34 interviews, zero names disclosed, and a finding that still stands
A school superintendent whom Alberta's whistleblower commissioner found responsible for a culture of fear wanted to know who her anonymous accusers were. The province's highest court has now ruled that investigators never had to name them.
In a decision dated June 1, 2026, the Court of Appeal of Alberta allowed the Public Interest Commissioner's appeal and reinstated his report, which concluded that Mary Lynne Campbell, the former superintendent of the Sturgeon School Division, had grossly mismanaged employees. The panel of Justices Jolaine Antonio, William T. de Wit and Joshua B. Hawkes overturned a lower court that had thrown the report out.
A disclosure and 34 interviews
The case began in May 2021, when a whistleblower filed a disclosure under Alberta's Public Interest Disclosure (Whistleblower Protection) Act, alleging Campbell had grossly mismanaged employees through a pattern of conduct relating to bullying, harassment or intimidation. The complainant's identity was withheld from Campbell from the start.
An investigator interviewed 34 current and former employees of the Division, a public school authority north of Edmonton, asking general questions about workplace culture without telling them Campbell was the person under investigation. The summaries that followed reported that thirty-one witnesses described the culture as one of fear, and that nineteen described her management style as micromanagement.
In her disclosure, the whistleblower wrote, "I have absolutely no voice unless I agree with her completely. If I disagree, I get yelled at. I get belittled."
Superintendent pushed back
Campbell, appointed superintendent in July 2018, denied the allegations. She went on medical leave in October 2021 and gave notice that she intended to retire in 2022. Through counsel, she filed a 157-page response that addressed the investigation summary paragraph by paragraph and argued the allegations were factually incorrect.
She said she treated everyone equally and with respect and did not bully, harass or intimidate staff. She said the board had directed her to change a workplace culture it considered entitled and complacent, and that the complaints were coordinated by employees unhappy with the changes she had made.
Her central objection was secrecy. She argued she could not properly answer accusations without knowing who was making them or when the events were said to have happened. The Commissioner declined, explaining that protecting witnesses and whistleblowers was central to the scheme, and he set aside any evidence Campbell could not address without knowing a name. In December 2022, he issued a report concluding Campbell had grossly mismanaged employees and was responsible for a culture of fear. Because she had retired, he recommended no corrective measures.
Why the court let the secrecy stand
A judicial review judge sided with Campbell in 2024, quashing the report and finding that withholding every witness's name was procedurally unfair. He described the potential damage to her reputation as impossible to measure, even though her employment was never at stake.
The Court of Appeal disagreed. Stepping into the lower court's shoes, the panel found the whistleblower scheme is built to protect the people who come forward, and that the genericized summaries had given Campbell the substance of the case she needed to meet. The panel added that a report carrying no binding consequences, issued after her retirement, did not call for the court-like process she had sought.
The judges also noted that Campbell had since received the witnesses' identities through the court record, yet had not shown how her response would have differed. Knowing the names might have made it easier to challenge credibility, they acknowledged, but "administrative procedures need not be optimal to be fair." The appeal was allowed, and the Commissioner's report stands.
See Campbell v Alberta (Public Interest Commissioner), 2026 ABCA 184
