CITY OF Peterborough Integrity COMMISSIONER, Guy Giorno

Citation: Trent Central Student Association et al. v. Leal, 2025 ONMIC 11 Date: December 22, 2025

INQUIRY Report

Notice: Municipal Integrity Commissioners provide investigation reports to their respective municipal councils and, in some cases, make recommendations for imposition of penalty or other remedial action to the municipal councils. Therefore, reference should be made to the minutes of each particular municipal council to obtain information about the particular council's consideration of each report. When possible, a link to the relevant municipal council minutes is provided.

Please find below the link to the corresponding council decision.

https://pub-peterborough.escribemeetings.com/filestream.ashx?DocumentId=41550 (City Council Minutes, January 19, 2026, p. 5)

TABLE OF CONTENTS

The Complaints. 3

Timing. 3

Summary. 3

Background. 4

Process. 10

Positions of the Parties. 12

Complainants’ Positions. 12

Respondent’s Position.. 17

Findings of Fact 19

Issues and Analysis. 20

A. Did the Mayor’s apology resolve the need for an inquiry?. 21

B. Did the Mayor breach section 10 of the Code?. 21

Recommendations. 26

Content 26

The Complaints

1. The Trent Central Student Association, the Afrocentric Awareness Network of Peterborough, Ms Jennifer Avis, Ms Deborah Berrill, Ms Cynthia Budgell, Mr. John Hauser, Ms Anna and Mr. Iain Jamieson, Mr. Jeffrey Macklin, Ms Sarah McNeilly, and Ms Patricia Sullivan (Complainants) separately filed Complaints alleging that Mayor Jeff Leal contravened the City of Peterborough Council Code of Conduct, By-law Number 19-028, during remarks to Trent University students on March 19.

2. Nine Complaints were received between April 7 and April 16. The Complaint of the Afrocentric Awareness Network of Peterborough was received June 20. The Complaints were collectively numbered 2025-03-CC.

3. The Afrocentric Awareness Network of Peterborough included with its Complaint a change.org petition with more than 800 signatures.

Timing

4. I issue reports based on the order in which complaints are received. Since issuing the joint report in the Therrien-Hale et al. v. Leal and Lachica v. Leal inquiries, 2025 ONMIC 4, I have moved promptly to complete the remaining reports.

Summary

5. The N-word is an odious, vile, dehumanizing racial slur.

6. All parties, including the Respondent, agree that the Respondent’s March 19 comment was inappropriate and should not have been made.

7. The sole question in the inquiry is whether what occurred on March 19 was covered by and contrary to the Council Code of Conduct.

8. The Code as presently drafted does not cover the incident. However, the Code can be amended.

9. Any resident is free to call for the Mayor to resign but removal from office is not presently a possible outcome of an Integrity Commissioner inquiry.

Background

10. Dr. Wanda Thomas Bernard, an expert in anti-Black racism, has given evidence before the British Columbia Human Rights Tribunal. Dr. Bernard’s evidence on the N-word was summarized by the BCHRT as follows:

The N-word arises out of the history and legacy of slavery. It is used to further to dehumanize slaves and make them feel worthless and undervalued. Slave owners didn’t have to learn the slaves’ names, just use the N-word so that they were not individualized. Today when that word is used, it conjures up a lot of painful memories, rage and anger. The word is associated with slavery.¹

11. Dr. Arig al Shaibah and Sophie Poinar describe the N-word as “not only disrespectful and distasteful, but also profoundly dehumanizing.”²

12. More simply, the N-word is “a virulent and egregious racial slur aimed at dehumanizing Black people.”³

13. Last year, the rate of police-reported hate crime in Peterborough was nearly double the national rate, and 34 per cent higher than the rate in Ontario overall.^{4 5}

14. Over the last five years, the frequency of reported hate crime in Peterborough was roughly triple the frequency during the five years prior.⁶

15. According to the RCMP, the highest level of targeting by hate crime from 2020 to 2024 was experienced by Canada’s Black population.⁷

16. Since 2019, Peterborough has belonged to the Coalition of Inclusive Municipalities (formerly Canadian Coalition of Municipalities Against Racism and Discrimination).⁸ The coalition is “a network of cities seeking to improve policies against racism, discrimination, exclusion and intolerance.”⁹

17. Member municipalities embrace “Ten common commitments.” These include: “Providing increased vigilance against systemic and individual racism and discrimination” and “Monitoring racism and discrimination in the community broadly and taking action to address them.”¹⁰

18. The Respondent, Mayor Jeff Leal, has broad experience in the private sector and government. He is a graduate of Trent University (economics and political science) and the University of Windsor (business administration). He was formerly employed as a health and safety representative for Coyle Corrugated Containers. He was elected to six terms as Alderman/Councillor. During 15 years as an MPP, he served as Minister Responsible for Small Business, Minister of Agriculture, Food and Rural Affairs, Chief Government Whip, Parliamentary Assistant to the Minister of Energy, and Parliamentary Assistant to the Minister of Economic Development and Trade, among other roles. He was elected Mayor in 2022.

19. On March 19, Mayor Leal was an invited speaker and addressed students in the Management Skills (ADMN-2010H-A) course of Trent University.

20. The course syllabus for ADMN-2010H-A: Management Skills describes the March 19 class as follows:

Two experienced managers will present on their own viewpoint on The Importance and Relevant Management Skills and Strategies Required to be a Successful Manager [emphasis added]

21. The bolded words indicate that the Mayor was there to present personal reflections based on his extensive career experience as a manager. He was not speaking to the class as a representative of the City.

22. During his career, the Mayor displayed a passion for political history, often quoting from past leaders and drawing comparison to past events. In the Ontario Legislature, he was known to quote Canadian Prime Ministers John Diefenbaker and Lester Pearson, Ontario Premier Bill Davis, U.S. Presidents Franklin Delano Roosevelt and John F. Kennedy, British Prime Ministers Benjamin Disraeli and Winston Churchill, and more. Sometimes, he would complete or correct the historical quotations used by others. His remarks were frequently populated with anecdotes drawn from the political history of Canada, Ontario, the United States, and the United Kingdom.¹¹

23. On March 19, while speaking to the Management Skills class, the Mayor mentioned Lyndon Johnson, 36th President of the United States. While many people have reported the Mayor’s words, I am relying not on their reports but on my personal consideration of the audio recording.

