Rebellious Lawyering and Ontario Sex Workers during COVID-19

Disponible uniquement en anglais.

par Alexandra Tamiko Da Dalt, lauréate 2021 du concours de dissertation Écrire au féminin.

“Must we accept what we’re now living as our only option?… Must we settle for wildly less than we dream in building our relationships, our institutional capacity, and our democratic communities?”¹

I. INTRODUCTION: REBELLIOUS LAWYERING

When Gerald P. Lopez entered law school in 1970, he sought to practice left-wing activist lawyering and to create change in and beyond his community. As a young Chicano man who believed that justice requires the creation of power, he rejected modes of prescriptive lawyering that were disconnected from people’s realities. Instead, he envisioned a new kind of practice, “radical lawyering,” that must be anchored in the world it is attempting to change and in the lives of the people it most affects.²

Lopez asked, “How could my vision trigger in others recognition of how we might work and live together to tackle particular challenges, to alter our institutions and practices, to change the world as we know it?”³ As a paradigm, rebellious lawyering distinguishes between the “reigning approach” of “regnant lawyers” in contrast to the alternate “rebellious vision.”⁴ Regnant lawyers might be well-meaning, but Lopez defines them as practicing law in a way that reinforces existing power dynamics and ultimately “practice for the subordinated.”⁵ Ultimately, this model of lawyering does a disservice to the communities it is purporting to serve. The egos of lawyers often prevail, and they end up pursuing strategies that benefit their ambitions rather than their clients.⁶ They do not collaborate with other problem-solvers in a community to most effectively address issues – rather, they relegate themselves to legal doctrine and work in isolation. Additionally, regnant lawyering ignores the rich experiences and knowledge that clients bring to the relationship – by neglecting to engage with these realities, lawyers miss an opportunity to effectively communicate and equip people with the tools they need to solve their own problems.⁷

In contrast, rebellious lawyering embraces community-based models of working and generating power. Its roots are in the everyday experiences and stories of the people it seeks to serve, and rebellious lawyers collaborate with others (professionally and personally) who are immersed in communities. Additionally, they try to make the law accessible to everyone, making it a tool for self-help and empowerment as opposed to an opaque system of the powerful. This combination of organizing, educating, and lawyering attempts to reshape power dynamics and the current system of lawyering. Lopez writes, “They [rebellious lawyers] try… to draw on marginalized experiences, neglected institutions and dormant imagination to redefine what clients, lawyers, and others can do to change their lives.”⁸

Rebellious lawyers reject uncritically adopting traditional legal approaches without considering alternatives.⁹ They understand the transformative power of coalition building between lawyers, other professionals in a community, and the people who are experiencing the issue at hand. Rebellious lawyers do not impose their own legal agendas on clients, but rather work with clients to identify the best path forward. Lopez highlights that lawyers must seek to learn from their clients about their needs but also “about law’s limited imagination, sometimes about its irrelevance on the street, its failure to penetrate the lives of subordinated people.”¹⁰

This paper seeks to engage with Gerald Lopez’s work on rebellious lawyering in the context of access to justice for sex workers in Ontario, Canada. Models of lawyering in Ontario that have relied on the rebellious approach are creating power in their communities and working with (not just for) sex work-engaged populations. Current initiatives offer transformative possibilities and visions for the future with regards to access to justice for sex workers.

II. FEMINIST ANALYSIS OF SEX WORK

This paper acknowledges the reality that sex workers are not a monolith, and that there are a multiplicity of experiences in the industry. This complexity requires an attention to the subjectivities and needs of different communities that engage in sex work. For the purposes of this paper, the term “sex work” will refer to consensual acts of labour in exchange for material compensation.¹¹ The term includes stripping, work on camera, sexual acts with a client, and/or other activities.

