys) had a Métis dispensation to

hound as safeguarded by the section 35 of the 1982 Constitution Act. The arguments were

discharged, though the Crown petitioned the verdict. The Crown’s appeal was later dismissed in

January 2000, by the Ontario Superior Court of Justice who validated the trial judgment.

Subsequently, the Crown further petitioned the verdict to the Ontario Court of Appeal (Dickason

& McNab 46). The Court of Appeal generally supported the previous decisions and

authenticated that the Powleys had an aboriginal liberty to hunt as Métis on February 23, 2001.

The Crown afterward appealed to the Supreme Court of Canada.

The decision of the Supreme Court of Canada

On September 19, 2003, the Supreme Court of Canada, in an undisputed verdict, alleged

that the Powleys, as associates of the Sault Ste Marie Métis community, can implement a Métis

right to hunt as protected by section 35 (Bolaria & Hier 36). The Court alleged that the Métis

were incorporated as one of the ‘Aboriginal peoples of Canada’ in section 35; to distinguish

them, to value diverse Métis cultures, and to improve their continued existence. Particularly, the

Court embarked on the test for formulating Métis harvesting rights defended by section 35 of the

Constitution Act, 1982 (Isaac 11). The Court applied this test to the Sault Ste Marie Métis

society and to the Powleys and discovered that the Powleys were implementing the Sault Ste.

Marie Métis community’s constitutionally protected right to hunt3.

The court implied that that did not mean however, that the case was restricted in its

relevance only to the Sault Ste Marie Métis society. The test would henceforth apply to Métis

communities all over the Métis Nation Homeland. The Court as well talked about the pressing

call for developing a more precise method of recognizing Métis rights-holders (Belcourt 74). In

3
Singh, Bolaria. B. & Sean, Hier. Race and Racism in 21st-century Canada: Continuity, Complexity, and
Change. Washington, DC. Broadview Press, 2007. pp 23-307
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response to government asserts regarding Métis identification issues, the Court assumed that this

subject was not invincible and that the complexity ought not to be overstated so as to overcome

Métis claims.

LITERATURE REVIEW

Immediate significance of the Powley case

Prior to this judgment being passed on, Métis people were deprived of a patent

Aboriginal right to hunt (Bolaria & Hier 51). While the Constitution under section 35 protected

and avowed the Métis rights, definite rights that branched from that sector lingered imprecise.

The Powleys confronted the ‘existing rights’ phrase by shooting a moose devoid of Provincial

permits. They satisfied that harvesting was a presented right of the Métis and that harvesting

meat for the winter was constitutionally protected (Dickason & McNab 94). This case signified

the first major difference of opinion to these Section 35 rights for the Métis. The rights

confirmed that;

(1) The present indigenous and contract rights of the native peoples of Canada are hence

documented and avowed.

(2) In this Act, native citizens of Canada consist of the Indian, Inuit and Métis individuals of

Canada (Belcourt 26).

Critique of the decision of the supreme court; Identifying Métis Rights Holders

The prospective general impact of the Supreme Court of Canada (SCC) verdict in the

Powley case on the Aboriginal rights of Métis community is evidently colossal. Ironically,

though, it is exceedingly complex to determine the exact nature, or yet the degree of that impact

on an individual Métis harvester who wishes to implement the right that the pronouncement so
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perceptibly acknowledges. The Supreme Court emphasized that Aboriginal rights are communal,

based in the survival of a historic and a contemporary community. However, the ‘communal’

character of Aboriginal rights is well founded in other SCC decisions although persistence that

the community be both ‘historic and contemporary’ to ascertain basis for exercise of a right may

be challenging for some Métis (Belcourt 59).

The final verdict of Canada’s Supreme Court in the 2004 Powley case signified the

foremost occasion the Supreme Court has contemplated on the upshot of Métis Aboriginal rights

preserved in specific section of the 1982 Constitution Act. The pronouncement elucidated the

constitutionally preserved rights for the accused; nevertheless, the verdict left a great number of

queries unrequited for Métis people in additional provinces of Canada. Despite the fact that the

court ruled in favor of the Powleys, it did not create an all-inclusive explanation of Métis for all

rationales (Bolaria & Hier 67). The Court defined the fundamental approaches to recognize

Métis rights-holders. The Court acknowledged three extensive aspects: self-identification,

ancestral connection to the historic Métis community, and community acceptance4.