24. My review of the audio recording indicates that the Mayor said the following:

Lyndon Johnson was an FDR New Dealer.¹² He came out of the hills of Texas. He used this language that you would never use today, and he talked about the poor [N-word plural] and Mexicans that he taught Sunday school to.

25. After the lecture, students raised concerns with the professor and the university. The Mayor issued an apology through the instructor.

26. Outside the classroom, the Mayor’s comment appears not to have attracted attention until he issued the public apology set out below.

27. On April 7, I received the first Complaint, from the Trent Central Student Association. By the time the Mayor issued a public apology the next day, I had not yet processed the Complaint or informed the Respondent (Mayor).

28. Mayor Leal released the following apology to the news media, April 8:

During a recent guest lecture at Trent University, I quoted a historical remark attributed to former U.S. President Lyndon B. Johnson from his time as a congressman in the 1930s. In doing so, the quote that I used included a racial slur that is deeply offensive and hurtful.

I sincerely apologize. Regardless of the context or intent, using that word was wrong. I recognize the pain it carries and the responsibility I have to speak with care and respect. I apologize to Trent students and faculty, to Trent University, and to my community.

I believe in building a welcoming and inclusive community. I did not contribute to the betterment of my community when I used that quote – when I said those words.

I am committed to listening, learning, and doing better.

29. The text of the apology posted on the City website omitted the last sentence:

During a recent guest lecture at Trent University, I quoted a historical remark attributed to former U.S. President Lyndon B. Johnson from his time as a congressman in the 1930s. In doing so, the quote that I used included a racial slur that is deeply offensive and hurtful.

I sincerely apologize. Regardless of the context or intent, using that word was wrong. I recognize the pain it carries and the responsibility I have to speak with care and respect. I apologize to Trent students and faculty, to Trent University, and to my community.

I believe in building a welcoming and inclusive community. I did not contribute to the betterment of my community when I used that quote – when I said those words.

30. The same day, Trent University issued its own statement:

Trent University is releasing this statement in response to an incident which took place in a business administration class. During a guest lecture, as an invited speaker, the Mayor of Peterborough referenced the writings of an historical figure who used racist language. In doing so, the Mayor repeated a racial slur. Thank you to the students who came forward to express their concerns. The Mayor has since delivered a written apology to the class and released a public apology.

The University acknowledges that it is unacceptable to use racist language, regardless of context. We affirm that the University prohibits all forms of discrimination, harassment, racism and hate as per our policies. We apologize for the harm this caused to our students and recognize that words (racial slurs) can have lasting impacts on racialized students.

In an effort to ensure that such an occurrence is not repeated, the University will extend our equity, diversity, inclusion, and anti-Black racism training to invited speakers. We will confirm that invited speakers are informed of our policies and joint responsibility to ensure a safe and respectful learning environment free from all forms of racism and hate.

The University is dedicated to promoting a diverse, equitable, and inclusive campus that ensures that all students, staff, faculty and community members are included, safe and supported.

Should students or others in our campus community need support, please reach out. Assistance and resources are available to you. The Equity and Human Rights Office also offers support and has learning resources available.

31. The Trent Central Student Association issued a statement, April 9, that referred to its April 7 Code of Conduct Complaint:

The Trent Central Student Association is deeply saddened by the actions of Peterborough Mayor Jeff Leal when visiting our campus. On March 19th, 2025, Mayor Jeff Leal attended a Trent business class as a guest lecturer and used the N-word within his speech. Furthermore, he expressed racist sentiments that demeaned both the Black and Mexican communities. The City of Peterborough should hold its mayor to a higher standard. In response, the TCSA has filed a complaint to the Peterborough Integrity Commissioner regarding this incident.

The Trent Central Student Association calls on Trent University to:

• Provide assurance that Mayor Jeff Leal will not be invited back to campus.

• Ensure a BIPOC member of Trent staff conducts DEI and Anti-Black racism training for guest speakers.

• Guarantee that future guest lecturers are properly screened and their content is reviewed before being presented to students.

The Trent Central Student Association calls on the City of Peterborough to:

• Conduct a review from the City of Peterborough's Integrity Commissioner on the conduct of Mayor Jeff Leal in line with the Peterborough City Council Code of Conduct: Conduct Respecting Others: Section 10, Subsection A & B

• Mandate all City Councillors and City staff to receive anti-racism, diversity, equity, and inclusion training.

• Review and amend their 2023-2050 Strategic Plan to include anti-racism and race relations as a strategic priority under their Community and Wellbeing pillar. This should include but is not limited to addressing anti-Black racism, anti-Indigenous racism, anti-Asian racism, xenophobia, anti-immigrant sentiments, anti-semitism, and Islamophobia within the Peterborough community.

The TCSA will be hosting a sit-in at City Hall on Monday, April 28th, 2025, at 5:00pm; we invite Trent students and Peterborough community members to join us. We urge Peterborough residents to consider the values of the people representing them. Individuals who spread hate do not deserve to hold political power. Anyone wishing to express their dissent can contact the Mayor’s office at (705) 742-7777 ext. 1870 or email cityptbo@peterborough.ca.

Yours in solidarity,

The TCSA Executive Team

32. The Afrocentric Awareness Network of Peterborough also issued a statement:

At a recent Trent University business lecture, Mayor Jeff Leal was invited as a guest speaker. During his speech, he casually used an anti-Black racial epithet.

This use of a dehumanizing slur is a direct affront to Black people in Peterborough and beyond. As Mayor, he sets the tone for the City – and his use of that word sends a chilling message: that Black people are not welcome here.

Mayor Leal’s word was painful and harmful. By using such a charged racial slur, he normalized it, implicitly permitting others to spread similar contempt, disdain, and hatred – especially toward Black communities.

It is deeply troubling to see the leader of our City express such regressive, outdated values in today’s society. Hearing the recording of him saying the word so casually is proof that racism is far from behind us.

We are living in a time where overt racial slurs are resurfacing, emboldened by the divisive rhetoric spilling over from the politics of our southern neighbours. And it’s not just adults – children are being targeted with painful racial insults too.

To make matters worse, Mayor Leal attempted to downplay his word choice by claiming he was quoting someone else. But he wasn’t quoting — at best, he was paraphrasing. Even more troubling, he used the slur immediately after stating that it was no longer acceptable language, which indicates he understood it was inappropriate.

