" While Connor Homes is an Ontario case and the test in article 2085 of the Civil Code is subordination, which is different from the common law test, Grimard makes it clear that, in determining whether or not there is subordination, juridical subordination, the common law tests are useful indicia in determining whether there is subordination.
 ... 'In practice, one looks for a number of indicia of supervision that may, however, vary depending on the context: compulsory attendance at a workplace, the fairly regular assignment of work, imposition of rules of conduct or behaviour, requirement of activity reports, control over the quantity or quality of the work done, ownership of tools, chance of profit, risk of loss and so on. Work in the home does not preclude this sort of integration into the business.'"
Another interesting focus of J. Jorre: He distinguishes contract terms imposed by the clients, rather than by the appellant French langugage provider. Externally imposed terms, which the supplier passes on to its workers, are consistent with independent contractor relationships.
" Not every request made by the appellant stemmed from the CBC contract directly. For example, at one point the appellant learned that a number of students who were studying French as a second language had expressed a desire to learn expressions used in Quebec so as to better communicate with their colleagues and the appellant supplied some material with Quebec expressions to the teachers of French as a second language and asked them to use it.
" This last example was a decision resulting from a request by students rather than by the CBC, which was paying for the service, but it was still an externally driven instruction rather than an internally driven one originating with the appellant."
So, J. Jorre found that each of the instructors was an independent contractor.
See Enseignants de langue anglaise de Montréal. v. M.N.R., 2014 TCC (Jorre)