1. Self-identification

The individual is required to self-identify as an affiliate of a Métis community. It is not

sufficient to self-classify as Métis, that recognition should have a constant correlation to a

historic Métis community (Belcourt 31).

2. Ancestral Connection

Though there is little or no blood quantum required, the Métis rights holders should have

some evidence of an ancestral correlation to the historic Métis community whose

communal rights they are implementing (Dickason & McNab 49). The Court said the

4
Thomas, Isaac. University of Saskatchewan. Métis rights. Michigan. Native Law Centre Native Law
Centre, University of Saskatchewan, 2008
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ancestral connection is by birth, adoption or other means (Isaac 46). ‘Additional modes’

of connection to the historic Métis community did not come up with the Powleys and will

have to be determined in another case.

3. Community Acceptance

It stated that there should be evidence of approval by the contemporary Métis community

(Dickason & McNab 117). Association in a Métis political organization may be pertinent

although the membership necessities of the organization and its function in the Métis

community should as well be put into verification. The proof has to be impartially

confirmable. That means that there must be documented proof and a fair process for

community acceptance. The Court alleged that the center of community approval is as

regards to precedent and constant contribution in a mutual culture and in the ways of life

and traditions that disclose a Métis community’s individuality (Isaac 92).

Additional proof might consist of involvement in community actions and authentication

from other community affiliates regarding a person’s association to the community and its

customs. There must be verification of a firm attachment of past and current shared

recognition between the individual and the other associates of the Métis community. This

particular community acceptance requirement implies that in order to claim section 35

rights, it is not sufficient to verify a progeny relationship to a historic Métis community and

subsequently join a Métis organization (Belcourt 86). One is obliged to have a past and

continuing connection to the Métis community.

The term Métis, in the Constitution Act of 1982 section 35, does not include all persons

with mixed Indian and European traditions; The Decision does not properly describe the word
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Métis, however, it does position some limiting barriers around it (Bolaria & Hier 115). This

section affirms that mixed Indian and European birthright, does not make an individual eligible

as a Métis in section 35 of the Constitution Act 1982. It actually rules out mixed heritage of

non-European races or nationalities, Inuit or Indians for instance the various Indian/Black

Métis of the fur trade period and their lineage (Dickason & McNab 37). It possible also

eliminates the Indian/Asian Métis that surfaced following construction of the initial Canadian

railways.

The court defined a Métis community as a group of Métis with a distinctive shared

identity, residing together in the same geographical locale and sharing a common lifestyle

(Isaac, 68). This verdict defines ‘Métis community’ for the intentions of this judgment. It is

possibly extensive sufficient to envelop majority of historical Métis circumstances.

Nevertheless, it is inaccurate enough, to have a frustration effect for governments who wish to

demarcate the execution of Métis Powley harvesting by barely defining the terms distinctive,

collective, and common lifestyle.

Establishing a Métis Harvesting Right - The Powley Test

In 1982, subsequent to generations of struggling for equality, the present Aboriginal as

well as Treaty civil rights of Canada’s Aboriginal peoples acquired constitutional protection

(Isaac 33). The Constitution Act of 1982 in Section 35 made it clear that the present native and

treaty rights of the native communities of Canada are thus documented and acknowledged. It

also stated that in this Act, ‘aboriginal peoples of Canada’ consists of the Inuit, Indian and Métis

communities of Canada (Belcourt 87). For all Aboriginal peoples in Canada, this constitutional

defense was a conquest. For the Métis Nation, the clear addition of the Métis in section 35 was

realized as a new commencement following more than a century of denial, evasion and disregard
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by the Canadian government. Still in the legislative body of Canada, section 35 was expressed as

a ‘political division’ as well as a defining moment for the position of indigenous citizens in

Canada (Bolaria & Hier 123).