So, how did he go from discussing business to veering off-topic and using an anti-Black slur? His public apology only came after complaints were submitted — and even then, it took him three weeks to issue it. This delayed response feels more like damage control than genuine remorse. His reluctance to apologize speaks volumes.

Mayor Jeff Leal should resign.

The fact that he could say such a word aloud to a group of people reflects what he may be thinking and saying behind closed doors. What he says in public could very well mirror what he says in private. He does not have the right to use such a hurtful, harmful slur and walk away without consequence.

He should step down because he no longer represents the inclusive, diverse, and welcoming Peterborough we strive for. This is Canada. Racist language and behaviour have no place in our public institutions – especially not from the leader of our City.

There must be accountability. There must be consequences.

What Mayor Leal did was irresponsible and harmful.

The Afrocentric Awareness Network of Peterborough (AANP) will be joining the Trent Central Student Association’s sit-in at City Hall on April 28th (5 p.m.) to stand against this injustice.

The N-word is degrading, dehumanizing, and alienating. Peterborough should not be associated with it. This is not the Peterborough we know or believe in.

33. The Trent Central Student Association and the Afrocentric Awareness Network of Peterborough protested the Mayor’s comment outside City Hall on April 28.

Process

34. Most Complainants want the Mayor to resign. While any resident is free to call for the Mayor to resign, removal from office is not presently a possible outcome of an Integrity Commissioner inquiry. Bill 9, the Municipal Accountability Amendment Act, 2005, would permit removal from office in certain circumstances, but it is not yet law.

35. In operating under the Code, I follow a process that ensures fairness to both the individuals bringing the Complaints (the Complainants) and the Council Member responding to the Complaints (the Respondent). This fair and balanced process begins with me issuing a Notice of Inquiry that sets out the issues in the inquiry. The Complaints, including any complaint materials, are attached to the Notice. The Respondent is given the opportunity to respond and then, typically, the Complainants may reply to that Response. The Respondent is made aware of the Complainants’ names. I do, however, redact personal information such as personal phone numbers and email addresses. I may accept supplementary communications and submissions from the parties, generally on the condition that each party gets to see the other’s communications with me. I do this in the interest of transparency and fairness.

36. In the circumstances of this case, I modified my typical process to be fair while also efficient. The fact of the Mayor’s comment is not disputed, and the only issues are whether the Mayor’s apology resolved the matter, whether the Council Code of Conduct covers the comment and, if so, whether the Code was contravened. The modified steps and reasons for adopting them are described starting at paragraph 41, below.

37. I received the Trent Central Student Association Complaint on April 7. From April 10 to April 16, I received eight additional Complaints. I assigned all of them the collective file number 2025-03-CC and lettered the individual Complaints A through J.¹³

38. The Afrocentric Awareness Network of Peterborough Complaint was received June 20, and assigned letter K.

39. Under section 223.4 of the Municipal Act, an inquiry into the Complaints is not automatic. Subsection (1) uses the words, “if the Commissioner conducts an inquiry …” The Divisional Court has confirmed that whether to commence an inquiry lies within the Integrity Commissioner’s discretion.¹⁴

40. I exercised my discretion to conduct an inquiry. On April 17, I issued a Notice of Inquiry that identified the following issues:

A. Does the Mayor’s April 8 statement [apology] resolve the need for further proceedings?

If not, then:

B. Did the Mayor breach section 10 of the Code of Conduct on March 19?

C. What recommendations, if any, should the Integrity Commissioner make to Council?

41. The allegation about inability to pronounce the Anishinaabemowin name “Nogojiwanong” correctly was not included in the inquiry as it is outside of scope and jurisdiction.

42. I amended the Notice on April 19. The only amendment was to add, to the section where I quoted the Mayor’s apology, the final line of it. The original Notice was based on the posted apology and did not include its last sentence: see paragraphs 28-29, above.

43. I invited the Complainants to address issue A by April 28.

44. I also invited the Complainants, by April 28, to address issues B and C, but I explained that that it was unnecessary for them to repeat the content of the original Complaints as it was already going to be considered.

45. Finally, I stated that if any Complainant possessed evidence (that is, facts) relevant to the issues, or if any Complainant knew of someone who might possess evidence relevant to the issues, then the Complainant was invited, by April 28, to provide the evidence (or the name and contact information of the potential witness) to me.

46. I informed the Complainants that anything I received from them would be considered by me in the inquiry and would be shared with the Respondent so that he would have an opportunity to address it.

47. Concerning evidence and potential witnesses: I reminded the parties that the Mayor had already acknowledged what he said, and (at the time of issuing the Notice) I was not aware that any interviews would be necessary. Nonetheless, I invited the parties to bring any relevant evidence or witnesses to my attention.

48. Concerning the sharing of submissions: I explained that I was sharing the Complainants’ submissions with the Respondent, because fairness requires that the person who is the subject of allegations know them and receive the opportunity to respond. On the other hand, I said I would not share the Complainants’ submissions or the Mayor’s submissions among the Complainants, or allow one Complainant to reply to another Complainant or the Mayor. In my view, that would be unwieldy and unnecessary, as I could fairly investigate the Complaints and examine the issues, after receiving the Complainants’ submissions and allowing the Mayor to respond.

49. Most of the nine Complainants (at this point, the tenth Complaint had not yet been received) felt the Mayor’s apology was insufficient and wanted the inquiry to continue.

50. I received some additional evidence, such as evidence about the accuracy of the comment and about impact, but I received nothing that caused me to find that interviews of the parties or any witnesses would be relevant, useful, or necessary.

51. I did receive further submissions from some Complainants concerning application of the Code and concerning recommendations that might be made to City Council.

52. I received written and oral submissions from the Mayor.

53. I have considered all the material submitted by the Complainants and the positions of the Complainants and the Respondent. I have considered the audio recording, all the evidence provided to me and the results of the research summarized in this report.

Positions of the Parties

Complainants’ Positions

54. Two Complainants argue that paragraph 10 a) of the Code was breached;¹⁵ five assert a contravention of paragraph 10 b);¹⁶ three believe that the Mayor violated paragraph 10 c).¹⁷ Two Complainants submit that the Mayor’s comment contravened section 10 generally.¹⁸ One Complainant cites provisions of the County’s Code of Conduct, over which I lack jurisdiction.