The criminalization of sex work in Canada has had devastating consequences for sex work-involved populations. Criminalization is dangerous – sex workers are more vulnerable to violence and have fewer options for recourse when harm does occur. They are not able to turn to law enforcement or other authorities for assistance because of the risk of penalization. Laws such as Bill C-36, the 2014 Protection of Communities and Exploited Persons Act (PCEPA), criminalize the purchase of sexual services and legally frame all sex workers as victims who need to be monitored and “protected.”¹² The removal of criminal laws and decriminalization of sex work would represent progress and a step towards the realization of sex workers’ rights, including autonomy and self-determination.¹³

Additionally, campaigns around human trafficking contribute to stigma and harm for sex workers. The misconception remains that sex work is the same as sex trafficking, but sharp contrasts exist. First and foremost, choice, consent, and freedom are essential parts of sex work. Danielle Hoffmeester writes:

It is imperative to understand the difference between sex work – transactional sex between adults who have consented – and sex trafficking, which is an abhorrent abuse of human rights. Failure to make this distinction will increase societal ignorance that ultimately filters through to legislation, law enforcement and social justice work and thereby exacerbate the risks and dangers faced by sex workers.¹⁴

This does not mean that harm and violence do not occur in sex work – as mentioned above, the risks remain real and are magnified due to criminalization.¹⁵ However, the perception that sex workers need “rescuing” (particularly migrant or racialized sex workers) is rooted in racism, xenophobia, and persistent myths about largely fictional transnational crime networks. Investigations into trafficking, funded in Ontario and federally, largely allocate resources to federal and municipal police as well as border security services. Investigations carried out by these bodies increase the vulnerability of sex workers and often subject them to “arbitrary arrests and detainment, inhuman and degrading treatment, false allegations, and false evidence being used to keep them detained.”¹⁶ Legal systems and law enforcement are often weaponized and become tools of oppression rather than protection. The increased surveillance of racialized sex worker populations leads to harm, and tactics often include coercion and intimidation of women who are living and working at the intersection of multiple forms of oppression. Sex workers are more vulnerable as a result of increased policing and surveillance without pathways to decriminalization and a real focus on protection, not penalization.

III. POSITIONALITY STATEMENT

I subscribe to feminist research methods and believe knowledge building is a way of constructing new forms of understanding. Key to feminist research methodology is trying to understand and change society’s power dynamics, and this article recognizes the hierarchical power relations that persist between women and men, as well as between women with different identities such as class, race, sexual orientation, assigned gender at birth, and/or ability.¹⁷ I operate and conduct research with an intersectional feminist lens that takes into account systems of oppression and their effects on distinct communities. I believe sex work is valid work and that every person has the right to engage in it safely. I have not engaged in sex work or identified as a sex worker; it is an academic and personal area of interest. My hope is that this article will function as a snapshot of a current moment in lawyering in the province of Ontario – one that will provide insights into the ways activists and lawyers are mobilizing and providing access to justice for sex workers.

IV. ONTARIO SEX WORKERS AND THE COVID-19 PANDEMIC

In Ontario, sex workers are confronting a variety of challenges, some new due to the COVID-19 pandemic. The role of the police in sex workers’ professional and personal lives remains focused on surveillance and primarily creates harm. The province’s series of lockdowns, public health measures, and emergency orders have forced many into precarious positions with regards to their labour and how and where it is conducted.

A. POLICING DOES NOT PROTECT SEX WORKERS UNDER THE CURRENT LEGAL REGIME

A 2021 study by the University of British Columbia’s Centre for Gender & Sexual Health Equity and the University of Ottawa’s Department of Criminology interviewed two hundred sex workers from across the country to understand federal laws, policing, and their effects on sex work. The study found that 31% of sex workers do not report crimes or harm to the police because of the current laws that criminalize their work. The current focus on an “End Demand” framework for legal interventions criminalizes clients as well as third parties involved in sex work (which includes managers, assistants, security, etc.). Laws under this model also include penalties against cost sharing models or pooling of expenses by multiple sex workers, which could be seen as profiting off sex work.¹⁸ This model, and accompanying fear that it creates among sex workers, ultimately results in less protection for sex workers themselves. This risk is magnified for sex workers living at the intersection of multiple identities and experiences. Over 36% of Indigenous sex workers report being unable to call 911, and among sex workers who had previously experienced police harassment, 47% reported being unable to call police in an emergency.¹⁹

