Ontario College of Teachers v. Buonafede, 2025 ONOCT 13

DISCIPLINE COMMITTEE OF THE ONTARIO COLLEGE OF TEACHERS

Citation: Ontario College of Teachers v Buonafede 2025 ONOCT 13

Date: 2025-02-28

DECISION, REASONS FOR DECISION AND ORDER

IN THE MATTER OF the Ontario College of Teachers Act, 1996 and the Regulation (Ontario Regulation 437/97) thereunder;

AND IN THE MATTER OF a discipline proceeding against

Dennis Mauro Buonafede, a member of the Ontario College of Teachers.

BETWEEN:

ONTARIO COLLEGE OF TEACHERS

– and –

DENNIS MAURO BUONAFEDE (REGISTRATION #447269)

PANEL: Élaine Legault, Chair Mary Carol Edy, OCT Hanno Weinberger, OCT

HEARD: February 25, 2025

Ava Arbuck, for the Ontario College of Teachers Simone Truemner-Caron, for Dennis Mauro Buonafede Ahmad Mozaffari, Independent Legal Counsel

PUBLICATION BAN: Pursuant to subsections 32.1(3) of the Ontario College of Teachers Act, 1996, no person shall publish the identity of, or any information that could disclose the identity of any person who is under 18 years old and is a witness in a hearing or is the subject of evidence in a hearing.

1This proceeding was heard electronically before a panel of the Discipline Committee (the “Panel”) of the Ontario College of Teachers (the “College”) on February 25, 2025, in accordance with rule 8.01 of the Rules of Procedure of the Discipline Committee and of the Fitness to Practise Committee.

2Dennis Mauro Buonafede (the “Member”) did not attend the hearing but had legal representation. The Panel was advised at the outset of the hearing that the parties had entered into an agreement with respect to the hearing.

A. PUBLICATION ban

3The Panel ordered a publication ban pursuant to subsection 32.1(3) of the Ontario College of Teachers Act, 1996 (the “Act”), which makes such an order mandatory. Accordingly, no person shall publish the identity of, or any information that could disclose the identity of, any person who is under 18 years old and is a witness in a hearing or is the subject of evidence in a hearing.

B. THE ALLEGATIONS

4The allegations against the Member in the Notice of Hearing #6332dated October 31, 2023 (Exhibit 1) are as follows:

IT IS ALLEGED that Dennis Mauro Buonafede is guilty of professional misconduct as defined in the Act in that:

(a) he failed to maintain the standards of the profession, contrary to Ontario Regulation 437/97, subsection 1(5);¹

(b) he abused a student or students, verbally, contrary to Ontario Regulation 437-97 [sic], subsection 1(7);

(c) he abused a student or students psychologically or emotionally, contrary to Ontario Regulation 437/97, subsection 1(7.2);²

(d) he failed to comply with the Act or the regulations or the by-laws, specifically section 32 of the by-laws, contrary to Ontario Regulation 437/97, subsection 1(14);³

(e) he failed to comply with the Education Act, Revised Statutes of Ontario, 1990, chapter E.2, and specifically subsection 264(1) thereof or the Regulations made under that Act, contrary to Ontario Regulation 437/97, subsection 1(15);

(f) he committed acts that, having regard to all the circumstances, would reasonably be regarded by members as disgraceful, dishonourable or unprofessional, contrary to Ontario Regulation 437/97, subsection 1(18);

(g) he engaged in conduct unbecoming a member, contrary to Ontario Regulation 437/97, subsection 1(19).

5The allegations against the Member in the Notice of Hearing #6470 dated October 31, 2023 (Exhibit 2) are as follows:

IT IS ALLEGED that Dennis Mauro Buonafede is guilty of professional misconduct as defined in the Act in that:

(a) he failed to comply with the Act or the regulations or the by-laws, specifically section 32 of the by-laws, contrary to Ontario Regulation 437/97, subsection 1(14);⁴

(b) he failed to comply with the Education Act, Revised Statutes of Ontario, 1990, chapter E.2, and specifically subsection 264(1) thereof or the Regulations made under that Act, contrary to Ontario Regulation 437/97, subsection 1(15);

(c) he committed acts that, having regard to all the circumstances, would reasonably be regarded by members as disgraceful, dishonourable or unprofessional, contrary to Ontario Regulation 437/97, subsection 1(18);

(d) he engaged in conduct unbecoming a member, contrary to Ontario Regulation 437/97, subsection 1(19).