55. Several Complainants describe the harm caused by the Mayor’s words. One says the words made students “feel personally threatened and vulnerable … students were and felt personally assaulted by the Mayor’s language.”¹⁹ Another says the Mayor’s comment and apology “actively incited further polarization and hostility … and created a less inclusive, more hostile environment for marginalized members of our community.”²⁰

56. Some Complainants argue that the Mayor, by his conduct, legitimized the N-word and encouraged others to use it.²¹

57. Words used by the Complainants to describe the Mayor’s conduct are: alarming,²² absolutely appalling,²³ gross disregard for our citizens,²⁴ disrespectful,²⁵ most egregious,²⁶ inexcusable,²⁷ inflammatory,²⁸ poor judgment / error in judgment,²⁹ deeply offensive,³⁰ shameful,³¹ and unacceptable.³²

58. Several felt that the statement was connected to Mr. Leal’s City function. One said that it “undermin[ed] the dignity of the Office of the Mayor.”³³

59. At least one Complainant observes that the Mayor’ comment was also insulting to Mexicans.³⁴

60. Two Complainants state that Lyndon Johnson never made such a statement,³⁵ and a third Complainant notes that the statement has not been sourced.³⁶

61. Two Complainants note the Mayor was not quoting President Johnson directly, meaning the choice to say the N-word was that of the Mayor.³⁷

62. Six Complainants call on the Mayor to resign.³⁸ One other wants City Council to vote on whether it has confidence in him to continue.³⁹

63. Several Complainants feel the Mayor’s previous apology was insufficient.⁴⁰ One says the apology deflected responsibility.⁴¹ Another wants the Mayor to make a public apology.⁴²

64. One Complainant also alleges that the Mayor does not properly pronounce the Anishinaabemowin word “Nogojiwanong,” the name originally given by the Michi Saagiig Anishinaabeg to the land now occupied by Peterborough.⁴³

65. The Complaint of the Afrocentric Awareness Network of Peterborough reads, in part, as follows:

When the Peterborough community learned that Mayor Jeff Leal used the N-word, we – the city’s Black population – were shocked, disappointed, and horrified that our Mayor would use such a deeply offensive, anti-Black epithet – the most egregious one possible. He used this language while addressing approximately 400 students, including those of African descent, in a business administration class (Steven Girardi’s ADMN-2010H: Management Skills) on March 19, 2025.

According to Arthur – Trent University’s student newspaper – students were informed that the Mayor’s lecture would be worth 5% of their final grade, and that questions about his presentation would appear on the final exam. Arthur also quoted one student as saying, “Jeff Leal had no regard for how the students would feel hearing that.” The student continued, “As a Black Canadian student here at Trent, hearing this was harmful.”

Immediately before using the N-word, Mayor Jeff Leal – invited as a guest lecturer in the Trent business class – acknowledged that the term was unacceptable in today’s society. His disclaimer indicates he was aware of its inappropriateness.

Mayor Leal attempted to minimize his choice of word by claiming he was quoting someone else. However, he was not quoting – at best, he was paraphrasing. His public apology only came after formal complaints were submitted, and even then, it took him three weeks to issue it. This delayed response appears more like damage control than a demonstration of genuine remorse.

The Harm Done by Mayor Jeff Leal’s Use of the N-Word: Mayor Jeff Leal’s use of the N-word was not just a poor choice of language – it was a harmful act of anti-Black racism with far-reaching consequences in our community. The damage includes:

1. Perpetuating Disrespect Towards Black People

• Reinforces the notion that Black people are undeserving of respect or dignity.

• Normalizes the use of a word that is now widely condemned and recognized as indecent and violent.

• Sends a message – especially from someone in power – that it is acceptable to show contempt, disdain, and hatred toward Black people.

Demonstrates that the values of equality, diversity, and inclusion are not upheld by the City’s leadership.

2. Undermining Safe Spaces for Black Children and Adults

Children in Peterborough are increasingly being targeted with racial slurs and insults, creating unsafe environments in schools and public spaces.

• Adults are also affected – the very next day after the incident became public, Jane Braithwaite, a Black 4th-generation Canadian, was verbally assaulted in public with the N-word.

• Yesterday, Thursday, June 19th, we received an email from a parent that her child was subjected to a racial slur by another student at school. This incident has deeply affected her child, making her feel unsafe and unsupported. Understandably, such experiences can have a lasting impact on her emotional and psychological well-being. This is not an isolated racial incident that is occurring in the school, but there has been an increase in the number of racial slurs in the Peterborough schools.

These acts illustrate the immediate real-world impact of the Mayor’s words and how they embolden others.

3. Weakening Race Relations in the Community

Harms interpersonal relationships between Black residents and the broader community, generating mistrust and alienation.

• Sparked racist backlash online, including claims that:

➔ The Black community is “overreacting.”

➔ The N-word “should be used freely.”

Promotes the false idea that if a mayor can say it, so can others, further eroding social norms and safety for Black residents.

4. Threatening the Safety of African Diasporans in Peterborough

His use of the N-word was an act of verbal violence against Black people.

It has endangered the physical and emotional safety of Black individuals in the community.

Leadership sets the tone. When leaders behave this way, it signals that Black safety and dignity are not of any concern.

5. Fueling Hate in a City Already Struggling with Racism

Peterborough has the highest hate crime rate per capita in Canada in recent years:

• 2020: 19.0 per 100,000 residents (highest in Canada).

• 2021: Slight dip to 18.7 per 100,000.

• 2023: Rose again to 33.5 per 100,000, second only to Kitchener-Waterloo.

These numbers from Statistics Canada show a clear pattern of rising hate, underscoring the urgent need to:

• Address racism at all levels of leadership.

• Implement serious education and accountability measures.

• Support the Black community in Peterborough.

“These numbers highlight the ongoing and urgent need to address hate and systemic racism within the Peterborough community.” ~ Charmaine Magumbe

66. The position of the Trent Central Student Association reads, in part, as follows:

The Mayor’s statement on April 8, 2025, attributes his racist actions to a quote from President Lyndon B. Johnson. This is inherently untrue. While President Johnson did often use racial slurs, as the Mayor did, there is no record of the specific ‘quote’ that the Mayor was referring to. Falsely attributing these actions to ‘historical accuracy’ deflects from the issue at hand. The dishonesty with which the Mayor issued his apology diminishes any sense of sincerity in apologising to affected communities. The false attribution to ‘historical context’ attempts to justify the Mayor’s actions, and deflects any sense of accountability. His commitment to “listening, learning, and doing better” seems moot, given that the rest of his statement lacks genuine responsibility.