The study’s author and researcher Anna-Louise Crago extrapolated on how these numbers have most likely worsened during the COVID-19 pandemic:

When you have a legal framework where you are concerned that if you call for help, or you call for assistance, that could result in a raid of your workplace and you could lose your income…it gives us reason to be concerned that these dynamics that we’ve documented could be worse now during the pandemic.²⁰

The report’s findings on the relationship between sex work and violence illustrate the harms associated with “end demand” criminalization frameworks as well as police enforcement and targeting of sex workers. These results align with the findings of a 2019 Canadian HIV/AIDS Legal Network report in which interviewed sex workers described “increasingly pervasive, unsought and disproportionate surveillance from law enforcement, who employ an array of laws to scrutinize, monitor, interrogate, harass, detain, ticket and/or arrest sex workers.”²¹ The law enforcement interventions mentioned were not a case of a “few bad apples,” but ultimately pointed to a systemic regime of control of sex workers’ lives and rights.²²

B. PANDEMIC RESTRICTIONS AND RISKS

1. CLOSURE OF BUSINESSES AND ESTABLISHMENTS

The Ontario government closed strip clubs on 12:01 a.m. on 26 September 2020.²³ This closure followed outbreaks in Toronto two strip clubs in August and September of that year.²⁴ Toronto Mayor John Tory made public remarks disparaging strip clubs, such as, "I noticed that this person [owner of a strip club establishment] voluntarily closed their doors for two weeks; maybe it’d be better if they all closed and then we wouldn’t have to worry about this.”²⁵ During press conferences announcing these closures, Ontario Premier Doug Ford made remarks that reflected negatively on the stripping industry, including, "I’m sorry for the spouse. Man, I wouldn’t want to be on the end of that one," referring to the person who visited the strip club and was diagnosed with COVID-19.²⁶

Toronto and Ontario Public Health were involved in the notifications of the outbreaks of individual strip clubs, but there was very little evidence of their involvement in the closure decision. One infectious disease specialist and ICU doctor at Toronto Western Hospital referred to the strip club and earlier bar and restaurant closures, “I think it’s window dressing, I think it doesn’t address the reality that human behaviour will adapt. It’s an optical illusion. I just don’t think it’s going to make a measurable difference. Will it help? Potentially. But not enough.”²⁷ There was no other information regarding public health professionals nor epidemiologists weighing in on the closure to inform the government’s decision, and the effect on the livelihoods of strippers and other strip club employees has been devastating.

2. INCOME CHALLENGES

The COVID-19 pandemic has pushed many people into precarious financial situations and changed the landscapes of different kinds of work. Sex work is no different – demand for sex work services have decreased and the risks have increased. Many buildings no longer allow guests, and sex workers who ordinarily would work inside have had no choice but to work on the street. Outside, street-based sex work poses more risks, leaves less time to negotiate a payment amount, and by extension, the pay tends to be one-third of the rate.²⁸ Additionally, as sex work is criminalized and often secretive, the majority of sex workers have not been able to access income replacement programs during the pandemic. A May 2020 survey revealed that less than half of sex work respondents applied for the Canada Emergency Response Benefit (CERB), some ineligible because of precarious or undocumented immigration status and others because they were already claiming another kind of social assistance.²⁹ Additionally, many sex workers do not file taxes (a requirement for CERB) due to the criminalization of their work and the attached stigma.³⁰ Many organizations across Ontario have stepped up to crowdfund resources and assistance for street-based sex workers who tend to be the most vulnerable.³¹ These initiatives further highlight how the community has mobilized to respond to the government’s lack of action on these critical issues.

