Canada · Alberta appeal procedures
When must I challenge an Alberta case management officer’s direction?
A person affected by a CMO’s administrative direction may apply to a single appeal judge within one month of the direction’s date to have it rescinded, confirmed, amended or enforced under Rule 14.36(3).
- Period
- 1 month after the established operative event
- Trigger
- The date of the actual CMO administrative direction
- Rule
- Alberta Rules of Court, Alta Reg 124/2010, r 14.36(3) (official PDF p. 354)
Official Alberta Rules of Court PDF published June 2026, including AR 79/2026, acquired October 8, 2026. The retained 2026 Gazette cumulative index and September 29 issue were checked for later listed amendments. Interpretation Act PDF is current as of September 1, 2025. Read with the consolidated directions amended March 10, 2025, electronic filing direction, July 2, 2025 registry reopening and current electronic scheduling notice. The actual September 30, 2026 closure is retained separately.
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When must I challenge an Alberta case management officer’s direction?
A person affected by a CMO’s administrative direction may apply to a single appeal judge within one month of the direction’s date to have it rescinded, confirmed, amended or enforced under Rule 14.36(3).
Responsible actor. A person affected by a case management officer’s administrative direction.
The date of the actual CMO administrative direction.
Learning of the direction later does not automatically restart the month. This procedure concerns an administrative direction, not every judicial order.
Alberta Court of Appeal civil procedure. Establish the administrative direction and affected-person status, then bring the application to a single appeal judge within the applicable period. Learning of the direction later does not automatically restart the month. This procedure concerns an administrative direction, not every judicial order. This ordinary branch requires the established actor, effective event and no operative varying direction. Unsupported holiday, closure and method facts require separate review.
Alberta Rules of Court, Alta Reg 124/2010, r 14.36(3) (official PDF p. 354)How does this provision count time?
- Establish the administrative direction and affected-person status, then bring the application to a single appeal judge within the applicable period.
- Establish the actual filing, service, hearing or listing event from the accepted document and proof.
- Rule 13.3 excludes the event or hearing date and counts consecutive calendar days. Its information note illustrates ten days before May 15 as May 5; it does not require ten intervening days. Rule 13.4 uses the same-numbered date for months, ending on the last day when that number does not exist. Its nonleap anniversary rule uses February 28 for a February 29 event.
- Check each required act’s actual holiday or closure boundary and any operative variation.
Rule 13.3 excludes the event or hearing date and counts consecutive calendar days. Its information note illustrates ten days before May 15 as May 5; it does not require ten intervening days. Rule 13.4 uses the same-numbered date for months, ending on the last day when that number does not exist. Its nonleap anniversary rule uses February 28 for a February 29 event.
Interpretation Act section 22(1) addresses expiry on a defined holiday; section 22(2) separately addresses closure of the actual required office or place. Section 28(1)(x) includes Sundays and specified holidays, but does not make every Saturday a holiday. A registry closure is not an automatic service extension. A backward minimum interval must remain satisfied. Actual proclaimed holidays, unsupported closures or an unestablished service method require separate review.
Alberta Rules of Court, Alta Reg 124/2010, r 14.36(3) (official PDF p. 354)What do independently checked examples show?
Fictitious example
The date of the actual CMO administrative direction is established on Friday, October 2, 2026. The event is effective under the actual governing method, rather than proposed dispatch or informal knowledge. Established ordinary actor and branch, effective filing and service as required, no varying direction, no additional proclamation or closure, and no independent earlier statutory bar.
| Step | What is counted | Date |
|---|---|---|
| Example 1. Ordinary established facts | The date of the actual CMO administrative direction is established on Friday, October 2, 2026. The event is effective under the actual governing method, rather than proposed dispatch or informal knowledge. Established ordinary actor and branch, effective filing and service as required, no varying direction, no additional proclamation or closure, and no independent earlier statutory bar. Independently add 1 months under Rules 13.3–13.4. The raw threshold is Monday, November 2, 2026. The final date is an established ordinary nonholiday weekday; no final-day adjustment is required. | Monday, November 2, 2026 |
| Example 2. Closed-day boundary | The date of the actual CMO administrative direction is established on Thursday, January 8, 2026. The event is effective under the actual governing method, rather than proposed dispatch or informal knowledge. Established ordinary actor and branch, effective filing and service as required, no varying direction, no additional proclamation or closure, and no independent earlier statutory bar. Independently add 1 months under Rules 13.3–13.4. The raw threshold is Sunday, February 8, 2026. The raw day is a defined holiday; the next nonholiday is Monday, February 9, 2026. The required filing place is established open and effective service is possible on that day. | Monday, February 9, 2026 |
| Example 3. Material procedural branch | The CMO makes the actual administrative direction on Friday, October 16, 2026, and the affected person receives it later. The direction date, rather than later receipt, starts the ordinary month. Established ordinary actor and branch, effective filing and service as required, no varying direction, no additional proclamation or closure, and no independent earlier statutory bar. Independently add 1 months under Rules 13.3–13.4. The raw threshold is Monday, November 16, 2026. The final date is an established ordinary nonholiday weekday; no final-day adjustment is required. The stated result is the established ordinary threshold for these actual facts; it does not establish an extension, earlier-duty compliance or procedural eligibility. | Monday, November 16, 2026 |
Fictitious established facts. These examples do not establish eligibility, effective service, relief or a direction.