6The parties agreed to proceed with a single hearing to address the allegations set out in these Notices of Hearing, in accordance with subsection 9.1(1)(b) of the Statutory Powers Procedure Act.

C. AGREED STATEMENT OF FACTS

7College Counsel presented the Panel with the parties’ Agreed Statement of Facts and Guilty Plea (Exhibit 3), which provides the following:

1. Dennis Mauro Buonafede is a member of the Ontario College of Teachers in the Cancelled-Resigned status. Attached hereto and marked as Exhibit “A” is a copy of the Ontario College of Teachers Registered Member Information with respect to the Member.

2. At all material times, the Member was employed by the Dufferin-Peel Catholic District School Board (the “Board”) as a teacher at [XXX] School (the “School”) in Brampton, Ontario.

3. During the 2020-2021 academic year, the Member taught Grade [XXX] at the School.

4. At all material times between September 2020 and December 2020, due to the safety measures in place at Ontario schools as a result of the Corona Virus, half of the Member’s students connected to the class online, while the other half was in class with the Member.

5. Between September 2020 and December 2020, the Member made racist, demeaning and derogatory comments in class on topics including Black Lives Matter, women, gender, sexual orientation, and visible minorities. The Member also spent a significant amount of class time discussing the upcoming American presidential election and sharing pro-Trump videos with his students.

Racist and Culturally Insensitive Comments In Class

6. The Member made a number of remarks in class regarding the Black Lives Matter movement and the Black community, including:

(a) the Black Lives Matter movement was “a proven Marxist organization”;

(b) he did not support a tenet of the Black Lives Matter movement in respect of his observation that the movement sought to undo the nuclear family unit in support of a village or extended approach to raising children, whereas he believed in the importance of biological parents being responsible for raising their children;

(c) “systemic racism does not exist”, a comment he made to demonstrate the need for precise language in philosophy, as his point was that endemic, not systemic racism exists;

(d) “while George Floyd’s death was tragic, if Mr. Floyd had resisted arrest or did something wrong, then he had forfeited his right not to be handcuffed”, comments the Member made when trying to explain the principle of forfeiture in natural law;

(e) one issue leading to violence and gang activity in the Black community is the lack of fathers’ involvement in their children’s lives, and that boys desire adult male models, comments the Member made after he heard Denzel Washington making similar statements.

7. The Member made eye contact with Black students in his class when he made the above comments, explaining he did so as a courtesy because he would not talk about someone without making eye contact. Further, he was trying to encourage and reinforce in his Black students the necessity for them as men to play an active role in the lives of their children.

8. The Member stated words to the effect of “Italians have strong family values and that is what you need to look for in a spouse”, comments he made while discussing fidelity in his class.

9. The Member recognizes that he should have explained his use of these examples clearly and/or used different examples to illustrate certain philosophical principles, and that his comments may have been understood or construed as inappropriate and racist by students.

Insensitive Comments Towards Females

10. The Member acknowledged he made the following comments in class about women:

(a) females/ women have an “expiry date”;

(b) “women cannot get an education, then travel and work like a man, and then expect to arrive in their 30s to have children, because by that point men will look for a 20-year old”, comments he said in order to make his students aware of a current cultural phenomenon;

(c) “men will not look at a woman over 35 since they can no longer have children, they will look at someone in their 20s, therefore, women should consider delaying their education in order to have babies”, statements the Member made to convey that if his female students desire marriage and family, then they may want to consider having children first before starting a career;

(d) “women who go on to do their post-secondary education have fewer options to date and marry”, a comment he made when attempting to explain the phenomena of hypergamy.

11. The Member intended the above comments to be understood within the context of biology and fertility, and acknowledges his comments may have come across to students as flippant and derogatory.

Insensitive Comments Regarding Gender and Sexual Orientation

12. The Member acknowledged he made the following comments and conduct in class about the LGBTQ community:

(a) according to natural law, the “gay lifestyle” is not what humans are intended for;

(b) an option for homosexuals is to engage in heterosexual relationships;

(c) he has two gay friends who each came to the realization intellectually that they could find happiness in marriage to someone of the opposite sex;

(d) he posted an article on Google Classroom on why homosexual couples should not be allowed to adopt.