The risks posed to sex workers’ health due to the pandemic mirror those of front-line workers. However, even following safety protocols, clients may not respect boundaries and criminalization makes it more difficult for sex workers to reach out for protection or support. Jelena Vermilion, Executive Director of the Sex Workers’ Action Program Hamilton (SWAP Hamilton) stated, “What’s happening right now is a crisis. It’s a specific crisis for sex workers.”³²

V. REBELLIOUS LAWYERING WITH SEX WORKERS IN ONTARIO

The following are examples of how rebellious lawyers are responding to the challenges posed by COVID-19 to create change and ensure sex workers’ rights are protected during the pandemic. The intervenorships and legal challenges, legal resource and education work, as well as clinics and direct legal services are all unique puzzle pieces that comprise an approach to rebellious lawyering in Ontario.

A. INTERVENORSHIPS & LEGAL CHALLENGES

While constitutional challenges can sometimes neglect smaller legislative changes, the visibility of sex workers and the centering of their rights in the courts is critical. In Canada (AG) v Bedford, sex workers’ rights organization Maggie’s Toronto Sex Worker’s Action Project sought to raise new constitutional issues under s. 15 of the Charter.³³ However, the Supreme Court declined to hear testimony of advocacy organizations run by sex workers themselves and ultimately did not provide reasons for the denial of intervenor status.³⁴ Mariana Valverde writes that the challenge that reached the Supreme Court was conducted primarily by lawyer and professor Alan Young, who:

…made some effort in 2006 to reach out to… Maggie’s: Toronto Sex Workers Action Project, but then ultimately sent Maggie’s a memo outlining his strategy. The case was thus conducted without accountability to that major local organization…. Young positioned himself as a heroic lawyer opposed to Big Brother.³⁵

Valverde’s assessment of Young’s lawyering style is reminiscent of the style of regnant lawyers who reinforce power dynamics and lead the work with their ambitions, not the needs of the clients. Though Bedford ultimately led to significant gains for sex workers in Canada, the manner in which the case was conducted, and the way sex workers’ contributions were treated, was not in following the model of rebellious lawyering. Mary J. Bunch writes:

Sex workers are a significant part of the conversation in Bedford, yet sex worker activists are the only group whose credibility with respect to their self-representation came under question during processes of appeal. Paternalistic, moralistic, and stigmatizing undercurrents were evident in several of the appeal factums. These subtly, and at times overtly, deny that sex workers can critically apprehend their own circumstances and ultimately make meaningful contributions to public discourse about the constitutionality of the laws surrounding prostitution in Canada.³⁶

In contrast to the processes and dynamics at play in Bedford, Naomi Sayers, a practicing lawyer with sex trade experience, is leading the current Work Safe Twerk Safe challenge to the Ontario closures of strip clubs. ³⁷ Work Safe Twerk Safe is a stripper-led organization that was established in 2019. They address concerns strippers may have about working conditions and related issues, and also provide a social space for solidarity building and information sharing.³⁸ The appeal, filed in October 2020, seeks to address the arbitrary and unsupported decision to close all strip clubs without consultation and prior notice. Work Safe Twerk Safe alleges that their section 7 Charter rights to the right to life, liberty, or security of the person have been violated and that strip clubs were treated differently than other bars due to whorephobia and stigmatization. Naomi Sayers stepped forward to lead the challenge on a largely pro bono basis with her co-counsel Christopher Folz.³⁹

A critical aspect of this court challenge is the anonymization order.⁴⁰ Naomi Sayers sought this order in order for strippers to be able to file affidavits without using their legal names. The anonymization is critical for the most affected to be able to tell their stories while being protected from potential retaliation from management, stigma and discrimination from family, friends, and future employers, as well as surveillance from police and child protection services.⁴¹ Sayers’ leading this challenge and her success with regards to the anonymization order speaks to the importance of sex workers’ needs and realities being centred in court.

