Plamondon Libel Case

Early 20th-Century Antisemitism in Quebec

Around the early 20th century, Quebec experienced a period of increased antisemitism . This was also the case overseas in France and the United States. In Quebec, a clerical-nationalist elite fostered antisemitic attitudes, possibly in reaction to increased Jewish immigration. They criticized the presence of Jewish people in public spaces. It was also common for Catholic priests to spread antisemitic misinformation. Some warned their parishioners against renting to Jews. Antisemitism commonly took the form of physical violence, media attacks, and public lectures, among other petty insults and discrimination.

Jacques-Édouard Plamondon’s Speech

On 30 March 1910, a respected Quebec City notary, Jacques-Édouard Plamondon, gave a speech to a Catholic youth group at the Collège des frères des Écoles chrétiennes. The school was located near the city’s small Jewish community in the Saint-Roch neighbourhood. At the time, there were between 60 and 75 Jewish families living in Quebec City. They were mostly of Romanian origin and had recently settled in the city.

Plamondon’s lecture was inspired by antisemitic texts published in France in the latter half of the 19th century. In his speech, Plamondon described Jews as morally debased and parasitic as well as being a threat to Christians. Plamondon stated that “the Jew, by his beliefs and by his acts, is the enemy of our faith, of our life, of our honour, and of our property.” Most of his lecture denounced sections of the Talmud, reflecting common antisemitic stereotypes. He further attacked the Jewish community for not observing the Catholic Sabbath (Sunday, as opposed to Saturdays, the Jewish Sabbath). Plamondon insisted that his listeners boycott Jewish businesses. His lecture was later published in La Libre Parole, a publication Plamondon edited and co-founded, and in pamphlet form.

Much of Quebec City’s Jewish community had fled pogroms and persecution in Eastern Europe. The community was quite familiar with Plamondon’s hateful allegations and stereotypes.

Some historians believe that Plamondon’s hatred of the city’s Jewish community may have begun as a personal vendetta against Jewish businessperson David Liebling. Apparently, Plamondon’s cousin had fallen behind on mortgage payments on a St. Joseph Street property that Plamondon used as his office. He had to relocate his business after Liebling foreclosed the property.

Consequences of the Plamondon Lecture

After the speech, Quebec City’s Jewish population was harassed by youth who repeated Jacques-Édouard Plamondon’s accusations. Meanwhile, the speech’s content became the subject of debate in local newspapers. Other incidents included beatings, stones being thrown at Jews and verbal harassment. People also broke windows of Jewish homes, businesses and the synagogue. The Jewish community was afraid to leave their homes. Several young men were arrested for the violence they caused.

For instance, a dozen youths beat up David Ortenberg, who they believed was a rabbi. Though he found refuge in his own home, it was pelted with stones. He fled and was mobbed and beaten again, the crowd trying to tear off his beard. In another case, Louis Lazarovitch’s young son was kicked in the abdomen while playing in the street during the same wave of antisemitic violence.

Notably, Lazarovitch (also spelled Lazarovitz) was a merchant who had resided in Quebec City since 1888. He was also president of the Bais Israel Congregation. Prior to Plamondon’s speech, Lazarovitch had asked the chief of police to intervene to prevent the lecture but was told nothing could be done. Instead, Lazarovitch hired a stenographer to attend the lecture and record what was said.

Trial and Result

Prior to initiating his lawsuit, David Ortenberg’s son, Benjamin, wrote to Jacques-Édouard Plamondon, offering him $500 if he could prove his speech’s accusations. Ortenberg’s ultimatum was that Plamondon should publish a retraction or face a lawsuit. Plamondon did not reply.

On 27 April 1910, Louis Lazarovitch and Benjamin Ortenberg initiated legal proceedings against Plamondon and his publisher, René Leduc. Lazarovitch and Ortenberg received the financial assistance of Montreal’s Jewish community. They also benefitted from the legal support of lawyers Samuel William Jacobs and Louis Fitch. In May 1913, they appeared before Quebec Superior Court Judge Albert Malouin.

Ortenberg and Lazarovitch demanded reparations for damages they claimed happened as a result of Plamondon’s call for a boycott of Jewish businesses. They claimed to have lost over $6,000, which would be worth about $160,000 in 2024. The plaintiffs requested $500 from Plamondon and Leduc. The small sum was likely because a larger claim would have necessitated a jury trial, which they felt they would lose.

Ortenberg made two arguments: first, that Plamondon’s allegations about Jews and the Talmud were categorically false; and second, that his business had suffered due to Plamondon’s lecture. Ortenberg argued it was Plamondon’s intent to cause harm to himself, his business and the rest of Quebec City’s Jewish community.

Rabbi Herman Abramowitz came in as a witness to describe the dangers posed by antisemitic tirades. He drew a parallel between the Plamondon speech and the troubles experienced by Jews in Europe.

Ortenberg also stated that he knew Plamondon personally. Despite this, Plamondon claimed that he wasn’t acquainted with either him or Lazarovitch. Instead, he argued that his speech referred to all Jews, not specifically to the Jewish community of Quebec.

On 22 October 1913, Justice Malouin dismissed the case, siding with Plamondon’s argument that he was speaking of Jews in general. Because of this factor, the judge refused to consider the other aspects of the case. This was in keeping with the case law of the era, which held that an individual had to demonstrate they were the specific target of defamation in order for speech to be considered libellous. Ortenberg appealed the decision immediately.

On appeal, the case was heard by Quebec Chief Justice Horace Archambeault and four judges. The judges determined that members of a community were entitled to sue for libel or slander if they were a small group since individuals within that group could suffer. Plamondon and Leduc were ordered to pay court fees and fines of $50 and $25 respectively, in a judgment made on 28 December 1914. The court’s ruling vindicated Ortenberg and Lazarovitch’s claims.

Consequences and Legacy

In the immediate aftermath of the case, Quebec City’s Jewish population fell in number ― the only major city in Canada where a net loss in Jewish population was recorded. La Libre Parole ― the newspaper where Jacques-Édouard Plamondon published his antisemitic writings ― stopped publishing a few months before the first trial began.

Meanwhile, René Leduc’s political ambitions fell apart amidst a series of scandals. Four years after the appellate decision, Jacques-Édouard Plamondon was convicted of embezzlement. Given the choice between pleading insanity or going to prison, he chose to follow the advice of the priests who were defending him. He spent several years in an asylum.

While Ortenberg and Lazarovitch won their case, it didn’t lead to the creation of anti-hate speech laws or other rulings against antisemitism in Canada. The affair showed how engrained hate speech and racial prejudice were in Canadian society. It also demonstrated that a considerable effort was needed to win even modest judgments against antisemitism. That said, an important precedent had been established — it was possible to fight back using the legal system and win. The Plamondon case provided a legal basis to fight back.

The question of antisemitism in Quebec remained a hotly contested issue, even nearly a century later. In 1990, when scholar Esther Delisle presented her doctoral dissertation on pre-Second World War antisemitism in Quebec, it caused a major scandal. (See Delisle-Richler Controversy.)