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Social worker found guilty of professional misconduct for inappropriate, unsolicited contact with IPV victim.
The College alleged that the Registrant, a registered social worker, engaged in professional misconduct by making an unsolicited phone call to the estranged spouse of a potential client during a high-conflict separation involving intimate partner violence (IPV) allegations.
The Discipline Committee found that the Registrant failed to conduct appropriate risk screening, initiated contact without consent, and made inappropriate comments minimizing the IPV allegations while urging reconciliation.
The Panel accepted expert evidence that the Registrant's conduct fell below the standards of a reasonably prudent social worker.
The Registrant was found to have engaged in professional misconduct on all four allegations, with his conduct deemed dishonourable and unprofessional.
Veterinarian found to have committed professional misconduct permanently resigns from practice; no further penalty ordered.
The College of Veterinarians of Ontario brought professional misconduct allegations against a member regarding his care of a Great Dane.
The Discipline Committee found the member committed professional misconduct by failing to reassess the dog after diagnostic testing, failing to adequately monitor and treat the dog, failing to communicate with the owner, and failing to maintain proper records.
Following the merits decision, the member retained counsel and entered into a joint submission on penalty, predicated on his undertaking to permanently resign from the profession.
The Committee accepted the joint submission, finding it protected the public interest and obviated the need for further penalty orders.
Substantial indemnity costs were awarded due to an unmet settlement offer and unproven fraud allegations.
This is a costs endorsement following the dismissal of an application to enforce an oral agreement and the granting of an application for partition and sale of property.
The successful parties (Bruno Rosso, Nancy Rosso, and Salvatore Rosso) sought costs awards.
The court awarded costs on a substantial indemnity scale to Bruno and Nancy, and on a partial indemnity scale to Salvatore.
The court considered factors including the complete success of the parties, the complexity of the issues, the proportionality of costs to the property value, the reasonableness of counsel fees and time spent, and the conduct of the unsuccessful party during litigation.
Discriminatory refusal of counselling services amounted to professional misconduct.
In a professional discipline proceeding, the panel found that a social worker committed professional misconduct by refusing counselling services based in part on the complainant's Chinese ethnicity and assumptions about social media use and boundary risks.
Applying the prima facie discrimination framework under the Ontario Human Rights Code, the panel held that the complainant suffered adverse treatment in the provision of services and that the protected ground was a factor in the refusal.
The panel accepted expert evidence on social work boundaries and cultural competence, found that the registrant failed to make adequate inquiries before asserting a boundary conflict, and rejected the registrant's procedural fairness and abuse of process arguments.
Some allegations were dismissed, including those tied to self-determination, referral adequacy, and the intake-form language error, but multiple standards breaches and Code-related misconduct findings were made.
Judicial review of discipline committee decision dismissed; eight-year delay found not inordinate.
The applicant sought judicial review of a Discipline Committee's decision dismissing his motion to stay a professional discipline charge on the basis of delay.
The applicant argued that the eight-year delay in the proceedings amounted to an abuse of process.
The Divisional Court applied the framework for inordinate delay and found that while the delay was lengthy, it was not inordinate when viewed contextually.
Significant portions of the delay were caused by the applicant's own motions or were inherent to ensuring a fair process.
The application for judicial review was dismissed.
Sexual misconduct with a vulnerable client warranted revocation and a five-year reapplication ban.
In a professional discipline proceeding subject to a publication ban, the panel accepted the registrant’s admissions that she entered a personal and sexual relationship with a vulnerable client shortly after providing counselling and psychotherapy services to that client and the client’s spouse.
The panel found professional misconduct based on boundary violations, conflicts of interest, sexual abuse, misuse of confidential information, failure to terminate the therapeutic relationship appropriately, and conduct disgraceful, dishonourable, or unprofessional under the governing statute and regulation.
On a joint submission, the panel imposed a reprimand, revocation of registration, a five-year prohibition on reapplication, publication of the order, and $1,000 in costs.
The panel held the proposed penalty was consistent with public protection, denunciation, and specific and general deterrence.
Motion to lift permanent stay and appoint litigation receiver dismissed due to issue estoppel and incurable prejudice.
The Penfound Parties moved to lift a permanent stay of their claims and counterclaims, which had been imposed after they improperly accessed the Sprott Parties' privileged documents.
They sought the appointment of a litigation receiver and manager, arguing this constituted a material change in circumstances that would detoxify the litigation.
The court dismissed the motion, finding that the proposed remedy was not a new circumstance but an argument that could have been raised during the original stay motion.
