Ontario College of Teachers v. Hanley, 2025 ONOCT 63

DISCIPLINE COMMITTEE OF THE ONTARIO COLLEGE OF TEACHERS

Citation: Ontario College of Teachers v Hanley 2025 ONOCT 63

Date: 2025-09-30

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

Michael Gordon Hanley, OCT, a member of the Ontario College of Teachers.

BETWEEN:

ONTARIO COLLEGE OF TEACHERS

– and –

MICHAEL GORDON HANLEY (REGISTRATION #492558)

PANEL: Kayla Stephenson, Chair Andrew Glenny Linda Staudt, OCT

HEARD: September 25, 2025

Jordan Glick, for the Ontario College of Teachers Parmbir Gill, for Michael Gordon Hanley Emily Graham, Independent Legal Counsel

PUBLICATION BAN: Pursuant to subsection 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 September 25, 2025, in accordance with rule 8.01 of the Rules of Procedure of the Discipline Committee and of the Fitness to Practise Committee.

2Michael Gordon Hanley (the “Member”) attended the hearing and 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 dated September 16, 2024 (Exhibit 1) are as follows:

IT IS ALLEGED that Michael Gordon Hanley is guilty of professional misconduct as defined in the Act in that:

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

(b) 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);

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

C. STATEMENT OF UNCONTESTED FACTS

5College Counsel presented the Panel with the parties’ Statement of Uncontested Facts and Plea of No Contest (Exhibit 2), which provides the following:

1. At all material times, Michael Gordon Hanley was a member of the Ontario College of Teachers. Attached hereto and marked as Appendix “A” is a copy of the College’s Registered Member Information with respect to the Member.

2. From September 2006 to June 2016, the Member was employed by the Toronto District School Board (the “Board”) as a teacher at [XXX] (“School 1”) located in Toronto, Ontario. From September 2016 to January 2023, the Member was employed by the Board as an [XXX] teacher at [XXX], a [XXX] school located in Toronto, Ontario (“School 2”).

The Investigation

3. In May 2022, a student at School 2 informed the school’s administration that the Member was posting content of concern to the student on his Twitter¹ account. At about the same time, a parent of a student at [XXX] Public School, a feeder school to School 2, contacted School 2 to indicate that they had seen the Twitter account belonging to the Member and that their daughter would not be attending School 2 as she would be unsafe. The parent asked what School 2 would be doing about the Member.

4. The Member was placed on home assignment on May 19, 2022, pending the Board’s investigation (the “2022 Investigation”). The Member was subsequently disciplined by the Board, the details of which are not reproduced in this Statement of Uncontested Facts.

5. During the 2022 Investigation, the Board supplied to the College additional information relating to two prior investigations into the Member’s conduct that had not previously been brought to the attention of the College as follows:

(a) An investigation into concerns raised by the Member’s use of social media between April 2012 and February 2015 (the “2015 Investigation”); and,

(b) An investigation in 2016 (the “2016 Investigation”) into a personal relationship between the Member and a [XXX] year-old female student (“Student 1”) at School 1 that crossed professional boundaries.

The 2015 Investigation

6. Between April 2012 and February 2015, the Member communicated with students via the social media platform Twitter², including, but not limited to, posting, replying, tweeting and retweeting statements that included content that did not relate to an educational or school-related purpose.

7. Between April 2012 and February 2015, the Member posted the following statements on his Twitter account which were unprofessional, offensive and in some cases discriminatory. The Member’s tweets were publicly available between 2012 and 2015 and had been viewed by students and former students:

(a) “did @pmharper want to make sure they would only be used by Saudi trained and funded militants to go kill Shi’a Muslims in the region”;

(b) “I don’t want one penny of my tax dollars going to support Israel or Saudi fucking Arabia”;

(c) “… stupid. fuck Saudi Arabia. all they do is take oil money from the USA so the USA can fuel their tanks and guns to kill Muslims because”;

(d) “Saudi Arabia supplies terrorists with guns to go kill Muslims (and very occasionally westerners)”;

(e) “wow, great guys. keep telling me I should follow their Islam because it’s authentic #YoureDumb”;

(f) “if I’ve said it once, I’ve said it a thousand times… fuck Israel”;

(g) “hey ISIS fan boys – why you think ISIS is so good cuz they be killing other Muslims but never say nothing about them not helping any Muslims?”;

(h) “how about y’all roll into Palestine & kill an Israeli or two. build some houses for Palestinians. protect their borders. provide them w food”;