Additionally, even if this had been historically accurate, the Mayor’s actions still would not be acceptable. The Mayor used a slur which is widely known to be one of the most demeaning and offensive words ever used against the Black community. Given the Mayor’s dedication to historical teachings, he should know the violent history of this word. By using this slur, the Mayor perpetuated harm against the Black community, and has failed to take true accountability for his actions, or the harm he has caused.

2. Did the Mayor breach section 10 of the Code of Conduct on March 19?

The use of a racial slur clearly violates Section 10 of the Code of Conduct. The use of the N-word is an obvious “use [of] indecent, abusive, or insulting words or expressions toward … any member of the public” (Section 10a). Furthermore, it would qualify as speaking “in a manner that is discriminatory .. based on … race [or] ancestry” (Section 10b).

Harassment is defined as “any comment … that is unwelcome or that ought reasonably known to be unwelcome that could affect a person’s dignity or a person’s psychological … health” (Section 10c). In this sense, the Mayor harassed not just a member of the public, but upwards of two hundred members of the public, who were present at his lecture; required to be there as the lecture content would be on the final exam. Multiple students have expressed the harm that was caused to them by witnessing this lecture and hearing the Mayor’s use of a racial slur. Furthermore, the Mayor’s false statement compounds this sense of harm and loss of dignity, by failing to understand the effects of his actions, and attempting to justify his racism. The Black community at Trent has been greatly harmed by the Mayor’s actions, and further harmed by his so-called apology.

Respondent’s Position

67. The Mayor provided a detailed Response. It is best to quote most of it verbatim:

The Context

On March 19, 2025, I gave a guest lecture to Professor Girardi’s Business Management class. I am an avid reader of political biographies and so when I was asked to do a lecture on Leadership, I developed a theme about how leaders evolve their views based on the circumstances they face. The leaders I discussed were Prime Ministers Pearson, Mulroney, Diefenbaker, and Pierre Trudeau. I also spoke of Premier Bill Davis, and Prime Minister Winston Churchill. The last person I spoke of was President Lyndon B Johnson, who, I believe, demonstrated the greatest transformation of his views during his tenure.

Johnson was a very complex man who was known to use the N-word frequently during the early part of his career, revealing his racist views at that time. During the lecture, I said,

[quotation omitted – see paragraph 24, above]

I continued my lecture by highlighting some of Johnson’s great accomplishments to help erase racial discrimination, demonstrating how significantly he changed his views during his tenure. I spoke of the Civil Rights Act of 1964 and the Voting Rights Act of 1965, the former Act outlawing discrimination and segregation and the latter outlawing discriminatory practices that restricted some minorities from voting. Johnson grew from a gruff southern racist into a president who was supported by Dr. Martin Luther King as he championed the Civil Rights Movement. Johnson’s evolution of views had a significant and permanent impact on multicultural communities in the United States.

After the lecture was over, some students approached Professor Girardi and myself to express that they really enjoyed the learning and insight of the lecture. They were particularly interested in the examples that I used of leaders whose views changed as the norms of society changed. I believed the lecture was a success.

Apologies

A couple of weeks passed before I learned that some students were upset that I had used a racial slur in my lecture. I was heavy-hearted that I had made some students distressed, it certainly was not my intention to be hurtful. I realized that it was an error in judgment to use the word itself as I attempted to illustrate Johnson’s rudimentary, crass and racist views at the beginning of his tenure. Consequently, I wrote and issued the following sincere public apology on April 8th, 2025:

[text of apology omitted – see paragraph 28, above]

The apology was issued to the public as a whole and in an email to Professor Girardi to share directly with the class, the latter to ensure that all students received it. Further, I was interviewed by Global News (our local CHEX division) where I also expressed my deep regret in an interview.

Academic Practices

I am deeply sorry for upsetting the affected students at Trent and anyone who was impacted in the community at large. I sincerely meant no harm. Practices and standards in academic settings change – while I thought that I was meeting the standard when I introduced the quote by saying, “He used this language that you would never use today,” I now understand that I did not meet the current practice and I regret that. I have since learned from my own children that the current cohorts of students never say the word aloud, even though the word is fully written in print in publications. For example, when secondary students in class read aloud the novel, To Kill a Mockingbird, they either skip the fully written word entirely or say the “N-word”. At the time of the lecture, I was not aware of this shift in practice in an academic setting, for me, this does shed light on why some of the Trent students took offence to my direct quote of Johnson.

Trent Professor Leo Groarke wrote an opinion piece about the incident that was published in the Examiner. He makes the academic distinction between using a word and mentioning a word and concludes: “President Johnson used the N-word, intending its racist connotations. The mayor did not use it, but mentioned Johnson’s use. No one should imagine that the mayor was aiming to use the word and make a derogatory, racist comment, or that he approves of Johnson’s racist attitudes.”⁴⁴

68. The Response continues by submitting that section 10 of the Code was not breached. The Mayor notes that the comment, for which he already apologized, was not directed at any individual. He states that he quoted a figure who was being discussed as part of the lecture, he did not intend to harm anyone, and he has learned from his error in judgment.

69. The Response concludes by referring to another published opinion piece, by citing sources to establish that President Johnson was known to use the N-word, and by citing authority for the principle that a quotation can consist of a single word.⁴⁵

Findings of Fact

70. Most findings of fact appear in this section and in the Background section which starts above at page 4.

71. Findings of fact are made based on the standard of the balance of probabilities.

72. I find that the Mayor spoke to the class in a personal capacity.

73. However, it is understood that sometimes even personal conduct can affect the interests of the City. This is a separate issue that will be considered under the next heading.

74. I find that the Mayor’s reference to President Johnson occurred in the context of a lecture about historical leaders including Johnson.

75. I find that the Mayor’s language was not directed to, at or about anyone.

76. However, it is accepted that exposure to the N-word can harm people even if the term is not directed to them. This separate issue will be considered under the next heading.

77. The Mayor’s university degrees were conferred in 1978 and 1981 – more than four decades ago. He was 70 years old at the time of the comment.

