Cromwell v Leon’s Furniture Limited, 2014 CanLII 16399, a Nova Scotia human rights board of inquiry found that the complainant had been subjected to racially discriminatory comments and differential treatment by her manager, with little response from her employer in relation to her complaints. The manner in which the complaint was investigated and concluded failed to meet a fundamental level of reasonableness in the circumstances. The complainant had acted reasonably in resigning her employment as a result.

The board declined to award loss of future earnings on the basis of what would have been reasonable notice. The discrimination had resulted in long-term injury to the complainant’s self-worth and had detrimentally affected her financial and emotional stability. The complainant was entitled to damages for loss of income equivalent to her regular gross income for an 18-month period following the cessation of her employment and $8,000.00 in general damages. The employer was ordered to arrange for training in cultural competency for store managers, supervisors and all staff at the store where the discrimination had occurred.