13. The Member made the above statements, provided the examples involving his friends, and posted the article with the intention of engaging his students in critical thinking, wanting to expose his students to different perspectives so that they can make good decisions. He acknowledges these were controversial topics and that his students likely perceived that he was advocating for these positions.

14. The Member acknowledges he may have made the following inappropriate comments in class:

(a) there was no need for protests following George Floyd’s murder;

(b) he referred to Black students in his class as “the Blacks”;

(c) he went to school in British Columbia where many of the last names listed in the yearbook were “Ching, Chang and Chong”;

(d) the best place to have a debate about politics is at a pub over a beer.

Inappropriate discussion regarding the United States Presidential Election and/or United States Politics

15. The Member discussed the upcoming Presidential Election in the United States in class. During these discussions, the Member:

(a) showed students videos that, in his view, explained why Donald Trump ran to be president;

(b) asked students to pray that Mr. Trump would win the presidential election;

(c) said that he was intrigued by QAnon and its information.

Board Investigation and Discipline

16. The parent of one of the Member’s students contacted the Principal to share her concerns regarding the Member’s conduct and comments while teaching, as well as concerns related to the resource materials he provided to his students. Attached hereto and marked as Exhibit “B” is a copy of a parent complaint dated December 4, 2020.

17. The Board investigated the allegations made against the Member by interviewing nine students from the Member’s Grade [XXX] class. When Board administrators met with the Member and his representative on December 14, 2020, the Member acknowledged he made mistakes and shouldn’t have discussed controversial topics. He explained he was trying to keep the topics relevant and meaningful, however, he was aware of his biases and that he comes across as passionate, and he understood how some of his comments might have been misunderstood and perceived as offensive and/or racist by students.

18. The Board issued the Member a three-day disciplinary suspension, reminded the Member that “students have the right to attend school in an environment free from harassment and discrimination”, and directed the Member to take the Human Rights 101 Learning Modules on the Human Rights Commission’s website. Attached hereto and marked as Exhibits “C” and “D” respectively, is a copy of the discipline letter dated February 17, 2021, and a copy of the Member’s Certificate of Completion of Human Rights 101, dated February 24, 2021.

May 10, 2021

19. On May 10, 2021 at 12:09 PM, the Member sent an email to all staff at the School with the subject line “Possible Resource”, in which he informed staff he came across an article “which really fits with philosophy, but may also be applicable in other subjects” and attached an article entitled “Being Critical of Critical Race Theory” for their consideration. Attached hereto and marked as Exhibit “E” is a copy of the email communication and article sent by the Member.

20. Before the end of the School day, after some colleagues expressed concern that the Member had shared this particular article, the Principal sent an email reminding staff, “For the last time, DPCDSB email is to be used for board purposes only” [emphasis in original]. The Principal strongly encouraged staff to re-familiarize themselves with the Board’s policy, advised staff to engage in any political discussion on their own time and through their private email, and instructed staff they must obtain his approval before sending an email to all staff/ teachers in the future.

21. On May 12, 2021, a colleague filed a formal complaint against the Member related to the article.

Board Discipline

22. On May 19, 2021, during a meeting with Board administrators where he was advised that some colleagues expressed concern about racist and micro-aggressive content in the article, the Member acknowledged he was aware that Board email was for board purposes only. He indicated he shared the article from an “academic” lens as a “possible cross-curricular resource”, therefore, he did not think about how his colleagues may receive it. He acknowledged he should have been more specific regarding who he sent the article to, and he expressed his remorse at both sending the article to all staff and offending some staff.

23. The Board issued a discipline letter dated June 28, 2021, in which it suspended the Member for five days without pay, required the Member to complete a professional boundaries course, and advised of its expectations. Attached hereto and marked as Exhibits “F” and “G” are copies of the Board’s discipline letter dated June 28, 2021, and the letter of completion of the professional boundaries course dated August 25, 2021.

Member’s Current Status

24. The Member retired from the Board on June 30, 2022, and is currently not employed in any teaching capacity. The Member resigned from the College, effective March 19, 2024.

GUILTY PLEA

25. By this document, the Member admits the truth of the facts and exhibits referred to in the paragraphs above (the “Admitted Facts”).

26. The Member hereby acknowledges that the Admitted Facts constitute conduct which is professional misconduct and pleads guilty to the allegations of professional misconduct against him, being more particularly breaches of Ontario Regulation 437/97 subsections 1(7), 1(14), 1(15), 1(18), and 1(19).

