Licence Appeal Tribunal File Number: 18043MED
In the matter of an appeal under subsection 50(1) of the Highway Traffic Act, R.S.O. 1990, c. H.8 (the “Act”), from a decision of the Registrar of Motor Vehicles to suspend a licence pursuant to Section 47(1) of the Act.
Between:
Laura-Lee Bradie
Appellant
and
Registrar of Motor Vehicles
Respondent
DECISION
ADJUDICATOR: Kailey Minnings, MD
APPEARANCES:
For the Appellant: Laura-Lee Bradie, self represented
For the Respondent: Melissa Litrenta, Representative
HEARD by teleconference: February 4, 2026
OVERVIEW
1Laura-Lee Bradie (the “appellant”) appeals from the decision of the Registrar of Motor Vehicles (“Registrar”) to suspend her Class G licence under s. 47(1) of the Highway Traffic Act, R.S.O. 1990, c. H.8 (the “Act”) after the Registrar received a report from a treating health care provider that the appellant suffers from a medical condition that may affect her ability to drive safely.
2The Registrar has the authority under s. 47(1)(g) of the Act to suspend or cancel a driver’s licence for any sufficient reason. Section 14(1)(a) of O. Reg. 340/94 under the Act (the “Regulation”) states that a holder of a driver’s licence must not suffer from any mental, emotional, nervous or physical condition or disability likely to significantly interfere with their ability to safely drive a motor vehicle of the applicable class safely. Under s. 14(2)(b) of the Regulation, the Minister of Transportation may require a driver to provide satisfactory evidence that they are able to drive safely.
3The Registrar takes the position that the appellant suffers from a medical condition, namely alcohol use disorder, that is likely to significantly interfere with her ability to drive safely and that this provides sufficient reason to suspend her licence under s. 47(1)(g) of the Act.
4The appellant appeals the suspension under s. 50(1) of the Act. She denies that she suffers from alcohol use disorder and denies that she suffers from a medical condition which interferes with her ability to drive safely.
5Pursuant to section 50(2) of the Act, after a hearing the Tribunal may confirm, modify, or set aside the decision or order of the Registrar.
ISSUES
6The issue in this appeal is whether the appellant suffers from a medical condition that is likely to significantly interfere with her ability to drive a motor vehicle safely.
7To resolve that issue, I will address the following questions:
i. Does the appellant have alcohol use disorder?
ii. If so, is this likely to significantly interfere with her ability to drive a motor vehicle safely?
8The Registrar bears the burden of proving on a balance of probabilities that the answer to each of the above questions is “yes.”
RESULT
9Having considered all the evidence and submissions and for the reasons that follow, I find that the Registrar has satisfied its burden to establish that the appellant suffers from a medical condition that is likely to significantly interfere with her ability to drive a motor vehicle safely and I confirm the Registrar’s decision to suspend the appellant’s driver’s licence.
ANALYSIS
Does the appellant suffer from alcohol use disorder?
10The evidence presented at the hearing establishes that the appellant has a medical condition, namely alcohol use disorder.
11The Registrar’s position is supported by several medical reports:
i. A Medical Condition Report (“MCR”) completed by ER physician Dr. Macdonald dated May 13, 2025, which indicates that the appellant has a Substance Use Disorder – alcohol, and depression.
ii. A Substance Use Assessment form (“SUA”), completed by family physician Dr. Colbran, dated January 15, 2026, which indicates that the appellant has a moderate-severe substance use disorder, specifically with alcohol; that she has completed a supervised treatment program in July 2024; and that, to the physician’s knowledge, the appellant has abstained from alcohol for 6-12 months. Dr. Colbran writes, “This is based on patient report of abstinence. I do not have reason to believe that she has drank, but she has not been honest with other aspects (ie saying she hasn’t been driving when she has).”
iii. A Mental Health Assessment form (“MHA”), also completed by family physician Dr. Colbran, dated January 15, 2026, which indicates that the appellant has a diagnosis of “?depression secondary to alcohol”, that this condition is stable with symptoms resolved for 6-12 months; and that “per the patient she doesn’t have issues with depression outside of alcohol use and she has been sober since May 2025.”
12The appellant denies that she suffers from alcohol use disorder. She testified that aside from a few occasions, she has been abstinent of alcohol for most of the past 7 years and that she never has alcohol in her house. She testified that she enrolled herself in a month-long, inpatient supervised treatment program in 2024 not because of heavy alcohol use, but to “get her life back in order.”
13I prefer the opinions of the two physicians that the appellant has an alcohol use disorder to the appellant’s testimony that she does not. Through their medical training and practice, both Dr. Colbran and Dr. Macdonald would have knowledge and expertise relating to the diagnosis of alcohol use disorder.