Unluckily, proper identification of the Métis under this constitutional protection lingered

principally vacant. For a moment, governments in Canada assumed the condition that Métis had

no present Aboriginal rights defended by s. 35 and declined to conform the Métis people

regarding their rights. In return to these persistent government situations, the Métis Nation began

its hunt for justice in the early 1990’s, by defending its civilians along with their rights in the

courts, forcing continuation into the legitimate declaration made in 1982 (Dickason & McNab

67).

Though not explicitly congealed by the court, through the Métis Aboriginal civil liberties

for the entire Métis natives in Canada, many significant legal doctrines were built up and put into

operation to offer direction for potential cases on Métis rights in the future (Belcourt 113). The

Supreme Court stated that the proper technique to characterize Métis rights in section 35 is to

adjust the test applied to characterize the Aboriginal rights of Indians (the Van der Peet test)

(Isaac 48).This customized Métis test came to be branded as the Powley test. The test is

explained in ten segments:

1. Characterization of the civil rights

Disposition of the Right safeguarded

As defined before, Aboriginal rights are rights held by aboriginal populace, not on the

groundwork of legislation, treaty, or Crown grant, but by basis of the actuality that aboriginal

peoples were previously sovereign, autonomous bodies in ownership of greater part of the lands

at the present making up Canada (Dickason & McNab 13). It is crucial to understand that
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section 35 of the bill is subservient to preserving practices that were in olden times momentous

aspects of typical Métis communities and that keep on to be fundamental to the basics of the

Aboriginal background in the recent day. In Van der Peet the judicial system instituted that in

line with section 35 of the bill which declared that to facilitate one to an aboriginal liberty; a

doing should be an aspect of a practice, standard or habit essential to the typical culture of the

indigenous inhabitants demanding the right (Belcourt 28).

All facets that are popular in majority of communities are not included in the implication

of the term distinctive. Nonetheless, it does not necessitate uniqueness. The privileges being

requested should abide by a contextual as well as site -particular component. A relative and place

particulate assert for instance, would contain the grounds for hunting and the expanse in which

the pursuing is undertaken, whilst claiming a constitutionally preserved right to hunt for food

(Bolaria & Hier 116). For a harvesting right, the term characterization implies the eventual

appliance of the harvest. Is it for foodstuff, barter or commercial reasons? The Court stated that

the Métis consent to hunt is not restricted to moose simply since that is what the Powleys were

hounding (Dickason & McNab 19). Métis are not obliged to discretely attest a right to hound

every species of wildlife or fish they count on.

The right to hound is not species-particulate. The Métis right to hunt is a universal right

to hound for provisions in the conventional hunting soils of the Métis community. To the Métis

community, the presented case law holds the insinuation that if an Aboriginal group of people

betrothed in trade past that which is secondary to mutual and customary activities at the

correlated historical time. That deed can position the persistence of a modern commercial

indigenous privileges or as a minimum, a right to hound for a rational existing, even though this

practice is now considerably condensed by legislation (Isaac 46).

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Contextual

When validating the essence of the civil liberties being claimed, it is vital not to widen or

constrict the right. It is as well vital to realize that the judicial system has recognized that native

civil rights can modify and advance sooner or later (Bolaria & Hier 89). For instance, a

constitutionally defended Aboriginal freedom to hunt consists of the acceptance of using

handguns in lieu of traditional techniques. It is necessary to demonstrate the manner in which the

privilege is a fundamental element of the culture and crucial to the mutual identity of the

population.

Site-definite

A Métis Aboriginal rights petitioner ought to ascertain their relationship to a particular Métis

community with some scope of permanence and constancy (Isaac 43). This can be attained by

presenting proof of mutual customs, ethnicity and shared identity in addition to demographic

verification.

2. Recognition of the historic rights bearing community

Métis Community

A historic Métis community was a faction of Métis with a distinguishing shared identity,

who resided jointly in the same soils and shared a universal lifestyle (Belcourt 18). The

Supreme Court seized the prospect to broaden on what is eligible as a Métis community

consistent with the continuity characteristic of the designation (Isaac 66). The court approved

proficient evidence offered at the hearing that a Métis population may turn out to be an ‘invisible

entity’ in the common population and yet accomplish the permanence constituent of the

designation (Isaac 67). In a case when a population of associated families and persons live

somewhere else prior to reverting to their home roots community, the ‘imperceptible’ group of
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people will still be eligible. The historic Métis society ought to be illustrated to have lived as an

exclusive Métis community before the instance when Europeans successfully set up political and

legal power in a certain area.