27. By this document the Member states that:

(a) he understands fully the nature of the allegations against him;

(b) he understands that by signing this document he is consenting to the evidence as set out in the Admitted Facts being presented to the Discipline Committee;

(c) he understands that by pleading guilty to the allegations, he is waiving the right to require the College to otherwise prove the case against him and the right to have a hearing;

(d) he understands that the Discipline Committee’s decision and reasons shall be published on the College’s website, and that a summary of the Discipline Committee’s decision and reasons, including his name, shall be published in the official publication of the College;

(e) he understands that any agreement between him and counsel for the College with respect to the penalty proposed does not bind the Discipline Committee;

(f) he understands and acknowledges that he is executing the Agreed Statement of Facts and Guilty Plea voluntarily, unequivocally, and having had the opportunity to obtain the advice of legal counsel.

28. In light of the Admitted Facts and the circumstances and the plea of guilt, the Ontario College of Teachers and the Member submit that the Discipline Committee find the Member guilty of professional misconduct.

D. DECISION

8Counsel for the College requested that the allegations of professional misconduct outlined in paragraphs (a) and (c) of the Notice of Hearing #6332, namely that the Member contravened subsections 1(5) and 1(7.2) of Ontario Regulation 437/97, be withdrawn. College Counsel stated that the Panel’s permission to withdraw allegation (a), namely that the Member contravened subsection 1(5), was being sought because the College was proceeding with allegation (d), that the Member contravened subsection 1(14), and it would therefore be duplicative to proceed with both allegations. As for allegation (c), namely that the Member contravened subsection 1(7.2), College Counsel submitted that the withdrawal was being sought as a by-product of negotiations in the adversarial process that resulted in the Agreed Statement of Facts and Guilty Plea. The Panel granted these requests.

9Having considered the Agreed Statement of Facts and Guilty Plea and the submissions of the parties, the Panel rendered an oral decision on February 25, 2025, finding that the Member engaged in acts of professional misconduct as alleged, contrary to Ontario Regulation 437/97, subsections 1(7), 1(14), 1(15), 1(18) and 1(19).

E. REASONS FOR DECISION

10The Member admitted the truth of the facts and exhibits referred to in paragraphs 1 to 24 of the Agreed Statement of Facts and Guilty Plea and admitted the allegations of professional misconduct against him. He acknowledged and the Panel accepts that the Admitted Facts constitute professional misconduct under the heads of misconduct set out above. The Admitted Facts demonstrate that the Member repeatedly made numerous inappropriate comments in class and to his colleagues, including racist, demeaning and derogatory comments in class.

11The Panel finds that the Member abused a student or students verbally, contrary to subsection 1(7) of Ontario Regulation 437/97. The Member made multiple racist, culturally insensitive, demeaning and derogatory comments in class to his students. For example, the Member made a number of remarks about the Black Lives Matter movement like saying it was “a proven Marxist organization” and “while George Floyd’s death was tragic, if Mr. Floyd had resisted arrest or did something wrong, then he had forfeited his right not to be handcuffed”. The Member admitted that his comments may have been perceived as racist. The Member also made insensitive comments about women, like women have an “expiry date” and “women who go to do their post-secondary education have fewer options to date and marry”. The Member acknowledged that his comments may have come across as flippant and derogatory. Further, the Member made derogatory comments about sexual orientation such as “the gay lifestyle is not what humans are intended for” and “an option for homosexuals is to engage in heterosexual relationships”. The Member’s comments perpetuated negative stereotypes and prejudice of marginalized groups within society. It was abusive, disrespectful and unacceptable to make such comments to his class, especially as some of his students belonged to these marginalized groups.

12The Admitted Facts demonstrate that the Member failed to comply with section 32 (now section 26) of the by-laws, contrary to subsection 1(14) of Ontario Regulation 437/97. The Panel finds that the Member breached the professional and ethical standards of the profession. In particular, the Member breached the standard of practice “Commitment to Students and Student Learning” and “Leadership in Learning Communities”. These standards require members to promote and participate in creating collaborative, safe and supportive learning communities; to be dedicated in the care and commitment of students; and to treat them equitably and with respect, while being sensitive to factors that influence student learning. The Member failed do so when he repeatedly made racist, homophobic and sexist comments in class. Exposing students to such comments can create a poisoned learning environment, especially for students who belong to the marginalized groups that the Member spoke about.

