A lawyer challenged a disciplinary reprimand imposed after a private letter to a judge containing abusive personal attacks.
The appeal required the court to determine the proper review framework where discretionary administrative decisions engage Charter expression values.
The court held that judicial review proceeds on reasonableness, with proportional balancing of Charter values and statutory objectives, rather than a full Oakes section 1 analysis.
Applying that framework, the reprimand reflected a proportionate balance between expressive freedom and professional civility obligations.
The appeal was dismissed with costs.
