In a recent BBC article, “Quiet quitting is the status quo. Workers are still proud to do the bare minimum,” journalist Kate Morgan^[1] traced the term’s cultural surge back to autumn 2022, when TikTok creator Hunter Ka’imi appeared on the U.S. talk show Dr. Phil to defend his now-viral video about doing exactly what you’re paid for—no more, no less. Ka’imi’s message, distilled into the phrase “quiet quitting,” struck a chord with millions online and reframed the practice as setting boundaries rather than slacking off. What began as a social-media moment became a lightning rod in the global debate over work ethic, employee disengagement, and the future of workplace expectations. Against that cultural backdrop, the Canadian legal system has been quietly developing its own response—through constructive dismissal law and recent return-to-office cases—when these shifting attitudes meet contractual obligations.

“Quiet quitting” may be the workplace buzzword of the moment, but there’s nothing new about employees doing only what their job descriptions require — and nothing more. The phrase captures a cultural shift, particularly in the wake of COVID-19, where workers consciously decline the unpaid overtime, extra responsibilities, or constant “above and beyond” that were once expected. For some, it’s an act of self-preservation. For others, it’s a symptom of disengagement.

In Canadian employment law, quiet quitting is not a legal category. There is no statute or reported decision using the term. But when it leads to conflict, it quickly intersects with well-established legal principles — especially constructive dismissal. And here, recent cases are already showing how courts might approach disputes rooted in an employer’s reaction to perceived quiet quitting.

The Legal Framework: Constructive Dismissal Principles

The starting point is Farber v. Royal Trust Co., [1997] 1 S.C.R. 846^[2]. The Supreme Court of Canada held that constructive dismissal occurs where an employer makes a unilateral and substantial change to a fundamental term of employment, or otherwise shows an intention not to be bound by the contract. The change must be such that a reasonable person in the employee’s position would view it as a breach.

Wronko v. Western Inventory Service Ltd., 2008 ONCA 327^[3], confirmed that where an employer gives notice of a fundamental change, an employee can either accept, reject and continue under protest, or treat the relationship as terminated. What an employer cannot do is impose a significant change without consent or proper notice.

And in Potter v. New Brunswick Legal Aid Services Commission, 2015 SCC 10^[4], the Supreme Court expanded the doctrine to include situations where an employer’s conduct — even without an explicit change to terms — demonstrates an intention to no longer be bound by the employment contract, such as through an indefinite suspension without justification.

These principles form the backbone of constructive dismissal law. The question for quiet quitting scenarios is whether an employer’s response — whether overt or subtle — can amount to such a change.

Recent Cases Illustrating the Risk

In Byrd v. Welcome Home Children’s Residence Inc. (2024 ONSC, Small Claims Court)^[5], the employee had worked remotely from Belgium for about 20 months while her spouse was posted overseas, with no clear agreement that she could be recalled to Canada. In January 2022, the employer unilaterally reduced her hours to 15 per week without prior agreement and stripped away most of her responsibilities. A few weeks later, through counsel, the employer told her she would be expected to return to in-person work in Ontario. The court found that remote work had become an accepted part of her role and that the combination of reduced hours, loss of duties, and the eventual in-person requirement amounted to unilateral and fundamental changes to essential terms of her employment. Applying the tests from Farber and Potter, the court concluded she had been constructively dismissed.

In Nickles v. 628810 Alberta Ltd. (2025 ABKB 212), the Alberta Court of King’s Bench dealt with a 37-year employee who had worked from home for her entire career, attending the office only when she chose to. New ownership gave her less than three months’ notice that she would be required to work full-time in the office. She objected, noting this was not a “return” to the office but a fundamental change to her job. The employer offered a compromise — 2.5 days per week in the office — but with a proviso allowing them to increase office time later. The court found that the work-from-home arrangement was an integral term of the contract, and that imposing a fixed in-office schedule without proper notice was a constructive dismissal. Citing Wronko v. Western Inventory Service Ltd., the court held the plaintiff was not obliged to accept the 2.5-day compromise as mitigation, since it still reserved the employer’s ability to impose the original, disputed change.

Parolin v. Cressey Construction Corporation (2025 BCSC)^[6] combined two significant changes: revoking a long-standing flexible schedule and imposing a de facto demotion. The court held that this combination fundamentally altered the employment relationship and breached the contract. The reasoning mirrors Farber in treating multiple changes cumulatively and reflects Potter’s warning that an employer’s broader course of conduct can be just as decisive as any single change.

Finally, Hagholm v. Coreio Inc. (Ontario Court of Appeal)^[7] predates the pandemic but remains a leading authority on long-standing remote work arrangements. The employee had, for more than two decades, worked from home three days a week under an agreed arrangement, and this had become an essential term of her contract. The employer, shortly after acquiring the business, sought to end the arrangement and require full-time in-office attendance — while also unilaterally reducing her contractual bonus. The Court of Appeal upheld the finding of constructive dismissal on both grounds and confirmed she was not required to mitigate by returning when the employer had breached a major term and showed no intention of restoring it. The case illustrates, in line with Farber and Wronko, that a term which has become integral to the relationship over time cannot be altered without the employee’s agreement.

What This Means for Quiet Quitting Disputes

While none of these cases involved an employee who was “quiet quitting” in the cultural sense, they illustrate a clear principle: once a working arrangement — whether it’s location, schedule, or role — becomes an essential term, the employer cannot unilaterally change it without risking a constructive dismissal finding. If an employer responds to perceived quiet quitting by reassigning an employee to less desirable duties, changing work location, or cutting hours without consent, the same analysis from Farber, Wronko, and Potter applies.

Employees who quietly reduce discretionary effort are not immune from lawful termination without cause, provided the employer gives proper notice or severance. But if an employer’s “solution” is to make the job intolerable or substantially different in hopes the employee will resign, that strategy risks converting a manageable HR issue into a costly legal claim.

The Bottom Line

The courts in Canada will not adopt “quiet quitting” as a legal category — they don’t need to. The established constructive dismissal framework already governs the disputes it generates. Byrd, Nickles, Parolin, and Hagholm are simply the latest illustrations of how Farber, Wronko, and Potter principles play out in the modern workplace. For employers, the safest path is clear communication, explicit job expectations, and direct performance management. For employees, understanding your contractual rights — and the risks of resignation — is key.

And for both sides, mediation remains a valuable tool to address the underlying causes of disengagement before they escalate into litigation. Quiet quitting may be cultural shorthand, but the law that applies to it is anything but quiet — it is clear, established, and adaptable.