14Further, the appellant testified that she has been a patient of Dr. Colbran for 3 years. As her family physician, Dr. Colbran would have a good understanding of the appellant’s medical conditions and diagnoses. As such, I place significant weight on Dr. Colbran’s opinion that the appellant has a moderate to severe alcohol use disorder.
15Finally, I find it unlikely that the appellant would voluntarily enrol in a month long inpatient supervised treatment program if she did not have an alcohol use disorder.
16I find that the Registrar has established on a balance of probabilities that the appellant suffers from alcohol use disorder.
Is the appellant’s medical condition likely to significantly interfere with her ability to drive a motor vehicle safely?
17I find that the Registrar has proven on a balance of probabilities that the appellant’s medical condition is likely to significantly interfere with her ability to drive a motor vehicle safely.
18The Registrar argues that alcohol use disorder interferes with the appellant’s ability to drive safely. The Registrar relies on the Canadian Council of Motor Transport Administrators Medical Standards for Drivers [February 2021] (the “CCMTA Standards”), Chapter 15.6.3, which states that all drivers suffering from Substance Use Disorder, including alcohol, may be eligible for a licence if they meet the criteria for remission and/or have abstained for twelve months. It also states that earlier re-licencing may be considered upon favourable recommendation from an addiction specialist and/or treating physician recognized by the licensing authority, and the successful completion of a rehabilitation program.
19Section 14(2)(a) of the Regulation allows the Registrar to consider the CCMTA Standards when determining whether the requirements of s. 14(1) are met. The Tribunal may take the CCMTA Standards into consideration but are not bound by them.
20The respondent’s position is that the appellant has not demonstrated the period of abstinence set out in the CCMTA standards. The respondent explained that while Dr. Colbran indicated on the January 15, 2026 SUA form that the appellant had been abstinent for 6-12 months, the physician also noted that this was based on the appellant’s self-report and “she has not been honest with other aspects (ie saying she hasn’t been driving when she has).”
21The respondent’s representative also pointed to the appellant’s driving record, which shows that on October 31, 2025, the appellant was issued an administrative driver’s licence suspension until January 29, 2026. The respondent’s position is that the appellant has therefore not been abstinent for the time period that is indicated on Dr. Colbran’s report.
22The appellant testified that she was charged with impaired driving on October 31, 2025 and that she pled guilty to the charge. She testified that her last drink of alcohol was on that date. Her position is that, aside from this incident, alcohol is not an ongoing problem for her.
23The appellant testified that she currently sees a therapist regularly. She does not see anyone or receive any treatment for alcohol use.
24While the CCMTA Standards are well-reasoned and provide assistance, every case must be considered on its own facts.
25Although I am not bound by the CCMTA Standards, I find them reasonable and given the evidence, I am persuaded to apply the CCMTA Standards in the circumstances of this case.
26The use of alcohol affects the functions necessary for driving including reaction times, visual acuity, judgement and insight, alertness and motor co-ordination. The use of alcohol impairs a driver’s judgment and behaviour towards others, including in determining whether they are fit to drive or not.
27I am concerned that, based on the evidence and testimony, the appellant has continued to drink alcohol as recently as October of 2025 when she was charged with impaired driving. Further, the appellant testified that she does not have any ongoing problem with alcohol, which I find suggests that she lacks insight into her alcohol use disorder. Insight means that a driver: is aware of their medical condition; understands how the condition may impair their functional ability to drive; and has the judgment and willingness to comply with their treatment regime and any conditions of licensing. Insight is an important consideration when determining fitness to drive.
28I agree with the CCMTA standards which require, among other things, confirmation of a longer period of abstinence prior to considering reinstatement of a driver’s licence. I acknowledge that while the appellant did attend and complete an intensive alcohol treatment program, the program was completed before the MCR was filed. The appellant does not have a favourable recommendation from a treating healthcare professional for earlier re-instatement of her driver’s licence. Therefore, the criteria set out in CCMTA Standard 15.6.3 have not been met.
29I am satisfied on a balance of probabilities that the appellant’s medical condition is likely to significantly interfere with her ability to drive safely.
Conclusion
30I find that the Registrar has discharged the onus of establishing on a balance of probabilities that the appellant suffers from a medical condition, namely alcohol use disorder, that is likely to significantly interfere with her ability to drive a motor vehicle safely.
ORDER
31For the reasons set out above, pursuant to subsection 50(2) of the Act, I confirm the Registrar’s decision to suspend the appellant’s driver’s licence.
Released: February 19, 2026
Kailey Minnings

