“an adjudicated administrative decision”, as Doré contemplated,
at para. 4.
 Where what is at issue is the discretionary decision of a
line official, as in this case, and not, as in Doré, “an adjudicated
administrative decision”, the rights claimant caught by the
Doré/Loyola framework faces several serious difficulties.
 Consider the context of this case as an example. In
Ontario, school boards are corporations and have a board of
trustees (sometimes confusingly referred to as the school board),
composed of democratically elected citizens. Boards of trustees
are occasionally required to exercise statutory powers in a natural justice hearing under the aegis of the Statutory Powers Procedures Act, R.S.O. 1990, c. S. 22. However, most school board
decisions are made by its employees, such as teachers, principals
and supervisory officers, as in this case. Sometimes they proceed
in a manner consistent with policy direction from the Education
Act, the Ministry of Education or the board of trustees, and
sometimes they are left to respond to the exigencies of the circumstances without much policy guidance apart from common
sense, and their training and experience. These individuals typically lack Charter expertise.
 At first sight, it seems to be eminently reasonable to
invoke “reasonableness” as the applicable standard of review of
discretionary decisions, as the application judge and my colleague do.
 But some questions emerge. I reflect on several difficulties with the application of the Doré/Loyola approach to a line
 First, in the necessary constitutional analysis, who has
decided that the underpinning statutory objectives are pressing
and substantial? Is the line decision maker competent and qualified to make that constitutional assessment? As I see it, applying
the Doré/Loyola approach to a line decision maker effectively
imports a presumption that the statutory objective on which the
decision rests is always “pressing and substantial”. But this is a
contestable proposition. Not every legislative or policy objective
implemented by a challenged line decision would have this character. But a presumption would effectively reverse the s. 1
Charter onus to the rights claimant’s disadvantage.
 Second, does such a presumption put the rights claimant
in the position of having to challenge the legislative objective in
order to defeat the presumption, when all she wants to do is
challenge a specific decision?