Licence Appeal Tribunal File Number: 18365/MED

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:

Ryan Doobay

Appellant

And

Registrar of Motor Vehicles

Respondent

DECISION

ADJUDICATORS:

Dr. Dimitri Louvish, Adjudicator Jeffery Campbell, Vice-Chair

APPEARANCES:

For the Appellant:

Ryan Doobay self represented

For the Respondent:

Melissa Litrenta, Representative

HEARD by teleconference: May 12, 2026

OVERVIEW

1Ryan Doobay (the appellant) appeals the February 20, 2026, decision of the Registrar of Motor Vehicles (the Registrar) to suspend his driver’s licence for medical reasons, pursuant to s. 47(1) of the Highway Traffic Act (the “Act”). The medical condition identified is “alcohol use disorder.” By way of letter to the appellant dated April 20, 2026, the condition of “substance use disorder” was added as a reason for suspension.

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 appellant appeals the suspension under s. 50(1) of the Act. He denies that he suffers from alcohol and substance use disorders which interferes with his ability to drive a motor vehicle safely.

4Pursuant to section 50(2) of the Act, after a hearing the Tribunal may confirm, modify, or set aside the decision or order of the Minister.

ISSUES IN DISPUTE

5The issues in dispute are:

i. Does the appellant suffer from the medical conditions of substance use disorder and/or alcohol use disorder; and

ii. If the answer is yes to one or more of the conditions, is that or those conditions likely to significantly interfere with his ability to drive a motor vehicle safely.

RESULT

6Having considered all the evidence and submissions and for the reasons that follow, we find that the Registrar has satisfied its burden to establish that the appellant suffers from alcohol use disorder and substance use disorder that are likely to significantly interfere with his ability to drive a motor vehicle safely. We confirm the Registrar’s decision to suspend the appellant’s driver’s licence.

ANALYSIS

7The Registrar bears the burden of proving on a balance of probabilities that the answer to each of the above questions is “yes”.

The appellant suffers from alcohol use disorder and substance use disorder.

8The evidence presented at the hearing establishes that the appellant suffers from medical conditions, namely substance use disorder and alcohol use disorder.

9The Minister’s position is supported by the following medical reports:

i. A February 12, 2026 Medical Condition Report (“MCR”) from psychiatrist Dr. Lougheed. It indicates that the appellant suffers from alcohol use disorder.

ii. A March 20, 2026 Substance Use Assessment (“SUA”) from addictions specialist, Dr. Fletcher which states that the appellant has the diagnoses of severe substance use disorder pertaining to both alcohol and illicit substances and/or non-prescribed pharmaceuticals. In the SUA, Dr. Fletcher states that the appellant has been abstinent from alcohol and other substances for less than six months and has recently completed a supervised treatment program as a result of his condition.

10The appellant testified that he had “begun abstinence” since a motor vehicle accident in 2024, and that he has been abstinent since February 2026. He further testified that he has completed a rehabilitation program at the Rapid Access Addiction Medicine (RAAM) Clinic in Toronto at which he has been treated by Dr. Fletcher as well as psychiatrist. Dr. Tang.

11The appellant’s own testimony, considered alongside the MCR, the SUA, and the April 15, 2026 correspondence from Dr. Tang confirming that the appellant remains under his ongoing care, provides a comprehensive evidentiary foundation. Taken together, we are satisfied that this evidence establishes that the appellant continues to experience alcohol and substance use disorders, notwithstanding his assertion of abstinence.

The appellant’s medical conditions of alcohol and substance use disorder is likely to significantly interfere with his ability to drive a vehicle safely.

12We find that the Registrar has proven on a balance of probabilities that the appellant’s medical conditions are likely to significantly interfere with his ability to drive a motor vehicle safely.

13The 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 drug rehabilitation program.

14While the appellant did not directly address his ability to operate a motor vehicle safely, he testified that he has been unable to drive due to a spinal injury sustained in a motor vehicle accident in 2024. In addition, his driver’s licence is currently suspended as a result of a 2024 conviction for dangerous driving, unrelated to that accident. Although these circumstances may independently preclude the appellant from being licensed to drive, regardless of the Registrar’s decision of February 20, 2026, they are not determinative of the issue before the Tribunal. The question for determination remains whether the appellant’s medical conditions impair his ability to drive a motor vehicle safely.

15Absent of any evidence to the contrary, we defer to the CCMTA in this instance. We find them reasonable and given the evidence and submissions, we are persuaded to apply the CCMTA Standards in the circumstances of this case.

16The 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.

17In light of the circumstances of this case, we find that it is premature to reinstate the appellant’s driver’s licence. At the time of the hearing, the appellant had been abstinent for only approximately three months. This period falls short of the CCMTA standards, which contemplate confirmation of a longer duration of abstinence before reinstatement may be considered. Additionally, there is no supportive recommendation from a treating healthcare provider endorsing an earlier return to driving. Accordingly, we find that the requirements set out in CCMTA Standard 15.6.3 have not been satisfied.

18We are satisfied on a balance of probabilities that the appellant’s medical conditions are likely to significantly interfere with his ability to drive safely.

ORDER

19For the reasons set out above, pursuant to subsection 50(2) of the Act, we confirm the Registrar’s decision to suspend the appellant’s driver’s licence.

Released: May 15, 2026

__________________________

Dr. Dimitri Louvish, MD

Adjudicator

__________________________

Jeffery Campbell

Vice-Chair