LAW SOCIETY TRIBUNAL
HEARING DIVISION
Date: June 10, 2026
Tribunal File No.: 24H-116
BETWEEN:
Law Society of Ontario
Applicant
- and -
Glenn Patrick Bogue aka Spirit Warrior
Respondent
Before: Malcolm M. Mercer (Chair), Laura Arndt, Kathleen Lickers
Heard: In writing
Appearances:
Kristin Bailey, for the applicant
No submissions from the respondent
Summary:
BOGUE – Spirit Warrior – Penalty – Ungovernability – The Lawyer maintained that he is not subject to regulation because he is “an unconquered Métis man” – The panel sought submissions from the parties on the appropriate order; the Lawyer did not respond – The Lawyer has continued to practise despite being suspended – The panel concluded that the Lawyer was ungovernable and revoked his licence to practise law, effective June 3, 2026.
REASONS FOR DECISION ON PENALTY
1Malcolm Mercer (for the panel):– In Law Society of Ontario v Bogue, 2026 ONLSTH 91, we have found that the respondent (SW), who also uses the name Spirit Warrior, engaged in professional misconduct. Specifically, we found that SW:
Practised law and/or held himself out as able to practise law when he was not entitled to do so because his licence was suspended by order of the Law Society Tribunal.
Failed to treat the court with courtesy, civility, good faith, and/or encourage public respect for the administration of justice.
2SW’s position is that he is not subject to the authority of the Law Society Act, RSO 1990, c L.8; the Law Society; or the Tribunal because he is an unconquered Métis man – having been born on Turtle Island and having elected to be treated as unconquered. He says that his proven conduct is not subject to regulation under the Law Society Act.
3While we concluded that SW’s conduct was the result of illness, we nevertheless concluded that professional misconduct should be found.
4In paragraphs 147 and 148 of our reasons, we stated:
147Having found professional misconduct and that, by reason of mental illness, SW is unwilling to be subject to regulation, this leaves the question of what conduct order should be made. It appears to follow from our reasons above that SW’s licence should be revoked or surrendered.
148However, we think it proper before finally deciding on the appropriate conduct order to invite SW to file any relevant evidence and written submissions that he may wish to file on this issue. He may do so on or before May 25, 2026.
5Despite this invitation, SW has not filed any evidence or made any submissions.
6For the following reasons, we have revoked SW’s licence to practise law.
ANALYSIS AND CONCLUSION
7The primary purposes of penalty orders are well-established, namely specific deterrence, general deterrence, rehabilitation and restitution, and maintaining public confidence in the legal profession: Law Society of Upper Canada v Strug, 2008 ONLSHP 88.
8SW’s licence has been suspended for many years. He has continued to practise law despite this suspension. He does not accept that he is bound by the suspension order. There is no basis on which to conclude that making any order that does not terminate his licence will have any effect. Suspending SW’s licence, when his licence is already suspended, for failing to comply with the existing suspension order would not satisfy the need for specific deterrence.
9We conclude that maintaining public confidence in the legal profession requires an order that does not simply maintain the status quo. Reasonable members of the public would think it absurd if the consequence of refusing to comply with a suspension order is another suspension order. Maintaining public confidence in the circumstances requires loss of licence.
10SW is clearly ungovernable in the sense that he is unwilling to be bound by his professional obligations. Ungovernability is most often used to describe the point at which progressive discipline has failed to cause a licensee to comply with their professional obligations. The Tribunal has used a two-stage analysis outlined in Law Society of Upper Canada v Shifman, 2014 ONLSTA 21 at para 25 to determine ungovernability.
11This case does not fit well within the Shifman framework. The original suspension order was made in a capacity application. The capacity panel ordered suspension on the possibility that SW might recover from his illness and regain capacity. This is not a case of progressive discipline as the existing suspension order was not made as a penalty for professional misconduct.
12But SW is ungovernable in the sense that he is unwilling to be subject to governance by the Law Society Act, the Law Society, and the Tribunal. SW does not believe that the rules that licensees must follow apply to him, so he is not prepared to abide by these rules. That his belief is the result of mental illness does not change the fact that he is ungovernable. Being a licensee requires being governable as such.
13It is helpful to put the decision that we must make in the context of the original suspension order made in the capacity application. The capacity panel decided to suspend SW’s licence because it could not rule out the possibility of recovery. The capacity panel concluded that “the public interest would be protected by an immediate and indefinite suspension”: Law Society of Ontario v Bogue, 2020 ONLSTH 21 at para 22.
14In retrospect, the public interest has not been protected by the suspension that was ordered in the capacity application. As matters now stand, it is clear that protection of members of the public and the public interest requires loss of licence rather than a suspension. It is likely that SW will continue to represent people in proceedings despite having been found to be incapacitated. His representation of clients to date has been adversely affected by his delusional thinking. There is no reason to think that this will not continue despite the existing suspension. It is necessary to be clear as possible to members of the public and the courts that SW is not entitled to represent clients as a lawyer.
15We conclude that specific deterrence and maintaining public confidence requires loss of licence. It is unfortunate that mental illness has caused SW to be ungovernable, but we conclude that SW cannot continue to be licensed.
16Accordingly, we have ordered that SW’s licence to practise law be revoked. We note that it is open to SW to apply to be licensed again if he does recover.
17If the Law Society seeks costs, it may file written costs submissions and a bill of costs by June 24, 2026, to which SW may respond by July 8, 2026.
ORDER
18On June 3, 2026, we made the following order:
- The respondent’s licence to practise law is revoked, effective immediately.