Date: March 31, 2026

Tribunal File No.: 25H-040

BETWEEN:

Law Society of Ontario

Applicant

and -

Kristofer Brendan Beau Angle

Respondent

Before: Kathleen Lickers (chair), Ingrid Berkeley, Mark Surchin

Heard: February 10, 2026, by videoconference

Appearances:

Louise Hurteau, for the applicant

Daniel Goldbloom and Caterina Cavallo, for the respondent

Summary:

ANGLE – Criminal Charges – Failure to Report – The Lawyer was charged with assaulting his spouse though the charge was later withdrawn – The Lawyer did not report the charge – The Lawyer was later charged with additional criminal offences – Intimate partner violence is inherently incompatible with professional responsibilities of trust and integrity – The panel determined that a suspension was necessary but the duration of suspension would be informed by the Lawyer’s commitment to rehabilitation and mitigating steps he continued to take – The Lawyer was suspended for two months and ordered to pay $7,500 in costs to the Law Society.

1Kathleen Lickers (for the panel):– This is an application brought by the Law Society of Ontario alleging that Kristofer Brendan Beau Angle (the Licensee) engaged in conduct unbecoming by committing the criminal offence of assault contrary to s 266 of the Criminal Code and professional misconduct for his failure to report the criminal charge to the Law Society.

2The application comes before us on the basis of an agreed statement of facts (ASF) in which the Licensee confirms that he understands the allegations and voluntarily admits the truth of facts set out in the ASF and the authenticity of the documents provided in support thereof. The Licensee, in addition to adopting the ASF, gave oral evidence and provided a written letter which was entered into evidence.

3The Licensee voluntarily admits that the facts recounted in the ASF constitute professional misconduct and conduct unbecoming as alleged in the notice of application.

4As a preliminary matter, the Law Society requested an order under Rule 13.3(1)(2) of the Tribunal Rules of Practice and Procedure to protect the personal and identifying information of the Licensee’s former spouse and minor child. We granted the order and accepted the Law Society’s redacted book of documents filed as an exhibit to ensure compliance with the order while minimizing any restriction on openness.

5We accept the Licensee’s admissions and find he engaged in conduct unbecoming and professional misconduct as alleged.

6The appropriate penalty was not agreed. For the reasons that follow, we order a two-month suspension of his licence effective two weeks following release of our reasons for decision. We accept the joint submission of the parties on costs.

7These are our reasons.

BACKGROUND

8Kristofer Angle was born in 1983 and called to the Ontario Bar in 2016. He practises insurance law as an associate for a firm in Hamilton, Ontario. At the time of the events giving rise to the criminal charge he was married and the father of a 20-month-old son.

Criminal proceedings

9On September 4, 2021, the Licensee was arrested and charged with assault of his then spouse, S, contrary to s 267(c) of the Criminal Code. He denied the allegation, and the Crown eventually withdrew this charge. He did not report this charge to the Law Society as soon as reasonably practicable as required by By-Law 8 and the Rules of Professional Conduct.

10Following his arrest, the Licensee was not held for a bail hearing but was released on an undertaking to follow certain conditions common in allegations of intimate partner violence. These conditions included no communication with his spouse except through a third party contact for childcare and custody issues, and to keep 100 metres from S, except in the presence of the Hamilton Police for the purpose of removing property.

11The Licensee and S separated in September 2021 after four years of marriage. He commenced family law proceedings in the Ontario Superior Court seeking, amongst other things, joint custody of their son.

12On March 24, 2022, the Licensee was charged with additional criminal offences that pre-dated the September 2021 charge. The March 2022 charges included:

Assault with a weapon (a water bottle) on August 21, 2021, contrary to s 267(a) of the Criminal Code.
Assault on July 10, 2021, contrary to s 266 of the Criminal Code.
Uttering a threat to damage real or personal property (cell phone) on July 10, 2021, contrary to s 264.1(3) of the Criminal Code.
Assault on May 3, 2021, contrary to s 266 of the Criminal Code.
Assault on March 1, 2021, contrary to s 266 of the Criminal Code.
Mischief in relation to property not exceeding a value of $5,000 (cell phone) on March 1, 2021, contrary to s 430(4) of the Criminal Code.
Assault with a weapon (a plate) on April 9, 2020, contrary to s 267(a) of the Criminal Code.
Assault with a weapon (a pumpkin) on November 1, 2018, contrary to s 267(a) of the Criminal Code.

