In Chief Steinhauer v. Saddle Lake Cree Nation’s, 2025 FC 1362 (CanLII), the Federal Court ordered that Chief Dale Steinhauer be reinstated as the elected leader of Saddle Lake Cree Nation in Alberta, halting a community motion and council decision that had removed her from office just weeks after her election. The decision follows an urgent motion heard by videoconference on August 6, 2025, with Justice Julie Blackhawk issuing the ruling two days later.
Saddle Lake Cree Nation, located northeast of Edmonton and home to nearly 7,000 on-reserve members, operates under custom election regulations developed in the 1950s and 1960s. These rules call for the election of nine councillors, with the chief selected from among them. In the June 11, 2025 general election, nine councillors were elected, and one week later, Steinhauer was chosen as chief. She formally began her role with traditional and community inauguration ceremonies.
Tensions arose within weeks of her swearing-in. On June 24, 2025, during an open orientation meeting, members Wilfred Whiskeyjack and Linda McGilvery called for a community meeting, which was held on July 2. At that gathering, frustrations were voiced over what some members described as unilateral actions by the chief. A motion was introduced seeking her immediate removal, the reinstatement of the previous council, and the calling of a new election in September. According to the record, 128 members supported the motion, while 58 opposed it. The following day, several current councillors formally certified and approved the removal motion.
Steinhauer applied to the Federal Court for an injunction, arguing that the removal breached the nation’s election regulations and caused irreparable harm to her reputation and ability to carry out her duties. The Saddle Lake Cree Nation ultimately agreed to an interim stay of the removal decision but opposed some of the additional governance measures she sought while the judicial review proceeds.
Justice Blackhawk ruled that the chief met the legal test for injunctive relief, finding there was a serious issue to be decided, evidence of irreparable harm, and that the balance of convenience favoured interim reinstatement. The court also emphasized the need for proper quorum, notice, and participation in council decision-making, noting that democratic principles require more than just meeting minimum quorum thresholds.
The order not only reinstates Steinhauer but also imposes detailed governance protocols on the council until the judicial review is resolved. These include equal access for all councillors to facilities and communication tools, mandatory regular meetings, co-chairing arrangements, advance agendas, and decision-making by consensus or, where necessary, majority vote. Council meetings will be open to community members except when discussing this litigation or confidential matters involving individual members.
Justice Blackhawk also determined that the Saddle Lake Cree Nation, rather than individual councillors, should be the respondent in the case. The chief was awarded costs at the top range of the court’s tariff, payable immediately.
The judicial review will determine whether the July motions removing Steinhauer from office complied with the nation’s election rules and governing principles. Until then, she will remain in her role as chief, and the council will operate under the court’s interim directions.
Read about more cases involving indigenous matters here.