3. Identification of the contemporary rights bearing community

Métis community recognition calls for two things. Initially, the community should self-

recognize as a Métis community (Dickason & McNab 121). Subsequent, there should be

evidence that the modern Métis community is an extension of the preceding Métis community

(Bolaria & Hier 217). To be calculated mutual privileges or civil rights collective by the Métis

community, the right should be founded in an olden times and contemporary community and an

area applicable, on account of the Métis individuals ancestrally founded connection in the in

progress population (Belcourt 54). The permanence trait of the society concentrates on the

observances of the people, instead of the society itself.

4. Substantiation of membership in the contemporary Métis community

There should be an impartially provable procedure to recognize associates of the

community. This denotes a process that is founded on rational values and historical actuality that

can be accepted. The Court did not define an inclusive description of Métis. On the other hand,

Belcourt (87) affirmed that it embarked three mechanisms to direct the recognition of Métis

rights-holders like named above (self-recognition, familial attachment to the historic Métis

community, and community acceptance). Intricacy in verifying membership in the Métis group

of people does not indicate that Métis people do not have rights.

According to Dickason & McNab (126), the Supreme Court, in the undisputed

conclusion, took up the MNC state characterization as the initial step to agree on whom

legitimately meets the criteria as a Métis privileges proprietor under sector thirty five of the
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charter. The court justified its employment of the MNC designation as one that takes in to

account significant elements for future characterization even if it isn’t in itself an all-

encompassing ordeal (Isaac 89). The judicial system also emphasized that modern customary

of self-acknowledgment is not approved. Otherwise stated, only those persons that have partaken

in a Métis community and observed Métis traditions, practices as well as customs for a length of

time will be absorbed in the designation. This was incorporated to put off persons from self-

categorizing as a Métis individual exclusively for the intention of obtaining constitutional rights

for example the dispensation to hound.

The foundation of community appreciation is past and continuing membership in a

communal ethnicity, in the mores and ways of life that make up Métis community individuality

(Belcourt 30). The acknowledgments of other Métis community associates regarding the

petitioner’s participation and responsibility in the Métis population can be handed out in court

although will almost certainly not be satisfactory attestation of membership. Therefore, all proof

presented in the court must be concrete and convincing.

5. Invention of the pertinent time

Pre-Control Test

Prior to the Powley decree, one of the main hindrances that challenged Métis Aboriginal

rights petitioners was prevailing over the pre-contact factor of the Van der Peet certified test

(Bolaria & Hier 167). The Supreme Court of Canada, in the Van der Peet verdict, set up a test

distinguishing the requirements for prove that a practice, norm or custom was basic to the home-

grown civilization before the Crown took power over the area. In Van der Peet, a 3-section

‘distinctive practices’ test was formulated (Belcourt 18). The preliminary stage was

exemplifying the right. The following phase was making sure if the practice was indispensable or
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else said, integral and indispensable, to the native community in subject. The third phase

explained the need to ascertain continuity.

Due to the distinctive actuality that Métis community came into survival in consequence

of European associations, the ensuing sector of the Van der Peet test offered modest optimism of

the Métis influential legitimate rights (Isaac 57). In Powley dispute, the Supreme Court

personalized this element of the Van der Peet test to being called the pre-control test. The era of

European supremacy will be determined via investigating the moment in the past when

Europeans conquered political as well as bureaucratic power in a region (Dickason & McNab

71). The court adjusted this sector of the initial test in tribute of the constitutional position of

Métis practices, ethnicity and lifestyle that adhered to every other component of the native

legalized privileges test.