13The Licensee was not held for bail and was again released on an undertaking with the same conditions as before. These conditions were varied on June 14, 2022 on consent of the Crown to allow the Licensee to be within 100 metres of S and communicate with S through Family Court counsel and for attendance at Family Court.

14On August 29, 2022, the Licensee, represented by counsel, pled guilty before the Ontario Court of Justice on one count of simple assault on May 3, 2021, contrary to s 266 of the Criminal Code. As part of the guilty plea, the Crown read into the record several incidents that occurred between November 1, 2018 and July 10, 2021, which the Licensee accepted as accurate:

During a verbal argument, walking toward S with a clenched fist, spitting in her face, and attempting to grab her phone.
Bodychecking S.
When S began filming the Licensee during a verbal argument, the Licensee grabbed her arm, took her cellphone and threw it, shattering the screen.
The Licensee yelled and threw a plate at S, which shattered. He yelled for S to leave the kitchen, or he would throw another plate.
The Licensee threw a pumpkin at S, hitting her face causing a scratch and bruise to the left side of her face.

15The Crown did not read in any facts relating to the assault in September 2021.

16A joint submission on sentencing was accepted by the court:

…a conditional discharge and two years probation with conditions to keep the peace and be of good character; appear before the court as required; notify the court or probation officer in advance of any change of name or address; report as directed by the probation officer; have no contact with S except through legal counsel, incidental to court proceedings, pursuant to a Family Court order or as agreed upon by Family Law counsel, or through a mutually agreeable third party for access to the child; to stay more than 50 metres from S except with the named exceptions; and to take counselling as directed by the probation officer.

17The Licensee completed probation successfully in August 2024.

18S provided a written Victim Impact Statement in the Ontario Court of Justice proceedings. In her statement, S described the emotional trauma she suffered because of years of abuse and her continued fear of the Licensee.

19The Licensee’s counsel filed four letters in the Ontario Court of Justice proceedings to demonstrate his counselling efforts, including anger management, psychotherapy, and local family services programs covering many topics addressed in the Partner Assault Response (PAR) Program including anger management, empathy/respect, communication, and healthy relationships.

20His professional counselling efforts are ongoing to this day and, as stated in the ASF, he continues rehabilitative efforts to address the root issues that led to the criminal charges.

Failure to report to the Law Society

21The Licensee first notified the Law Society of all of the criminal charges by email on March 25, 2022. The Law Society sought further information by return email on April 11, 2022, when it questioned the nature of the offence(s), when it occurred, and whether the criminal charge was related to his legal practice or personal life.

22In his response the same day, the Licensee acknowledged that he erroneously relied on Rule 7.1-3(c) and believed he did not have a duty to report, explaining his belief that the initial charge on September 4, 2021, aggravated assault, s 267(c) of the Criminal Code, was scheduled to be withdrawn when the March 2022 charges were laid.

23The Law Society enquired into the timing of reporting the September 2021 charge. On June 17, 2022, the Licensee explained that he had reviewed the Rules of Professional Conduct and interpreted Rule 7.1-3 as not requiring him to report at the time he was charged because it was not related to his practice. However, after informing his mentors at work, he became aware of and reviewed By-Law 8 and immediately reported himself to the Law Society.

24The Licensee has no discipline history.

FINDINGS

25Rule 1.1-1 defines conduct unbecoming a barrister or solicitor to mean:

conduct, including conduct in a lawyer’s personal or private capacity, that tends to bring discredit upon the legal profession including, for example,

(a) Committing a criminal act that reflects adversely on the lawyer’s honesty, trustworthiness, or fitness as a lawyer,

26Rule 7.1-4.4 states, “If a lawyer is charged with an offence described in By‑Law 8 of the Law Society, he or she shall inform the Law Society of the charge and of its disposition in accordance with the by-law.”

27By-Law 8 states:

2.(1) Every licensee shall inform the Society in writing of,

(a) a charge that the licensee committed,

(i) an indictable offence under the Criminal Code (Canada) ….

28The Licensee admits that the conduct leading to his criminal conviction constitutes conduct unbecoming under Rule 1.1-1 and s 33 of the Law Society Act, RSO 1990, c L.8 (the Act). Further, he admits that his failure to report the September 2021 charge constitutes professional misconduct under By-Law 8 and the Rule 7.1-4.4.