13The Member also breached the ethical standards of “Care”, “Respect” and “Integrity”. “Care” requires members to show compassion, acceptance, interest and insight for developing students’ potential. “Respect” requires members to “honour human dignity, emotional wellness and cognitive development” and to model respect for spiritual and cultural values. The Member failed to show compassion and acceptance when he made numerous demeaning comments about marginalized groups. By making such comments in class, the Member showed no insight or regard for students’ well-being and how his students, especially those belonging to marginalized groups, might feel or be negatively affected by his statements.

14The Member also breached the ethical standard of “Integrity” by failing to show continual reflection in exercising integrity in his professional practice. The Member sent a contentious email to all staff at his School regarding an article on critical race theory that he ought to have known could offend some staff, and he do so despite being disciplined by his Board 3 months earlier for his offensive comments in class.

15The Panel finds that the Member failed to comply with subsection 264(1) of the Education Act, contrary to subsection 1(15) of Ontario Regulation 437/97. Section 264(1)(c) sets out that teachers must exemplify moral virtues and act as positive role models. By repeatedly making inappropriate and offensive comments in class without regard for whether students could be offended by his views, the Member acted as a poor role model. Teachers’ responsibilities to exemplify good values and act as positive role models should be taken seriously given their unique position of trust and authority. Section 264(1)(d) of the Education Act requires members to assist in developing co-operation and co-ordination of efforts among staff. The Member failed do so by using a Board email to send a contentious article to all staff at the School which led to a formal complaint by a colleague and raised concerns about racist and micro-aggressive content in the article.

16The Member committed acts that would be reasonably regarded as disgraceful, dishonorable and unprofessional, contrary to subsection 1(18) of Ontario Regulation 437/97. The Panel finds that the Member’s conduct can be characterised as all three terms. The Member demonstrated a profound lack of moral and professional judgment by making numerous derogatory, demeaning, and offensive comments in class. The Member’s remarks in class were disgraceful. The Member ought to have known that his conduct was unacceptable and that students might perceive his comments as racist and derogatory. Further, the Member showed a serious disregard of his professional obligations and poor professional judgment when he sent an email to staff with a contentious article about critical race theory, just a few months after he was disciplined by the Board for making inappropriate (including racists) comments in class and required to complete remedial coursework on human rights.

17Finally, the Admitted Facts demonstrate that the Member engaged in conduct unbecoming a member, contrary to subsection 1(19) of Ontario Regulation 437/97. Members of the profession are expected to be respectful and culturally competent in the classroom. The reputation of the teaching profession is undermined when members make racist, discriminatory, and derogatory comments about marginalized groups in class.

F. undertaking and acknowledgment

18On January 23, 2025, the Member entered into an Undertaking and Acknowledgment (the “Undertaking”) (Exhibit 5), in which he agreed to the following terms and conditions:

1. I am a former member of the College, bearing Certificate of Qualification and Registration number 447269. I resigned from the College effective March 19, 2024.

2. I undertake that I will never seek reinstatement of my Certificate of Qualification and Registration.

3. I undertake that I will never teach in any public or private school in Ontario or work in any position that requires membership in the College.

4. I acknowledge that having resigned, and irrevocably surrendering my Certificate of Qualification and Registration pursuant to this Undertaking and Acknowledgment, I will not be entitled in the future to seek membership in the College

5. I understand that a breach of this Undertaking and Acknowledgment may constitute professional misconduct and that in those circumstances, the College may take legal action and/or commence a complaint against me.

6. I acknowledge that my status on the Public Register of the Ontario College of Teachers will be “Resigned-Cancelled” and the notation will read as follows:

“On March 19, 2024, the Member resigned his membership with the Ontario College of Teachers, and on January 23, 2025 has undertaken not to teach in any public or private school in Ontario or work in any position that requires membership in the Ontario College of Teachers, nor to seek reinstatement of his Certificate of Qualification and Registration.”

7. I acknowledge and understand that the decision and reasons of the Discipline Committee in these matters will be available on the College’s website.

8. I acknowledge my understanding about the scope, purpose and effect of my execution of this Undertaking and Acknowledgment, and am executing same voluntarily, unequivocally, and with the advice of legal counsel.