Métis peoples are exceptional from other Aboriginal individuals in this aspect; regardless

of all, the constitution has ascertained and inveterated presented Métis civil liberties and the

Powley test presently acts as the legal progression to make certain that constitutional protection

is given to the Métis general public (Isaac 98). The formalization of the Robinson Huron Treaty

in Powley was identified as the time of European dominance. However, this does not denote that

contract dates will be the factors applied in other vicinities. The essence and extent of European

existence in the region, the extent to which the Métis were really besieged by European laws and

traditions, along with the degree that colonial authorities supported or depressed settlement in the

region, are factors that will determine the period of European control in a particular locality

(Belcourt 113).

6. Was the practice integral to the claimant’s distinctive customs?

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Proof that the activity is an essential feature of the petitioner’s life and a central trait of

the petitioner’s connection to the land should be established, in order to meet this part of the test.

Evidence ought to be brought forth that hounding is integral to the Métis practices at the

particular geographic locality, in the period immediately prior to European ascendancy (Bolaria

& Hier 74). The value of the practice, norm or routine to the culture will add to it being termed

‘integral’. With the purpose of suggesting that the routine, norm or tradition is of essential

implication, the petitioner is supposed to exemplify that the act is among the issues that made the

culture of the community distinctive from the culture of the Europeans, which ultimately take

over. This implies that the practice, norm or ritual cannot be an aspect general to all individuals

or a feature that is simply incidental or irregular to the Aboriginal people. Dickason & McNab

(79) advised that, to discover if a practice is ‘integral’ the court will rely on the significant and

fundamental features of the Aboriginal people and the responsibility that the practice has.

A successful procedure to perceive if the practice is ‘integral’ is to solicit the query of

whether devoid of the practice, norm or tradition the culture in subject would be essentially

changed (Isaac 64). In Van der Peet the court emphasized that practices that are embedded in

pre-contact communities of the aboriginal society in subject will embrace the aboriginal rights.

So as to be apprehended as an integral practice, the tradition or practice ought not to be

contingent on another practice but should be separately central to the traditions. Aboriginal

practices that are supplementary to other practices or that are basically a subdivision of a primary

practice are not preserved by the Section 35 of the act (Isaac 75).

In Aboriginal rights cases justified earlier than Powley, the Supreme Court has stated

that Aboriginal practices, mores and traditions that came up due to Aboriginal relations with

European invaders were not among the rights preserved by the constitution. This was among the
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grounds that the Supreme Court put into action a time period (pre-contact) in the Van der Peet

case (Bolaria & Hier 91). On the other hand, special instances for example when a right that

existed before European dominion was somehow altered by the colonizers and that kept on to be

indispensable after that; was not disqualified from the privileges from defense by the

constitution.

7. Founding of Continuity connecting the Historic era and the modern-day Rights claimed

There should be some proof to hold up allege that the modern observance is in

connection with the precedent practice. The Court discovered that the Métis society of the Sault

Ste Marie had given adequate proof to verify that hounding for provisions carries on to be a basic

practice. According to Dickason & McNab (124), in various geographic regions intricacy may

crop up in confirming that the current community takes on the designation of ‘a population of

Métis with a distinctive shared individuality, residing together in the similar geographical region

and undertaking a universal practice.’ In the Sparrow case, settled by the SCC in 1990, the court

documented that Aboriginal customs, traditions and practices, are not fixed and could have

advanced eventually; such as because of technology (Isaac 97).

Nevertheless, it remains imperative to illustrate the association or permanence amid the

tradition, practice or norm of the present time and that, which subsisted, in pre-control societies

of the Métis (Isaac 62). This does not suggest that a steady cycle should survive. The trial judge

in the Sparrow hearing admitted that the community may cease to carry out the practice for a

certain time and recommence later on. However, the appropriate interval of termination has not

yet been markedly formulated (Bolaria & Hier 263). The Supreme Court has lain down that the

continuity element ought to be understood flexibly (Belcourt 116).