(i) “… in other words, operate like a real calipha”;

(j) “but let’s look at what Hezbollah does – provides aid and protection in Southern Lebanon. protects important religious sites”;

(k) “but you’re pro ISIS. & you say you follow “real” Islam. laughable little Salafi shits you are”;

(l) “this is an aggressive & therefore permits an aggressive response” in response to a news article entitled “Israel upped settler construction in 2014”;

(m) “number one … Music is crack for the brain. is this why it’s haram in Islam”;

(n) “lmao. who knew Justin Bieber is a gateway drug more than marijuana”; and

(o) “Christmas concerts at the @tdsb mostly consist of white teachers getting hindu and Muslim students to sing the whitest of white Xmas carols”.

8. Between April 2012 and February 2015, the Member posted the following tweets that were unprofessional and offensive about School 1 and students and staff at School 1:

(a) “for once at a [XXX] event the teacher table actually seems like the most fun table #Dry #Semiformal”; and

(b) “come to [XXX]” in response to a Twitter user stating, “I have yet to meet an ugly Arab girl”.

9. In 2015, after the tweets were brought to the attention of School 1’s administration and the Board, school administrators spoke to the Member and the Member was advised that his comments were deemed to be inappropriate. The Member subsequently deleted his account. The tweets excerpted above have not been publicly accessible since 2015.

The 2016 Investigation

10. Between April 2016 and June 2016, the Member crossed professional boundaries by forming a personal relationship with Student 1. His conduct included:

(a) befriending Student 1;

(b) adding her to a public, school-related page on the social media platform Facebook;

(c) sharing personal information about his family with Student 1;

(d) spending time with Student 1 in his classroom during educational breaks for non-educational purposes;

(e) asking Student 1 to meet him in his classroom;

(f) meeting Student 1 alone in his classroom on one occasion after Student 1 passed by and entered the classroom;

(g) arm wrestling with Student 1;

(h) engaging in communications of a personal nature with Student 1, including outside of school hours;

(i) making inappropriate and boundary crossing comments to Student 1, including, but not limited to, the following:

i. telling her she looked beautiful, cool and great, in response to her describing herself as ugly;

ii. telling her that if she wanted his eyes, she could take them, in response to her complimenting his eyes;

iii. telling her that she should be in School 1’s fashion show;

iv. complimenting her on her clothing;

v. calling her by the nickname, “Queen of Sheba;” and

vi. telling her that, as a school [XXX] coach, he would teach her [XXX] and [XXX], in response to her request that he do so.

(j) in May 2016, the Member told Student 1 that they had to stop communicating because there were rumours about them going around;

(k) in June 2016, the Member contacted Student 1 telling her that he missed her; and

(l) in June 2016, the Member shared with Student 1 that he had a dream about her but could not share the details of the dream.

11. In June 2016, the Member received a letter of reprimand from the Board relating to breaches of professional standards as they related to his relationship and conduct with Student 1.

2022 Investigation

12. The 2022 investigation uncovered that the Member, between 2020 and 2022, had resumed posting on Twitter through a new account which did not include his real name and did not identify him as a teacher or Board employee. If the Member were to testify, he would say that he intended this account to be private and mistakenly believed he was tweeting in a secure private setting. Among his tweets, he posted the following which were unprofessional and offensive:

(a) “God was really in His bag when he created women. Like, he made man, took a step back and said, “I can do better,” and then created women”;

(b) “Was wondering why that pizza was so delicious” in response to a picture with the caption, “Pizza Delivery Woman Squirts Vaginal Fluid All Over the Pizzas of Known Non Tipping Customers”;

(c) “You know you’re down bad when you catch yourself wondering what her vagina smells like”;

(d) “Sometimes I get reminded me of the bad old days where I had zero emotions about the most fucked up things. Like the time I knew my fiance was getting pegged in the backroom by our coke dealer but I didn’t care cuz her best friend was blowing me on the couch”;

(e) “Remembering the days when I’d work two weeks and get a paycheck that had a number that didn’t need commas. How did I have a cocaine problem on that budget? Lol”; and

(f) “Yo this happened to me. I got called in for a meeting to council me about my tweets. It was sooooo embarrassing to have the Principal of my school at the time read them back to me. I was trying not to laugh cuz they were bangers but it was a serious matter”.