The court held that issue estoppel precluded relitigating the appropriate remedy, and regardless, a receiver could not effectively cure the prejudice caused by the moving parties' knowledge of privileged information.
Sexualized boundary violations with a client justified a misconduct finding and reprimand.
In a professional discipline proceeding, the panel found that the registrant committed professional misconduct by breaching boundaries with a client, engaging in sexualized text communications, accepting gifts, and abusing the client within the meaning of the governing statute and regulation.
The panel held that the admitted conduct contravened multiple standards in the profession’s handbook, constituted sexual abuse, and was disgraceful, dishonourable or unprofessional.
A publication ban protected the client’s identity and a sealing order applied to an exhibit brief.
The panel accepted a joint submission on penalty, emphasizing public protection, deterrence, and the principle that a joint penalty submission should be rejected only if contrary to the public interest.
The registrant was reprimanded, his resignation and undertaking not to reapply were noted, publication was ordered, and costs of $5,000.00 were imposed.
Serious boundary and conflict misconduct warranted suspension and remedial ethics conditions.
A discipline panel found a social worker guilty of extensive professional misconduct arising from a prolonged therapeutic relationship with a vulnerable client.
The admitted misconduct included boundary crossings, conflicts of interest involving multiple family members, confidentiality breaches, failure to respond appropriately to dependency and addiction issues, failure to report child protection concerns, improper termination, and inappropriate fee practices.
Applying the public-interest standard for joint penalty submissions, the panel accepted a joint submission imposing a reprimand, a nine-month suspension with a conditional remission component, remedial ethics training, practice restrictions, publication, and costs.
Because of the publication ban, identifying details concerning the client were not reproduced.
The court declared minutes of settlement null and void due to an uncured default, dismissing the motion to enforce.
The case involved a dispute between brothers Domenic, Salvatore, and Bruno Rosso, and their wives, concerning minutes of settlement.
Bruno moved to enforce the minutes, alleging Domenic breached them.
Domenic cross-moved to set aside the minutes, claiming duress, fraudulent misrepresentation, or improvidence, and also arguing they were null and void under a specific contractual clause.
The court found that Domenic and Carmelina (Domenic's wife and a "Settling Party") validly exercised their contractual right under the minutes of settlement to declare them null and void due to an uncured default.
The court dismissed Bruno's motion to enforce and granted Domenic's cross-motion to set aside the minutes of settlement on this contractual basis, rejecting Domenic's other claims of duress, misrepresentation, and improvidence due to lack of credible evidence.
Unauthorized CPIN searches justified suspension and discipline for professional misconduct.
In a professional discipline proceeding, the registrant admitted conducting multiple unauthorized searches in the Child Protection Information Network and improperly accessing confidential records belonging to several child protection agencies.
The panel found that the conduct breached employer confidentiality policies, contravened Part X of the Child, Youth and Family Services Act, 2017, and constituted professional misconduct under the governing statute and regulation.
Accepting a joint submission, the panel imposed a reprimand, a three-month suspension, remedial coursework, practice restrictions and reporting obligations, and publication terms.
The panel also ordered costs of $5,000 payable to the College.
Sexual relationship with vulnerable former client warranted revocation.
In a professional discipline proceeding, the panel found professional misconduct based on admitted boundary crossings with a vulnerable former client in an addiction treatment context, including an intimate and sexual relationship shortly after the counselling relationship, receipt of private aftercare fees, and misuse of a protected professional title before registration.
The panel held that the misconduct reflected on current suitability to practise and supported jurisdiction even though some conduct predated registration.
Applying the public-interest approach to joint penalty submissions, the panel accepted a jointly proposed order imposing a reprimand, revocation, a five-year prohibition on re-application, publication, and costs.
The panel emphasized public protection, deterrence, abuse of trust, and the seriousness of title misuse.
Boundary violations and client exploitation justified discipline and acceptance of a joint penalty.
In a professional discipline proceeding, the panel found professional misconduct arising from an instructor-registrant’s boundary violations with students and a supervisee who were also clients.
The admitted facts established repeated personal disclosures in class, requests for loans and rides, exploitation of information obtained through the professional relationship, and conflicts of interest contrary to the governing statute, regulation, and standards of practice.
The panel held the conduct was dishonourable and unprofessional, though not disgraceful in light of confidential health-related mitigating circumstances.
It accepted a joint submission on penalty as consistent with the public interest, ordering a reprimand, a conditional four-month suspension tied to any future reactivation, remedial training and supervision terms, publication, and $1,000 in costs.
Sexual relationship with counselling client warranted discipline and permanent removal from practice.