29Based upon the Licensee’s admissions and the contents of the ASF, we find that the Licensee engaged in conduct unbecoming a licensee by committing the criminal offence of assault for which he received a conditional discharge; and professional misconduct by failing to comply with mandatory reporting requirements.

30We now turn to consideration of penalty in accordance with s 35 of the Act.

PENALTY

31While the parties reached agreement on the facts and presented a joint submission on costs (to be addressed later in our reasons), penalty is a contested matter. The Law Society seeks a suspension of three months to begin within two weeks of our order. The Licensee submits that the appropriate penalty is a reprimand.

32The Law Society submits that the Licensee’s admission to assault against his former spouse and our findings of both conduct unbecoming and professional misconduct for failing to report the September 2021 charge to the Law Society are serious breaches that strike at the core of the expectations of integrity, candour and public trust.

33It is the Law Society’s submission that intimate parter violence is an issue well recognized as socially important and represents a profound breach of trust. It causes lasting harms to victims, families, and communities. As officers of the court, lawyers are expected to model respect for the law at all times. When a lawyer engages in violence, the public must be left in no doubt that the Law Society takes such conduct with the utmost seriousness.

34The Licensee’s co-operation in this proceeding, which obviated the need for testimony from the victim and other types of evidence, is acknowledged by the Law Society. However, it submits that the nature of the misconduct, occurring in private; the pattern of violence for a duration of years; and the Licensee’s failure to uphold his professional duty of self reporting warrants a meaningful penalty that denounces the behaviour, protects the public, and upholds the reputation of the legal profession.

35The Licensee has no prior discipline history. He seeks a reprimand and distinguishes the Tribunal’s prior jurisprudence from the facts of this case on the basis of the Licensee’s demonstrated insight, remorse, and accountability. He agrees his conduct is serious and reflected a pattern over that period in his life but was behaviour out of character with who he is now.

36The four goals of penalty have been clearly enumerated by Tribunal jurisprudence. These goals are general deterrence, specific deterrence, rehabilitation and maintaining public confidence in the professions: Law Society of Upper Canada v Strug, 2008 ONLSHP 88, Law Society of Ontario v Subramanian, 2023 ONLSTH 42.

37The Law Society also relies upon the recent decision in Law Society of Ontario v Patterson, 2025 ONLSTH 41, for the principle that Tribunal hearings, unlike criminal proceedings, are designed to prioritize protection of the public and preservation of the reputation of the profession over consequences to the member.

38The Law Society submits that specific deterrence is not a key factor here and accepts that the risk of recurrence by this Licensee is low. Rather, they argue the penalty principles of general deterrence and public confidence in the legal profession are the key considerations that may outweigh even strong mitigation in intimate partner cases.

39The Licensee accepts our findings and acknowledges the gravity of intimate partner violence and expresses unreserved remorse. He seeks a reprimand. In the alternative, if a suspension is imposed, he submits it should be no more than one month. This duration he submits recognizes his extensive rehabilitation and the low risk of recurrence.

The evidentiary record relevant to penalty

40In addition to adopting the ASF, the Licensee testified and provided a letter to us. We have the transcript of the joint submission to the Ontario Court of Justice on sentencing and the documentary material tendered there, including the victim impact statement of his former spouse. Counsel for the Licensee asks us to refer to the statement within its proper evidentiary limits. Namely, it may describe harm flowing from the offence he was convicted of but should not be used to prove withdrawn allegations; specifically, the description of events on September 4, 2021. Counsel referred to s 722(1) of the Criminal Code.

41This evidence shows the Licensee’s commitment to satisfy all conditions of his discharge and probation including counselling and addressing anger concerns, heathy communication and relationships. He successfully completed the terms of his sentence in August 2024 and has independently continued with counselling.

42We heard and accepted that the Licensee’s remorse is sincere and he accepts full responsibility, understands the impacts of his conduct, and is committed to rehabilitation. He testified of his apology to his former spouse and recognizes that one day he will have to speak to his son about the wrongfulness of his actions. We accept that the Licensee has clear insight into his conduct.

43We were also provided with character and support letters, including from legal colleagues and police officers attesting to the Licensee’s ownership of his conduct, rehabilitation, and the low risk of recurrence.