PLEA OF NO CONTEST

13. By this document, the Member agrees that the Discipline Committee can accept as correct for the purposes of this proceeding only the facts and appendices referred to in paragraphs 1-12 above (the “Uncontested Facts”).

14. The Member hereby acknowledges that the conduct contained within paragraph 6-12 of the Uncontested Facts constitutes conduct which is professional misconduct as defined in the Ontario College of Teachers Act, 1996 and pleads no contest to the allegations of professional misconduct against him, being more particularly:

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

(b) he committed an act or 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); and,

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

15. 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 Uncontested Facts being presented to the Discipline Committee;

(c) he understands that, by pleading no contest 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 with respect to the penalty proposed does not bind the Discipline Committee;

(f) he understands and acknowledges that he is executing this Agreement voluntarily, unequivocally, and having had the opportunity to obtain legal advice.

16. The Member provides this plea of no contest pursuant to Rule 3.02 of the Rules of Procedure of the Discipline Committee and Fitness to Practise Committee under protection of the Evidence Act, R.S.O. 1990, for the purposes of this proceeding under the Ontario College of Teachers Act, 1996, and for no other purpose. The Member’s plea of no contest does not constitute an admission by the Member as to the facts or findings in this or any other civil, criminal or administrative proceeding.

17. In light of the Uncontested Facts and circumstances and the plea of no contest, the Ontario College of Teachers and the Member submit that the Discipline Committee find the Member guilty of professional misconduct.

D. DECISION

6Having considered the Statement of Uncontested Facts and Plea of No Contest and the submissions of the parties, the Panel rendered an oral decision on September 25, 2025 finding that the Member engaged in acts of professional misconduct as alleged, contrary to Ontario Regulation 437/97, subsections 1(7.2), 1(18) and 1(19).

E. REASONS FOR DECISION

7The Member did not contest the facts and exhibits referred to in paragraphs 1 to 12 of the Statement of Uncontested Facts and Plea of No Contest and pleaded no contest to the allegations of professional misconduct against him. He acknowledged and the Panel accepts that the conduct set out in paragraphs 6 to 12 of the Uncontested Facts constitutes professional misconduct under the heads of misconduct set out above. The Uncontested Facts demonstrate that the Member posted inflammatory, offensive, unprofessional and discriminatory statements on his publicly available Twitter accounts and crossed professional boundaries by forming a personal relationship with a student.

8The Uncontested Facts demonstrate that the Member abused a student or students psychologically or emotionally, contrary to subsection 1(7.2) of Ontario Regulation 437/97. The Member crossed professional boundaries by forming a personal relationship with Student 1, which included befriending her, sharing personal information about his family with her, meeting her alone in his classroom and making inappropriate comments to her. Members of the profession are expected to maintain professional boundaries with students at all times and ensure their psychological and emotional well-being. The Member abused his position of power to exploit a vulnerable student. The Member was aware that the personal relationship he had formed with Student 1 raised concerns and told her that they needed to stop communicating, yet he reached out to her a month later to tell her that he missed her and had a dream about her, this was emotionally abusive.

9The Panel finds that the Member committed acts that would reasonably be regarded by members as disgraceful, dishonourable or unprofessional, contrary to subsection 1(18) of Ontario Regulation 437/97. The Member’s inappropriate conduct towards Student 1 was disgraceful, dishonourable and unprofessional. The Member failed to maintain appropriate professional boundaries with Student 1 and formed a personal inappropriate relationship with her. This demonstrates an element of moral failing and disregard towards his professional duties. It was also disgraceful, dishonourable and unprofessional for the Member to have posted inflammatory, offensive and discriminatory statements on his Twitter accounts, which was publicly available. Teachers hold a unique position of trust in society and, by virtue of their important role in their communities, they must conduct themselves appropriately both inside and outside of the classroom.

10Finally, the Uncontested Facts demonstrate that the Member engaged in conduct unbecoming a member, contrary to subsection 1(19) of Ontario Regulation 437/97. The public’s trust in the teaching profession is eroded when members share inflammatory, offensive and discriminatory content on social media. This was evident by the fact that a student from the Member’s school and a parent of a student from a feeder school made a complaint to the Member’s school administration regarding his online comments. The parent even indicated that their daughter would not be attending the Member’s school because she felt it was unsafe. The Member’s conduct clearly had an effect on the public’s confidence in the teaching profession.