On 30 March 2021 the Canadian Alliance for Sex Work Law Reform, an alliance of 25 sex workers rights groups across Canada including individual co-applicants, filed a Notice of Application to strike down sex work prohibitions. The focus is on prohibitions against:

…impeding traffic (s. 213(1)), public communication (s. 213(1.1)), purchasing (s.286.1(1)), materially benefiting (s. 286.2(1)), recruiting (s. 286.3(1)), and advertising (s. 286.4) in the Criminal Code, because they violate sex workers’ constitutional rights to security, personal autonomy, life, liberty, free expression, free association, and equality.⁴²

This constitutional challenge is led by sex workers themselves and targets the Protection of Communities and Exploited Persons Act and the harms it has produced for sex workers. The press release features quotes from individual sex worker co-applicants and the action is built on the experiences of sex workers who live and work under the conditions of PCEPA and other criminalization regimes. Though the outcomes still remain to be seen, the Work Safe Twerk Safe case and the Canadian Alliance for Sex Work Law Reform action provide models for rebellious lawyering in action with sex workers and their realities.

B. WORKSHOPS AND RESOURCES

Gerald Lopez’s model of community-centred problem solving involves resource creation and distribution, and Ontario sex work organizations have compiled comprehensive resources and organized events to inform people of their legal rights. ⁴³ Toronto queer community centre the 519 held an event on 30 March 2021 for attendees to “learn about your rights and the community supports available to you.”⁴⁴ The workshop featured Naomi Sayers and Samantha Peters, lawyers with expertise in employment and human rights law. The event covered unionizing, legal and non-legal mechanisms for reform, and privacy and safety concerns. The webinar was structured so that personal identifiers and cameras would be disabled to ensure participant safety and anonymity.⁴⁵

Other organizations, such as SWAP Hamilton, have “Safety Tips” and “Resources” sections of their website. The SWAP Hamilton “Safety Tips” listed include sections on “Getting Ready for Work,” “On the Job,” “Ways to Protect your Identity,” and “Tips for Making Referrals for Service Providers Assisting Sex Workers.”⁴⁶ These sections are tailored to the realities of sex work and the needs of different practitioners. The Butterfly Asian and Migrant Sex Workers Network also provides legal resources with a multidisciplinary approach to access to “health, social, labour, and legal rights and services.”⁴⁷Their report on how anti-trafficking policies harm sex workers concludes with the following statements:

Sex work is not trafficking!
Migration is not trafficking!
Sex work is work!
Sex workers’ right are human rights!⁴⁸

The Resource “Sex Work and COVID-19: Guidelines for Sex Workers, Client, Third Parties, and Allies”⁴⁹ was compiled and distributed by Maggie’s and Butterfly and focuses specifically on working during COVID-19.

C. LEGAL CLINICS AND SERVICES

In addition to participating in intervenorships and generating resources, Maggie’s Toronto has also partnered with the Biking Lawyer firm’s Junior Associate Deniqua Edwards to provide free consultations.⁵⁰ Sex workers have been stopped by the police in the enforcement of new COVID-19 bylaws, and Edwards is offering legal advice to those affected. This new 2021 partnership is in addition to Maggie’s regular legal clinic which provides assistance with employment, family law, and other issues. Though Maggie’s offices are now closed, legal advice is available virtually by booking a one-on-one consultation.⁵¹

This kind of direct legal support is a way of connecting more deeply with the problems experienced in a particular community and partnering to solve them. Lawyer Naomi Sayers, when speaking about her practice and working with clients, said, “You should be invited, you should be seeking the consent on your client, and you should really be figuring out what your client needs.”⁵² This aligns with both Gerald Lopez’s vision of rebellious lawyering but also Janet Mosher’s conception of access to justice. Mosher writes:

… Access to justice requires understanding, engagement with the reality of others, transparency regarding both the content of the rules/laws and how authority is exercised in relation to those rules, the opportunity to participate (to speak, to be heard), and the opportunity to learn (including through mistakes). ⁵³

Mosher’s definition of access to justice comes out of a study of youths in high schools near/in the Jane and Finch area of Toronto. In focus groups, participants spoke about their relationship with the justice system and its effects on their lives. As in Mosher’s study, Lopez’s rebellious lawyering is built on the foundation of what an affected population itself defines as most pressing.  Maggie’s direct action legal clinic and services meet sex workers where they are and allow them to define their own needs. This is foundational – as Naomi Sayers, Gerald Lopez, and Janet Mosher agree – to achieving a kind of justice.