78. The Mayor was and is aware that the N-word is improper, offensive, harmful, and must not be uttered. He acknowledged to the class that it was, “language that you would never use today.”

79. He states, however, he was unaware that it was unacceptable to quote the word directly – unaware that one must insert a euphemism, such as “N-word,” in its place. There is no evidence to contradict what he says about his state of mind and understanding.

80. I find that the Mayor is genuinely sorry, apologetic and regretful, that he has learned from the incident, and that it will not recur.

81. Whether contrition and regret are sufficient to dispose of the matter is a separate issue, to be addressed under the next heading.

82. I accept that the Mayor believed his comment was historically accurate; there is no evidence that his state of mind was different, and his demonstrated passion for political history makes it unlikely that he would knowingly invent an anecdote.

83. Whether the comment was accurate is a different question. In-depth study of historical accuracy is beyond the expertise and scope of a municipal Integrity Commissioner.⁴⁶ Within the limits of my role, I am unable to confirm that President Johnson said what was attributed, exactly when, exactly how, and in the exact context, suggested.⁴⁷ However, historical accuracy is a tangent that deflects from the key issue of whether the word should be used at all. It is not the Complainants’ position, nor is it generally accepted, that one may employ the N-word so long as historically accurate. This issue will be considered under the next heading.

84. In referring to President Johnson’s 1928-29 teaching, it would have been more accurate to use “Mexican-American,” the term Johnson himself employed, instead of “Mexican.”⁴⁸

Issues and Analysis

85. I have considered the following issues:

A. Does the Mayor’s apology resolve the need for an inquiry?

B. On March 19, did the Mayor breach section 10 of the Code?

86. Recommendations to City Council, identified as issue C in my correspondence with the parties, are addressed in the next section of this report.

A. Did the Mayor’s apology resolve the need for an inquiry?

87. I have accepted the submissions of those Complainants who said that, despite the April 8 apology, the inquiry should continue to completion.

B. Did the Mayor breach section 10 of the Code?

88. This issue can be divided into three sub-issues. First, were the Mayor’s personal remarks to the class subject to the Council Code of Conduct? Second, is historical accuracy a defence to use of the N-word? Third, is section 10 worded in a way that captures the Mayor’s comment during the lecture?

89. In a previous report, Ayotte v. Therrien,⁴⁹ I explained that generally the Code does not apply to personal activity unrelated to the office, role, function, influence, authority, or responsibility of a Council Member, and with no connection to the interests or business of the City. This is consistent with Integrity Commissioner reports in other municipalities.⁵⁰

90. While I have found that the Mayor was lecturing in a personal capacity, I agree with the Complainants that use of the N-word, by a Mayor, in a classroom inside the City, is sufficiently likely to have an impact on the interests of the City such that the Code may apply to the comment. In reaching this conclusion I have considered, among other factors, the prevalence of hate crime within the City and Peterborough’s membership in the Coalition of Inclusive Municipalities.

91. The second sub-issue is the relevance of whether the Mayor was correctly quoting President Johnson, or fairly paraphrasing him, or describing something that the President never said. I agree with and accept the argument of the Trent Central Student Association that discussion of historical accuracy “deflects from the issue at hand,” as the language used was, “one of the most demeaning and offensive words ever used against the Black community”: see paragraph 66. I accept the concern of another Complainant that some might weaponize and exploit the situation by asserting historical accuracy as licence to use the word. Consequently, my conclusion under the Code is not based on whether President Johnson actually said what was attributed.

92. The third sub-issue is whether section 10 of the Code has been drafted in such a way that it captures what was said on March 19.

93. This sub-issue turns, not on whether the N-word is execrable and vile (it is), but on whether the Code covers what occurred. On this point, Société Radio-Canada v. Canada (Attorney General), a recent court case on the CRTC’s power to regulate broadcasting of the N-word,⁵¹ is relevant and instructive. A university professor had mentioned in class the title of a book that included the N-word,⁵² and a radio program that covered the incident repeated the N-word three times in French and once in English.⁵³ Subsequently, the CRTC upheld a complaint under the Broadcasting Act and imposed sanctions on the broadcaster of the radio program.⁵⁴

94. Significantly, the CRTC did not make a finding that the use of the N-word in this instance breached the CRTC’s rules of conduct for broadcasting.⁵⁵ The CRTC majority focused on policy considerations of the N-word instead of examining how the rules of conduct applied to the specific facts of the case.⁵⁶

95. When the CRTC decision was appealed to the Federal Court of Appeal, the Attorney General for Canada intervened to oppose the CRTC decision and set it aside.⁵⁷ The federal Attorney General (obviously) did not defend use of the N-word. The Attorney General’s position was that the CRTC needed a finding that the rules of conduct had been breached in order to circumscribe how the N-word could be used on the air.⁵⁸ The Federal Court of Appeal agreed with the Attorney General of Canada and set aside the CRTC’s decision.⁵⁹

96. According to the Court, the CRTC had to apply the rules of conduct; merely holding that the N-word was contrary to policy was insufficient to justify a sanction.⁶⁰ If the N-word was not adequately covered by the rules of conduct, then the CRTC (which made the rules in the first place) could amend them.⁶¹ What the CRTC could not do was to impose sanctions for use of the N-word unless a specific rule was being contravened.⁶²

97. While not binding on a municipal Integrity Commissioner, Société Radio-Canada v. Canada (Attorney General) is significant and relevant. The judgment does not contradict the understanding that the N-word is repugnant and odious, an expression of racial hatred.⁶³ Nonetheless, the Federal Court of Appeal confirms that limits on using the N-word must be based on the wording of the applicable rules – in that case, the rules of conduct for broadcasting; in this case, the Council Code of Conduct.

98. I am required to analyze section 10 of the Code in the context of the facts of this case. It reads as follows:

Each Member has the duty and responsibility to treat members of the public, each other Member and staff appropriately and without abuse, bullying or intimidation, and to ensure that the City’s work environment is free from discrimination and Harassment. Without limitation, a Member must not:

a) use indecent, abusive or insulting words or expressions toward any other Member, any member of staff or any member of the public;

b) speak in a manner that is discriminatory to any individual, based on that person’s race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, gender identity, gender expression, age, marital status, family status or disability; or

c) engage in any Harassment of any other Member, any member of staff or any member of the public.

