The applicant, a registered clinical psychologist, sought judicial review of a decision by the College of Psychologists of Ontario's Inquiries, Complaints and Reports Committee (ICRC) ordering him to complete a specified continuing education or remedial program (SCERP) regarding professionalism in public statements.
The ICRC's order followed an investigation into the applicant's social media posts and public statements, which the committee found posed moderate risks of harm to the public and the profession.
The Divisional Court dismissed the application, finding that the ICRC reasonably balanced the applicant's Charter right to freedom of expression with the College's statutory mandate to regulate the profession in the public interest, in accordance with the Doré framework.
The Court also held that the ICRC's decision met the Vavilov standard of justification, transparency, and intelligibility.