G. PENALTY DECISION

19The parties entered into a Joint Submission on Penalty (Exhibit 4), which was presented to the Panel. In an oral decision rendered on February 25, 2025, the Panel accepted the Joint Submission on Penalty and made the following order:

1. The Member is directed to receive a written reprimand and the fact of the reprimand shall be recorded on the Register of the Ontario College of Teachers (the “Register”).

2. The Registrar is directed to suspend the Certificate of Qualification and Registration of the Member for a period of four months, commencing on the 15th calendar day following the date of the Decision and Order of the Discipline Committee relating to this matter.

H. REASONS FOR PENALTY DECISION

20The Panel accepts the penalty jointly proposed by the parties and notes that the Member has undertaken to never again hold a teaching position in Ontario. The Panel recognizes that, once it ensures that it has jurisdiction to make the order requested, the law confines the Panel’s role to determining whether the proposed penalty is so unreasonable that accepting it would bring the administration of the discipline process into disrepute or be otherwise contrary to the public interest.⁵ The Panel finds that (given the Member’s undertaking) the penalty proposed in the Joint Submission on Penalty is neither unduly harsh nor unduly lenient such as to bring the administration of the discipline process into disrepute, based on the following prior decisions of the Discipline Committee presented by the parties: Ontario College of Teachers v. Hall, 2022 ONOCT 118; Ontario College of Teachers v. Sanderson, 2021 ONOCT 56; Ontario College of Teachers v. Ojero, 2024 ONOCT 37; Ontario College of Teachers v. Campbell, 2022 ONOCT 6, 2022 ONOCT 06; and Ontario College of Teachers v. Manga, 2017 ONOCT 48.

21The Panel considered the Member’s circumstances in comparison to the cases provided. There are three aggravating factors: 1) the Member had a pattern of making numerous inappropriate (i.e., racist, sexist, homophobic) comments in class; 2) the Member’s comments perpetuated negative stereotypes and promoted a non-inclusive environment; and 3) the Member showed a continued lack of insight regarding his professional abilities even after being disciplined by his Board for inappropriate comments and completing remedial coursework on human rights. In terms of mitigating factors, the Member admitted their misconduct, saving the time and expense of a contested hearing, and has not been the subject of discipline proceedings in the past. After weighing these factors, the Panel accepts that the penalty proposed would not bring the administration of the discipline process into disrepute.

22The Panel finds that the Member’s pattern of repeatedly making inappropriate comments in class, warrants a reprimand. Members are expected to act as positive role models and be culturally respectful of students. The Member failed to foster an inclusive classroom environment by sharing his views. The reprimand will allow the Panel to directly address its concerns with the Member and will serve as a specific deterrent. Recording the fact of the reprimand on the Register will serve as a general deterrent to other members of the profession.

23Given the nature and severity of the Member’s misconduct, the Panel finds that a four-month suspension is reasonable and appropriate. While the cases presented are factually distinct from this case, the misconduct represented in those cases is of a similar underlying nature and the cases confirm that a suspension is justified. In deciding the length of the suspension, the Panel gave considerable weight to the fact that the Member resigned from the College on March 19, 2024 and undertook to never seek reinstatement of his Certificate of Qualification and Registration. This will ensure that students are no longer exposed to his racist, culturally insensitive and derogatory comments. The Panel’s order for a four-month suspension will not serve as much of a specific deterrent to the Member, but is important as a general deterrent to other members of the profession, making it clear that the kind of misconduct the Member exhibited is unacceptable. In accordance with the parties’ joint submission, the Member’s suspension will begin on March 12, 2025, which is 15 days after the Panel’s Oral Decision and Order.

24The Panel is satisfied that the penalty is appropriate in the circumstances and meets the principle of serving and protecting the public interest.

Date: February 28, 2025

Élaine Legault Chair, Discipline Panel

Mary Carol Edy, OCT Member, Discipline Panel

Hanno Weinberger, OCT Member, Discipline Panel

Footnotes

1. 1Allegation withdrawn at the request of College Counsel.
2. 2Allegation withdrawn at the request of College Counsel.
3. 3At the time of the hearing, section 32 was amended to be section 26 of the by-laws.
4. 4At the time of the hearing, section 32 was amended to be section 26 of the by-laws.
5. 5See R. v. Anthony-Cook, 2016 SCC 43, [2016] 2 S.C.R. 204, and Bradley v. Ontario College of Teachers, 2021 ONSC 2303.