99. The following definition in the Code is also relevant:

“Harassment” includes

i) any comment, conduct, action or gesture that is unwelcome or that ought reasonably known to be unwelcome that could affect a person’s dignity or a person’s psychological or physical health; and

ii) Sexual Harassment

100. Having carefully considered its text, purpose and meaning, I cannot conclude that section 10 covers the present instance: a one-time use of the N-word, in an academic context, not directed to anyone, but attributed (whether correctly or erroneously) to a historic figure during discussion of how that figure thought and acted.

101. Paragraph 10 a) only applies to words directed toward another individual. I accept the position of the Complainants that the N-word can be harmful without being communicated to or about any particular person. That observation does not, however, widen the ambit of paragraph 10 a) as presently drafted.

102. Paragraph 10 b) only applies to speech concerning a real, identifiable individual. The text does not necessarily require that the individual hear or be present for the speech, but it does imply a proximate connection between the spoken word and the subject of the spoken word. Paragraph 10 b) cannot cover a comment made about people whom a historical figure, now deceased almost 53 years, might or might not have made about unknown students in his class 96 or 97 years ago. Again, I accept the Complainants’ position that the N-word can be harmful without being communicated to or about any particular person. That observation does not, however, expand paragraph 10 b) beyond its present scope.

103. For the same reason, paragraph 10 b) does not cover the Mayor’s failure to describe the 1928-29 students as “Mexican-American.”

104. Paragraph 10 c) must be interpreted consistently in all cases. As I reported to City Council earlier in People and Culture Division v. Riel:

The established Canadian legal meaning of harassment encompasses a course of conduct or pattern of behaviour. [footnote omitted] While the Code defines harassment to include, “any comment, conduct, action or gesture that is unwelcome or that ought reasonably known to be unwelcome that could affect a person’s dignity or a person’s psychological or physical health,” the Workplace Discrimination and Harassment Policy defines harassment as “engaging in a course of vexatious comment or conduct …”⁶⁴

105. The words “a course of” are usually considered to mean a pattern of behaviour, though a single, severe incident could constitute harassment. As observed by the Supreme Court of Canada, “It is certainly difficult to see a course of conduct in a single incident.”⁶⁵

106. The established Canadian legal meaning of harassment has been applied in other municipalities.⁶⁶

107. I have carefully looked for any court, tribunal or arbitral precedent that upholds a finding of harassment arising in a context similar to that of March 19.

108. The Mount Royal University arbitration case was decided in favour of the professor but was based on a more complex factual context.⁶⁷ The complaint about a Brock University academic paper was dismissed on jurisdictional grounds for reasons inapplicable to Municipal Act inquiries.⁶⁸ The University of Ottawa case was settled on confidential terms before an arbitration award could be issued.⁶⁹

109. The Ontario College of Teachers cases involve very different facts, are distinguishable, and provide no assistance.⁷⁰

110. Harassment was not found in Redmond v. Hollywood Boutique, but the case involved playing a song as opposed to an academic lecture.⁷¹

111. Arbitration awards issued outside the academic context, though they mostly side with the grievors, are based on facts too dissimilar to be useful.⁷²

112. Municipal Integrity Commissioners are not entitled to their own interpretations of harassment. We should apply the principles established by courts and expert tribunals. On this basis, I cannot conclude that the March 19 comment constituted harassment or breached paragraph 10 c) of the Code.

113. To be clear, what occurred on March 19 was not acceptable. Everyone agrees it was unacceptable. The Respondent agrees it was unacceptable. He has acknowledged that, both earlier this year and in this inquiry.

114. The purpose of this inquiry is to determine whether the March 19 comment, which is universally agreed to be unacceptable, contravened the Council Code of Conduct. It did not.

115. What the Federal Court of Appeal said about the CRTC’s rules of conduct is equally applicable to City Council and the Council Code of Conduct. To cover what is not currently covered, Council needs simply to amend the Code. For example, Council could insert a new paragraph 10 d) that reads: “use the N-word regardless of context or circumstance.”

Recommendations

116. City Council may wish to ask the staff to report back on the recommendation of the Trent Central Student Association that the Strategic Plan be amended to include anti-racism and race relations as a strategic priority under the Community and Wellbeing pillar.

117. A Council vote of confidence or non-confidence in the Mayor, as recommended by some Complainants, is outside the scope of Part V.1 of the Municipal Act.

Content

118. Subsection 223.6 (2) of the Municipal Act states that I may disclose in this report such matters as in my opinion are necessary for the purposes of the report. All the content of this report is, in my opinion, necessary.