8. Extinguishment
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Before 1982, the constitution could extinguish the Aboriginal rights by, legislation or by

accord with the Aboriginal community. The ‘clear and plain intent test’ was developed in

Sparrow case by the Supreme Court of Canada to verify if the right has been extinguished by the

government (Dickason & McNab 23). The Sparrow pronouncement is a principal and

introductory case on the implication of the words used in s.35- ‘existing’ and ‘recognized and

affirmed’. The Supreme Court affirmed that section 35 grants protection for Aboriginal rights

though the warranty is not a complete protection. A treaty is an illustration of a clear and plain

intent to extinguish an aboriginal right. Approving legislation that does not seek to curb

Aboriginal rights but simply does so as a by the way, is not eligible to be termed as having a

clear and plain intent (Isaac 102).

In Powley, the Supreme Court verified that regardless of whether a Métis person’s

ancestor has obtained treaty rights, it is not pertinent to extinguishment. Aboriginal rights are

mutual rights and one person can’t coincide to extinguish the societies’ Métis rights (Bolaria &

Hier 237).The right will almost certainly be extinguished, if on the other hand, a whole Métis

community has signed a Treaty. However, there lacked proof of extinguishment by any of these

means in the row of the Sault Ste Marie Métis community (Isaac 46). Since the Métis were,

communally, openly debarred from the Robinson Huron Treaty, the treaty did not therefore

extinguish their Aboriginal rights.

9. If There Is a Right, Determination of whether there is an Infringement

Just like the Métis rights and any other existing rights, no rights are complete. This

implies that Métis privileges can possibly be narrowed (infringed) for a range of reasons

(Belcourt 142). If the violation is discovered to have transpired, in that case the government

could be capable to validate (justify) its deed. At this point, the Court stated that the overall
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malfunction to identify any Métis privilege to hound for food or every special permit rights to

natural reserves was a defiance of the right to hound offered to the Métis (Dickason & McNab

237)

10. Determination of Whether the Infringement is justified

The government can either use conservation, health, or safety as reasons that to justify

violating or infringing a native right, nevertheless, they are obliged to verify that there exists an

actual threat (Isaac 231). In the Powley case, they lacked proof to authenticate the existence of

any threat jeopardizing the moose populace. Even supposing it existed; it was declared by the

judicial system that the Métis would continue to be permitted to a precedence allowance to

gratify their survival needs compliant with the decisive factor established by the SCC in Sparrow

case (Bolaria & Hier 159). The Court alleged Ontario’s extensive stipulation of every Métis

freedom to hound for food would not be vindicated.

Conclusions

It would not be anybody’s expectation that the apparently trivial incident of violating a

hunting regulation would progress into one of the major important legal cases for Métis citizens

in the history of Canada. The case, which started as an accusation of a father and his son

concluded in to an immense issues involving the whole of the Métis population. It had turned out

that the conflict struggled in court was not merely over if Steve Powley and his son had done an

unlawful act, but rather, was disputed whether Métis community has a native right to hound.

However, the case marked a new beginning to the Métis population. At the end of the day, the

seemingly minor dispute led to the existence of a new law in the Canadian government known as

the Powley’s law (Isaac 75).

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In the effort to explore the remarkable representation of women in Métis governments,

two aspects emerged to be predominantly applicable. The foremost of these is about the

incomparable rank that women occupied in Western Canada’s fur trade society as well as in the

construction of Métis identity (Belcourt 93). There is jeopardy in eroding history, in presuming

that even in those cultures created beside matriarchal lines, that this automatically prohibited

men from afflicting women .Conversely, historical assessments of women in the Northwest holds

up the dispute that Métis women seized political, economic, and social authority in their societies

that was supreme in the lives of their European equivalents (Dickason & McNab 273).
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Bibliography

Belcourt, Herb. Walking in the Woods: A Métis Journey. Calgary. Brindle and Glass, 2006. pp

2-184

Bolaria, B. Singh. & Hier, Sean. Race and Racism in 21st-century Canada: Continuity,

Complexity, and Change. Washington, DC. Broadview Press, 2007. pp 23-307

Dickason, Olive. P. & McNab David T. Canada's First Nations: A History of Founding Peoples

from Earliest Times. Oxford, Oxford University Press, 2008. Pp 13-397

Isaac, Thomas. University of Saskatchewan. Métis rights. Michigan. Native Law Centre Native

Law Centre, University of Saskatchewan, 2008 pp 2-214