F. PENALTY DECISION

11The parties entered into a Joint Submission on Penalty (Exhibit 3), which was presented to the Panel. In an oral decision rendered on September 25, 2025, the Panel accepted the Joint Submission on Penalty and made the following order:

1. The Member is directed to appear before the Discipline Committee immediately following the hearing of this matter to receive a reprimand, which will be delivered electronically, and the fact of the reprimand is to be recorded on the Register of the Ontario College of Teachers;

2. The Registrar is directed to suspend the Certificate of Qualification and Registration of the Member for a period of 10 months commencing on the 15th calendar day following the date of the Decision and the Order of the Discipline Committee relating to this matter;

3. The Registrar is directed to impose the following terms, conditions, or limitations on the Member’s Certificate of Qualification and Registration:

(a) within 120 days of the date of the Order of the Discipline Committee, the Member shall enrol in and successfully complete, at his own expense, coursework of instruction pre-approved by the Registrar regarding cultural sensitivity, systemic racism, the appropriate use of social media and professional boundaries, subject to the following conditions:

i. the Member shall provide the course practitioner approved by the Registrar a copy of the Statement of Uncontested Facts and Plea of No Contest and Joint Submission on Penalty documents made exhibits at the hearing of this matter, and the Decision and Reasons of the Discipline Committee;

ii. upon review of the documents noted at paragraph 3(a)(i) above, the course practitioner shall provide to the Registrar, for approval, a syllabus for the proposed course which specifically addresses the Discipline Committee's concerns regarding the Member's professional misconduct. The syllabus proposed by the course practitioner shall also specify the length of the course to be undertaken by the Member and the assignments to be completed by the Member; and

(b) within 30 days of his completion of the course outlined in paragraph 3(a) above, the Member shall provide to the Registrar a report from the course practitioner stating that the Member has successfully completed the course and reporting on the progress of the Member with respect to addressing the outlined goals of the course.

G. REASONS FOR PENALTY DECISION

12The Panel accepts the penalty jointly proposed by the parties. 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.³ The Panel finds that 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 College Counsel: Ontario College of Teachers v Chrisopoulos, 2022 ONOCT 101; Ontario College of Teachers v Konstantinidis, 2023 ONOCT 32; Ontario College of Teachers v Suzuki, 2019 ONOCT 75; Ontario College of Teachers v Flitton, 2021 ONOCT 25; Ontario College of Teachers v Ubertelli, 2015 ONOCT 81; Ontario College of Teachers v Schmoll, 2024 ONOCT 5, 2024 ONOCT 05; Ontario College of Teachers v Dalamba, 2024 ONOCT 1, 2024 ONOCT 01; Ontario College of Teachers v Bohn, 2022 ONOCT 41; Ontario College of Teachers v Byers, 2021 ONOCT 90; and Ontario College of Teachers v Handscomb, 2022 ONOCT 63.

13The Panel considered the Member’s circumstances in comparison to the cases provided. The aggravating factors in the Member’s case are: 1) the fact that the Member was warned about his use of Twitter by the school administrators yet persisted in such conduct seven years later; and 2) the impact of the Member’s online conduct on the community (i.e., that a student and a parent made complaints to school administration). In terms of mitigating factors, the Member did not contest 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.

14The Panel finds that the Member’s inappropriate conduct warrants a reprimand. Members of the teaching profession hold a unique position of trust and authority, and they are expected to act as positive role models. By posting offensive and discriminatory statements on his Twitter accounts and by crossing professional boundaries with a student, the Member has tarnished the reputation of the teaching profession. 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.

15Given the nature and severity of the Member’s misconduct, the Panel finds that a 10-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. The suspension will serve as a specific deterrent to the Member and a general deterrent to other members of the profession, making 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 October 10, 2025, which is 15 days after the Panel’s oral Decision and Order.

16The Panel finds that the course of instruction regarding cultural sensitivity, systemic racism, the appropriate use of social media and professional boundaries will assist in the rehabilitation of the Member. The coursework will remind the Member of his obligations as a teacher with respect to the appropriate use of social media and will help him to make better decisions in any future interactions with students.

17The Panel is satisfied that the penalty is appropriate in the circumstances and meets the principle of serving and protecting the public interest.

Footnotes

1. 1This social media application was renamed “X” in July 2023. All references to posts after July 2023 appeared on X, but are referred to herein as Twitter.
2. 2All tweets in this SUF are reproduced as they were written.
3. 3See R. v. Anthony-Cook, 2016 SCC 43, [2016] 2 SCR 204, and Bradley v. Ontario College of Teachers, 2021 ONSC 2303.