Respectfully submitted,

Guy Giorno

Integrity Commissioner

City of Peterborough

December 22, 2025

Footnotes

1. 1Balikama obo others v. Khaira Enterprises and others, 2014 BCHRT 107, para. 485.
2. 2Arig al Shaibah and Sophie Poinar, Managing Campus Expression and Equality Rights: Contemporary Considerations for Canadian Universities, 2021 10-1 Canadian Journal of Human Rights 73, at 111, 2021 CanLIIDocs 13664, online: https://canlii.ca/t/7jfnv
3. 3Sarba v. Ruskin Construction Ltd. and others (No. 2), 2025 BCHRT 74, para. 42; Sarba v. Ruskin Construction Ltd. and others, 2022 BCHRT 35, para. 52.
4. 4Statistics Canada, Table 35-10-0191-01, “Police-reported hate crime, number of incidents and rate per 100,000 population, Provinces, Territories, Census Metropolitan Areas and Canadian Forces Military Police” (July 22, 2025), online: https://doi.org/10.25318/3510019101-eng
5. 5The rates per 100,000 population, were: Canada (total), 11.9; Ontario (total), 16.0, and Peterborough Census Metropolitan Area, 21.4.
6. 6Calculations based on Statistics Canada data, note 4. From 2020 to 2024, inclusive, the average annual rate of incidents of police-reported hate crime in Peterborough was 20.8 per 100,000 population. From 2015 to 2019, inclusive, the average annual rate was 6.0 per 100,000.
7. 7Royal Canadian Mounted Police, “Hate crimes and incidents in Canada: Facts trends and information for frontline police officers” (Dec. 9, 2025).
8. 8City Council Minutes (Nov. 25, 2019), Item 7, pp. 3-4.
9. 9Canadian Commission for UNESCO, “Coalition of Inclusive Municipalities” (online).
10. 10Canadian Commission for UNESCO, “The Canadian Coalition of Municipalities Against Racism and Discrimination” (2016), p. 2, online: https://unesdoc.unesco.org/ark:/48223/pf0000248270
11. 11Legislative Assembly of Ontario, Official Report of Debates (Hansard), 38th Parliament to 41st Parliament, passim.
12. 12“FDR” is Franklin Delano Roosevelt, 32nd President of the United States. The “New Deal” was his reform program. In accepting the Democratic Party nomination on July 2, 1932, Roosevelt promised, “I pledge you, I pledge myself, to a new deal for the American people.” Franklin D. Roosevelt, Address Accepting the Presidential Nomination at the Democratic National Convention, online: Chicago Online by Gerhard Peters and John T. Woolley, The American Presidency Project, https://www.presidency.ucsb.edu/node/275484
13. 13In lettering complaints, my practice is to skip the capital letters I and O, as they can be too easily confused with the digits 1 and 0 (zero).
14. 14Dhillon v. Brampton (City), 2021 ONSC 4165, paras. 34, 40.
15. 15Complainants A, G.
16. 16Complainants A, C, F, G, K.
17. 17Complainants A, C, G.
18. 18Complainants D, E.
19. 19Complainant C.
20. 20Complainant D.
21. 21Complainant C.
22. 22Complainant F.
23. 23Complainant B.
24. 24Complainant B.
25. 25Complainant F.
26. 26Complainant K.
27. 27Complainant J.
28. 28Complainant H.
29. 29Complainants F, G.
30. 30Complainants C, D, K.
31. 31Complainant H.
32. 32Complainant C.
33. 33Complainant C.
34. 34Complainant A.
35. 35Complainants A, D.
36. 36Complainant F.
37. 37Complainants A, G.
38. 38Complainants B, F, G, H, J, K.
39. 39Complainant A.
40. 40Complainants C, D, F, K.
41. 41Complainant D.
42. 42Complainant A.
43. 43Complainant B.
44. 44The Mayor cited the source in the body of his Response. For consistency, the citation has been placed in this footnote: Leo Groarke, Peterborough Examiner, “We need to understand the use/mention distinction of Mayor Leal’s use of the ‘N-word’” (Aug. 14. 2025).
45. 45I understand the Mayor’s last point to be that, even if the only word belonging to President Johnson was the N-word, this still constituted quoting President Johnson. Because the conclusions that I draw deal with the Complaints on other grounds, it is not necessary for me to make a finding on this point.
46. 46R. v. Zundel, 1992 CanLII 75 (SCC), [1992] 2 S.C.R. 731, at 756-8; Re Maika, 2018 ONMIC 11, paras. 121-144; Montforts v. Brown, 2021 ONMIC 10, paras. 135-137; Burton v. Inch, 2023 ONMIC 6, paras. 92-93.
47. 47There is ample evidence that President Johnson used the N-word: Adam Serwer, “Lyndon Johnson was a civil rights hero. But also a racist” (April 11, 2014), MS Now. There is also evidence that Johnson spoke of the poverty and prejudice experienced by the students he taught as a public school teacher from 1928-29. “My first job after college was as a teacher in Cotulla, Texas, in a small Mexican-American school. Few of them could speak English, and I couldn’t speak much Spanish. My students were poor and they often came to class without breakfast, hungry. They knew even in their youth the pain of prejudice. They never seemed to know why people disliked them. But they knew it was so, because I saw it in their eyes.” Lyndon Johnson, “Voting Rights and the American Promise” (March 15, 1965).
48. 48Ibid., “Voting Rights and the American Promise.”
49. 49Ayotte v. Therrien, 2022 ONMIC 10, para. 104.
50. 50Burton v. Inch, 2023 ONMIC 6, paras. 106-107; Gogos v. Jones, 2022 ONMIC 7, paras. 159, 161-162, 169-185; Pinto v. Anderson (No. 2), 2022 ONMIC 4, paras. 58-65.
51. 51Société Radio-Canada v. Canada (Attorney General), 2023 FCA 131, 483 D.L.R. (4th) 362.
52. 52This report deliberately omits citation of the book.
53. 53Société Radio-Canada v. Canada (Attorney General), note 51, para. 4.
54. 54Broadcasting Decision CRTC 2022-175.
55. 55Société Radio-Canada v. Canada (Attorney General), note 51, para. 44.
56. 56Ibid.
57. 57Ibid., para. 23.
58. 58Ibid., paras. 24, 27-28, 30.
59. 59Ibid., para. 62.
60. 60Ibid., paras. 42, 53.
61. 61Ibid., paras. 54-55.
62. 62Ibid., para. 53.
63. 63R. v. Beals, 2022 ONSC 2574, para. 34.
64. 64People and Culture Division v. Riel, 2025 ONMIC 9, para. 146; see also Therrien-Hale et al. v. Leal, 2025 ONMIC 4, at footnote 25.
65. 65Honda Canada Inc. v. Keays, 2008 SCC 39, [2008] 2 S.C.R. 362, at 398, para. 73.
66. 66Burton v. Inch, 2023 ONMIC 6, para. 52; Forbes v. Leahy, 2021 ONMIC 36, at footnote 7; Re Beyak et al., 2018 ONMIC 8, para. 58.
67. 67Board of Governors of Mount Royal University v. Mount Royal Faculty Association, 2024 CanLII 68666 (AB GAA).
68. 68Marceau v. Brock University, 2013 HRTO 569.
69. 69Association des Professeur.e.s à Temps Partiel de l’université d’Ottawa c. Université d’Ottawa, 2023 CanLII 51269 (ON LA), para. 13.
70. 70Ontario College of Teachers v. Mancuso, 2022 ONOCT 45; Ontario College of Teachers v. Riesberry, 2023 ONOCT 60; Ontario College of Teachers v. Corradetti, 2023 ONOCT 50.
71. 712018 BCHRT 121.
72. 72Alberta (Government) (Justice and Solicitor General) v. Alberta Union of Provincial Employees, 2023 CanLII 2834 (AB GAA); Re Alberta Justice and Solicitor General and AUPE (869395), 2023 CarswellAlta 160, paras 79, 81; United Food and Commercial Workers, Local 401 v. Sobeys Capital Incorporated – Safeway Operations, 2024 CanLII 45541 (AB GAA);