The Assembly of Manitoba Chiefs filed its written submissions in its challenge of the provincial Budget Implementation and Tax Statutes Amendment Act. The submissions of the AMC argue that through the BITSA, Manitoba:

• infringes the core jurisdiction of the superior courts and breaches section 96 of the Constitution Act, 1867 by having the province of Manitoba absolving itself from any liability and denying First Nations children in care the right to access the courts;
• denies First Nations children substantive equality and equal benefit of the law on the grounds of age, race, aboriginality-residence and family status, in which the BITSA is contrary to section 15 of the Canadian Charter of Rights and Freedoms;
• denies First Nations the rights, benefits and opportunities promised to First Nations children in care by Canada pursuant to s. 91(24) of the Constitution Act, 1867 and is therefore beyond the province’s constitutional authority; and
• violates the honour of the Crown and breaches its fiduciary duty owed to First Nations children in care