An appeal heading to Alberta’s Court of King’s Bench could shape how Canadian employers approach dual-role contracts and the legal limits of single-payroll structures. At its centre is a case involving a university academic who claims to have also been employed by the province’s health authority while receiving a single salary.

The outcome may affect how post-secondary institutions and healthcare providers define employment relationships, particularly for professionals who split time across academic and clinical duties. The court’s decision could also set a precedent for how employers in other sectors handle hybrid or shared roles in the context of collective agreements.

Dr. Stacey Hume, a molecular geneticist, is appealing a 2023 ruling that dismissed her claim of dual employment. For 17 years, she held a contingent appointment with the University of Alberta’s Faculty of Medicine and Dentistry. During that time, she also delivered clinical services through Alberta Precision Laboratories and Alberta Health Services.

Though her work spanned two distinct functions, all payments were processed through the university’s payroll, combining academic and clinical compensation into a single income stream. Hume alleges that this structure masked a separate employment relationship and argues she was effectively employed by both the university and Alberta Health Services.

Her legal action followed a 2021 notice that her appointment would not be renewed. She filed suit in 2022, claiming she was either an employee or a dependent contractor of the health agency. A lower court found no genuine issue for trial and ruled the matter was governed solely by the collective agreement between the university and its academic staff association.

Dual-role contracts challenge conventional employment structures

The structure at the heart of the case, a global payment model, has become common in medical faculties. According to court documents, made available via Canadian HR Reporter, more than 600 academic staff at the university hold similar dual appointments. While the collective agreement governs academic duties, clinical services are delivered under separate funding agreements through third-party health entities.

The case raises questions about whether pay structure alone defines the boundaries of employment. Although both pay components are administered through the university, clinical services are funded by Alberta Health Services and delivered under its authority.

The Association of Academic Staff of the University of Alberta (AASUA) sought and was granted intervenor status in the appeal. The union argues that the academic collective agreement does not and should not govern the clinical side of members’ work. In its filings, AASUA said dues are collected only on academic compensation and that the clinical role sits outside its bargaining scope.

Justice D.A. Yungwirth agreed that the union has a direct interest in the case. In her decision, she noted that the appeal’s outcome could affect how faculty contracts are interpreted and applied, particularly for members with dual responsibilities.

Legal test may redefine employee classification in hybrid roles

As more organizations adopt flexible workforce models, the appeal spotlights the friction that can emerge when traditional legal frameworks meet evolving job designs. For employers, it signals the risk of assuming that consolidated payroll or integrated roles equal unified employment; a view the court may now be forced to test.

Justice Yungwirth ruled the union may file written arguments, affidavits and make oral submissions when the case returns to court in September 2026. The union has limited its participation to questions around collective agreement scope and does not intend to remain involved if the case proceeds to trial.

The health agency, in turn, filed a third-party claim against the university, arguing that Hume’s sole employment was with the university and that no parallel relationship existed with Alberta Health Services. That claim was also dismissed in the original ruling.

The global payment structure used in the faculty mirrors models used in other sectors where funding and oversight may come from multiple sources, but administration is centralized. The case may prompt institutions to reconsider how such arrangements are documented and whether role definitions are clear enough to withstand legal scrutiny.

The decision could also have ripple effects beyond healthcare and education. As hybrid workforces grow and professionals take on multi-faceted roles, courts may be asked more often to assess who an employee really works for and which employer bears responsibility when disputes arise.