Pam MacEachern acted for the Canadian Human Rights Commission in the Canadian Human Rights Tribunal (CHRT) decision Warman v. Kyburz in 2003.

The case emerged from a complaint made by lawyer Richard Warman to the CHRT against Fred Kyburz. He alleged Mr. Kyburz communicated messages through his website that exposed identifiable groups – mainly Jews – to hatred or contempt, in violation of section 13 of the Canadian Human Rights Act.

The tribunal concluded that the messages clearly fostered hate and contempt, and so did in fact violate the Act. This was one of the first cases in Canada dealing with hate on the Internet, and reinforced the jurisdiction of human rights legislation over online content. Section 13 of the CHRA was repealed by the federal government in 2013.