Try these dates in the calculatorWhich conditions and exceptions apply?
- Actual actor and procedural branch
- Establish the administrative direction and affected-person status, then bring the application to a single appeal judge within the applicable period. Learning of the direction later does not automatically restart the month. This procedure concerns an administrative direction, not every judicial order.
- Material qualification
- Learning of the direction later does not automatically restart the month. This procedure concerns an administrative direction, not every judicial order.
- Actual variation
- Rule 14.2(3) displaces party-agreed extensions for Part 14. Rule 13.5 judicial powers and the actual authorized CMO direction must be read with the specific procedure. A requested extension, proposed timetable or private agreement does not establish operative relief.
- Required-act boundary
- Interpretation Act section 22(1) addresses expiry on a defined holiday; section 22(2) separately addresses closure of the actual required office or place. Section 28(1)(x) includes Sundays and specified holidays, but does not make every Saturday a holiday. A registry closure is not an automatic service extension. A backward minimum interval must remain satisfied. Actual proclaimed holidays, unsupported closures or an unestablished service method require separate review.
- Alberta Court of Appeal civil procedure. Establish the administrative direction and affected-person status, then bring the application to a single appeal judge within the applicable period. Learning of the direction later does not automatically restart the month. This procedure concerns an administrative direction, not every judicial order. This ordinary branch requires the established actor, effective event and no operative varying direction. Unsupported holiday, closure and method facts require separate review.
- Learning of the direction later does not automatically restart the month. This procedure concerns an administrative direction, not every judicial order.
What must the responsible actor complete?
Questions about this procedure
When must I challenge an Alberta case management officer’s direction?
What event starts the cmo direction review period?
The date of the actual CMO administrative direction. Preserve evidence of that event; Learning of the direction later does not automatically restart the month. This procedure concerns an administrative direction, not every judicial order.
Alberta Rules of Court, Alta Reg 124/2010, r 14.36(3) (official PDF p. 354)What must I complete for this cmo direction review procedure?
Establish the administrative direction and affected-person status, then bring the application to a single appeal judge within the applicable period.
Alberta Rules of Court, Alta Reg 124/2010, r 14.36(3) (official PDF p. 354)Does receipt of the direction start the month?
Rule 14.36(3) uses the date of the administrative direction. Establish that actual date.
Alberta Rules of Court, Rule 14.36 (official PDF p. 354)Who may apply for review?
Any person affected by the CMO’s administrative direction may apply under Rule 14.36(3).
Alberta Rules of Court, Rule 14.36 (official PDF p. 354)What relief can the appeal judge give?
The provision identifies rescinding, confirming, amending or enforcing the administrative direction.
Alberta Rules of Court, Alta Reg 124/2010, r 14.36(3) (official PDF p. 354)Is this an appeal from a single appeal judge’s decision?
No. It is review of a CMO administrative direction. Rule 14.5(1)(a) separately addresses appeals from a single appeal judge.
Alberta Rules of Court, Rule 14.5 (official PDF p. 339)Official sources and review
Provisions used (13)
| Provision | Purpose |
|---|---|
| Alberta Rules of Court, Alta Reg 124/2010, r 14.36(3) (official PDF p. 354) | Check the identified procedure, event, counting rule or qualification |
| Alberta Rules of Court, Rules 13.2–13.5, counting and variation | Check the identified procedure, event, counting rule or qualification |
| Interpretation Act, section 22, holiday and place-of-act expiry | Check the identified procedure, event, counting rule or qualification |
| Court of Appeal Electronic Filing Practice Direction, paragraphs 5(f) and 8 | Check the identified procedure, event, counting rule or qualification |
| Court of Appeal Consolidated Practice Directions, General A.3–A.4 | Check the identified procedure, event, counting rule or qualification |
| Interpretation Act, section 28(1)(x), holiday definition | Check the identified procedure, event, counting rule or qualification |
| Alberta Rules of Court, Rule 14.1 (official PDF p. 336) | Check the identified procedure, event, counting rule or qualification |
| Alberta Rules of Court, Rule 14.2 (official PDF p. 337) | Check the identified procedure, event, counting rule or qualification |
| Court of Appeal registry reopening notice, effective July 2, 2025 | Check the identified procedure, event, counting rule or qualification |
| Court of Appeal electronic scheduling notice of March 10, 2025 | Check the identified procedure, event, counting rule or qualification |
| Interpretation Act, RSA 2000 c I-8, sections 22 and 28(1)(x) | Check the identified procedure, event, counting rule or qualification |
| Alberta Rules of Court, Rule 14.36 (official PDF p. 354) | Check the identified procedure, event, counting rule or qualification |
| Alberta Rules of Court, Rule 14.5 (official PDF p. 339) | Check the identified procedure, event, counting rule or qualification |