VI. CONCLUSION: A PATH FORWARD

Access to justice is not just about access to lawyers and to the courts – it is about access to “the good life” and what that might mean to each person.⁵⁴ In this way, its meaning is difficult to define for a group as diverse as sex workers in Ontario. However, lawyers across the province are providing models of rebellious lawyering that are working in tandem with other forms of building power for sex workers.

Gerald Lopez writes, “Legal strategies are but one of multiple strategies that can be implemented to achieve social change.”⁵⁵ The lawyers and organizations detailed in this paper are forging paths that recognize the importance of community-based lawyering and innovative approaches to access to justice work from a variety of perspectives. Organizing and communicating authentically and openly with key stakeholders is a cornerstone of rebellious lawyering. Lawyer-facilitated advocacy is clearly in motion, but future paths toward access to justice for sex workers will continue this work. According to Lopez:

The absolutely grounded conviction… is that we can and must strive for something better, knowing that there have been moments of "something better" in the past, and that there can be such moments again in the future. … If we can learn to be any good at working together, we can lengthen these moments. And as we do so, we can change along the way both how we think about our living together and how we think about our solving problems together (including through our professional lawyering).”⁵⁶

Sex workers in Ontario deserve access to justice and to be the experts on their own lives and experiences when seeking out the “good life.” This requires problem solving rooted in collaboration and humility, as defined by Gerald Lopez. If a vision for the future continues to be grounded in rebellious lawyering and community engagement, it will keep producing more authentic gains for sex workers across the province.

LEGISLATION

O. Reg 364/20, s 19.1.

JURISPRUDENCE

Canada (AG) v Bedford, 2013 SCC 72 [Bedford].

SECONDARY MATERIAL

1310 News, “Premier Ford announces further restrictions to bars, restaurants, and strip clubs,” 1310 News (25 September 2020), online.

The 519, “Private Group #Webinar - Sex Work: Know Your Rights Tuesday, March 30, 3-4:30pm ET Via Zoom. Register: http://bit.ly/519swr Free webinar for #BIPOC #LGBTQ2S and other marginalized sex workers. All personal identifiers and cameras will be disabled. @LawFoundationOn @kwetoday” (15 March 2021 at 18:14), online.

Amnesty International, “The rights of sex workers are being ignored in the COVID-19 response: In conversation with Jenn Clamen of the Canadian Alliance for Sex Work Law Reform” (23 April 2020), online (blog)

Arthur, Bruce. “Closing strip clubs: you could say Ontario’s pandemic plan has no clothes, but it’s a start,” The Toronto Star (25 September 2020), online.

Bill C-36, “Protection of Communities and Exploited Persons Act”, 2^nd Sess, 41^st Parl, 2014 (as passed by the House of Commons 6 October 2014).

Buckley, Rya. “The Impact of COVID-19 on Hamilton Sex Workers”, The Silhouette (18 February 2021), online

Bunch, Mary J. “Communicating for the Purposes of Human Rights: Sex Work and Discursive Justice in Canada” (2014) 3:1 Can J Hum Rts 39 at 53 [Bunch].

Butterfly Asian and Migrant Sex Workers Network, “About Us” (2017), online.

Butterfly Asian and Migrant Sex Workers Support Network, “Behind the Rescue: How Anti-Trafficking Investigations and Policies Harm Migrant Sex Workers” (June 2018) at 4, online (PDF)

Butterfly Asian and Migrant Sex Workers Support Network, “How are Asian and migrant workers in spas, holistic centres, massage parlours and the sex industry affected by the COVID-19 pandemic?” (May 2020) at 3, online (PDF)

Canadian Alliance for Sex Work Law Reform, Press Release, “News! Sex Worker Human Rights Groups Launch Constitutional Challenge” (30 March 2021).