Discipline proceeding arising from a registrant’s admitted sexual relationship with a former or active psychotherapy/counselling client, together with related boundary violations and nondisclosure of a prior complaint to another professional body.
The Panel held that the timing dispute over whether the client was still active when the sexual relationship commenced was immaterial because the professional standards prohibited sexual relations at any time following termination where psychotherapy or counselling had been provided.
The admitted misconduct was found to be disgraceful, dishonourable and unprofessional, with significant aggravating factors including the client’s vulnerabilities, enduring psychological harm, and failure to disclose the earlier complaint on registration and renewals.
The Panel accepted a joint submission on penalty as consistent with the public interest and ordered a written reprimand, publication, and costs, in the context of the registrant’s irrevocable surrender and undertaking never to practise again.
Sexual misconduct warranted revocation, reprimand, re-application ban, and $100,000 costs.
Following prior findings of professional misconduct, the Discipline Committee determined penalty in a proceeding involving sexual abuse, sexual boundary violations, and dishonest record keeping affecting vulnerable clients.
The panel proceeded in the registrant’s absence after finding that notice requirements had been met and that the registrant had full notice of the proceedings.
Emphasizing public protection, denunciation, specific and general deterrence, and maintenance of confidence in self-regulation, the panel ordered revocation, a reprimand, a five-year prohibition on re-application or reinstatement, publication subject to an existing ban protecting client identities, and substantial costs.
The panel accepted the College’s submission that partial recovery of prosecution costs was appropriate and ordered payment of $100,000.
Discipline panel found sexual misconduct and false billing proven.
In a professional discipline hearing, the panel found that the member committed repeated boundary violations and sexual misconduct against three vulnerable clients, including prolonged unwanted touching, sexualized comments, coercive conduct, and in one instance forced sexual contact.
The panel also found that the member failed to maintain proper clinical and financial records and issued false invoices in a child’s name to obtain insurance reimbursement for services actually provided to adult clients.
Relying in part on expert evidence on social work ethics, boundaries, documentation, and trauma-informed practice, the panel held that the conduct breached multiple provisions of the governing statute, the Professional Misconduct Regulation, and the Standards of Practice Handbook.
All allegations in both Notices of Hearing were proven on a balance of probabilities.
Sexual misconduct with a client justified revocation and a five-year reinstatement bar.
In a professional discipline hearing subject to a publication ban, the member admitted boundary violations and sexual conduct with a vulnerable client following the provision of counselling-related social work services.
The Panel found professional misconduct under the governing statute and regulation, including sexual misconduct, failure to maintain proper boundaries, failure to prioritize the client's interests, and recordkeeping failures.
The Panel accepted a joint submission on penalty, holding that departure was unwarranted absent a risk to public confidence in the discipline process.
The member was reprimanded, her certificate of registration was revoked, reinstatement was barred for five years, publication was ordered, and costs of $3,000.00 were imposed.
Claims permanently stayed as abuse of process due to unauthorized access to opposing party's privileged documents.
The moving parties (Sprott Parties) sought to stay the responding parties' (Penfound Parties) claims as an abuse of process after discovering the responding parties had unauthorized access to and reviewed privileged emails and documents belonging to the moving parties.
The court found that the responding parties obtained access to confidential and privileged information and failed to rebut the presumption of prejudice.
Concluding that allowing the action to proceed would be manifestly unfair and bring the administration of justice into disrepute, the court permanently stayed the responding parties' claims.
Sexualized boundary breaches and chronic recordkeeping failures amounted to professional misconduct.
A discipline panel found that the member committed professional misconduct by making sexualized comments to a vulnerable counselling client, pursuing sexual topics after the client expressed discomfort, and disclosing intimate details of his own sexual history.
The panel also found longstanding and serious failures to maintain required clinical documentation, including progress notes, psycho-social assessments, and treatment plans across multiple files.
Applying the balance of probabilities standard, the panel accepted the evidence of the client and corroborating witnesses as clear, cogent and convincing.
All allegations of professional misconduct were proven.
Member suspended for 9 months and ordered to pay $10,000 in costs for professional misconduct.
The member faced allegations of professional misconduct including insurance fraud, failing to maintain records, altering and losing patient records, falsifying bank statements, and attempting to bribe a College investigator.
The member admitted to the allegations and the Discipline Committee found that the conduct constituted professional misconduct.
The Committee accepted a joint submission on penalty, ordering a reprimand, a 9-month suspension, practice conditions including ethics and record-keeping courses, and $10,000 in costs.