Canadian HIV/AIDS Legal Network, “The Perils of ‘Protection’: Sex Workers’ Experiences of Law Enforcement in Ontario” (March 2019) at 38, online (PDF)

Crago, Anna-Louise et al. “Sex Workers’ Access to Police Assistance in Safety Emergencies and Means of Escape from Situations of Violence and Confinement under an “End Demand” Criminalization Model: A Five City Study in Canada” (2021) 10:13 Social Sciences 1 at 2.

Farrow, Trevor. “What is Access to Justice?” (2014) 51:3 Osgoode Hall LJ 957 at 971.

Fenton, Claire. “30% of sex workers don’t call 911 because of fear of police: study” Global News (26 January 2021), online.

Gira Grant, Melissa. “Playing the Whore: The Work of Sex Work” (London: Verso, 2014) at 41 [Grant].

Herhalt, Chris. “Toronto mayor suggests strip club closure after second COVID-19 outbreak” CTV News (14 September 2020), online.

Hoffmeester, Danielle. “Important difference between sex work and sex trafficking is consent” (5 July 2018), online.

Hung, Betty. “Rebellious Lawyering at 25: Movement Lawyering as Rebellious Lawyering: Advocating with Humility, Love and Courage,” 23 Clinical L Rev 663.

Hutia Xeiti Rivera, Ignacio G. “The Invisibles,” in Natalie West & Tina Horn, eds, We Too: Essays on Sex Work and Survival (New York: First Feminist Press, 2021) 233 at 238.

Kassam, Ashifa. “Canada: 550 people exposed to Covid-19 at Toronto strip club” The Guardian (16 August 2020), online.

Lopez, Gerald P. “Living and Lawyering Rebelliously”, 73 Fordham L. Rev. 2041 (2005).

Lopez, Gerald P. “Rebellious Lawyering: One Chicano’s Vision of Progressive Law Practice” (Boulder: Westview Press, 1992).

Maggie’s, “Homepage” (2021), online.

Maggie’s, “Police Must Stop Ticketing Sex Workers Through the Pandemic” (13 January 2021), online.

Maggie’s and Butterfly Asian and Migrant Sex Workers Support Network, “Sex Work and COVID-19: Guidelines for Sex Workers, Clients, Third Parties, and Allies” (2020), online (PDF).

Mosher, Janet E. “Lessons in Access to Justice: Racialized Youths in Ontario’s Safe Schools,” (2008) 46:4 Osgoode Hall LJ 807 at 850.

Reinharz, Shulamit & Davidman, Lynn. “Feminist Methods in Social Research” (Oxford: Oxford University Press, 1992).

Sayers, Naomi. “Movement Lawyering Panel” (Osgoode Hall Law Union and Queens Law Union event delivered on Zoom, 16 March 2021) [unpublished].

Sayers, Naomi. Press Release, “Work Safe Twerk Safe v HMQRO: Update on Judicial Review” (16 February 2021).

St. Denis, Jen. “Less Money, More Danger: How the Pandemic Changed Sex Work” The Tyee (1 February 2021), online.

SWAP Hamilton, “Definitions” (2021), online: Sex Workers’ Action Program Hamilton.

SWAP Hamilton, “Safety Tips”, (2021), online, Sex Workers Action Project Hamilton.

Valverde, Mariana. “Canadian Feminism and Sex Work Law,” in Elya M. Durisin, Emily van der Meulen, & Chris Bruckert, eds, Red Light Labour: Sex Work Regulation, Agency, and Resistance (Vancouver: UBC Press, 2018) 247 at 249.

Work Safe Twerk Safe, “About”, (2019), online.

Work Safe Twerk Safe, “Donate to our GoFundMe! Funds go towards our legal action” (21 November 2020), online (blog).

Work Safe Twerk Safe, “Legal Action Update 2: The Importance of Anonymity” (26 November 2020), online (blog).

Endnotes