44The Licensee admits professional misconduct for failure to report the September 2021 charge promptly. He testified that he mistakenly interpreted the Rules of Professional Conduct as limiting him to report matters connected to his practice, not his private life. His evidence is that once alerted by mentors of his obligations under By-Law 8, he promptly self-reported.

Delay

45The Licensee submits that the two-and-a-half year interval between his guilty plea in August 2022 and the notice of application in April 2025 should mitigate penalty. During this time period, he completed the terms of sentencing including rehabilitation but lived under the cloud of pending discipline. This delay affected the Licensee’s career advancement within his firm and prolonged anxiety. The Licensee submits that the principle of proportionality allows us to take his progress through rehabilitation into account when determining penalty.

46The Law Society argues that the time the Licensee characterizes as “delay” and relies upon to reduce penalty is the same period during which he made progress in rehabilitation. In its submission, this time is not mitigating in the way the Licensee suggests but is instead an important factor in assessing penalty. Further, the Law Society submits whether the Licensee suffered any delay in advancing his career within his firm is not a penalty consideration for us: Patterson at para 17.

Comparative jurisprudence and the proper range

47Tribunal jurisprudence involving intimate partner violence establishes that such conduct is inherently incompatible with professional responsibilities of trust and integrity. While few cases have arisen involving this misconduct, penalty orders in three cases have proceeded by joint submission where the Tribunal’s review is limited to whether the proposed penalty complies with the public interest test: Law Society of Ontario v Widz, 2022 ONLSTH 140 at para 33.

48Further, intimate partner violence “is rightly the subject of increasing public awareness, concern and action, both in the criminal and regulatory spheres.” Widz at para 35.

49Across six comparable decisions, the Tribunal has taken a serious view of intimate partner violence. In three cases, by joint submission, this misconduct warranted suspension rather than a reprimand: Kumarasamy, 2015 ONLSTH 52, Subramanian, 2023 ONLSTH 42, and Aujla, 2022 ONLSTH 77. In only one recent decision, by joint submission, was a reprimand agreed to: Al Zahid, 2021 ONLSTH 89.

50In Kumarasamy, the paralegal’s conduct involved three incidences of assault against his wife and a mischief charge. Proceeding by joint submission, the panel ordered a two-month suspension plus counselling. The Tribunal stated that any case of spousal violence, absent particular mitigating circumstances, should include a suspension. It is noteworthy to extract this portion of the reasons where the Tribunal stated:

6This was conduct unbecoming a paralegal. His criminal actions in his personal capacity tend to bring discredit on the paralegal profession. Not only did he break the law and violate another person’s bodily integrity, but he did so to his wife. Male violence against women is an issue of gender equality. Lawyers and paralegals are under a particular obligation to respect equality, a core value in the Canadian legal system, protected under ss. 15 and 28 of the Canadian Charter of Rights of Freedoms, Constitution Act, 1982, Part I, and under the Human Rights Code, RSO 1990, c. H.19. When he committed gender-based violence by assaulting his wife, the Paralegal harmed the reputation of the paralegal profession for respecting and upholding equality and the law.

10Most important in this case are general deterrence, rehabilitation and maintaining public confidence. The penalty must emphasize the profession’s lack of tolerance for the Paralegal’s conduct, in particular given that the violence involved a vulnerable family member. The two-month suspension does so, and the counselling on issues of gender equality, anger management and spousal relations will assist in preventing any recurrence of the domestic violence, and help prevent any manifestation of the underlying attitudes in his work as a paralegal.

11A variety of cases involving assaults have led to findings of conduct unbecoming, with penalties ranging from a reprimand to revocation. None are particularly close analogies to the facts of this case. The parties submit, and I agree, that this case is more serious than those involving reprimands, in particular because of the vulnerability of the person assaulted and the gendered aspect of the violence. At the same time, it is less severe than cases that have led to much longer suspensions. In my view, any case of spousal violence, absent particular mitigating circumstances, should include a suspension to emphasize the profession’s condemnation of such conduct.

(emphasis added)

51In Subramanian, the panel accepted a joint submission and ordered a two-month suspension after the lawyer pled guilty to one count of assault and one count of failing to comply with an undertaking arising from several incidents of intimate partner violence and breaches of no contact conditions.

52Since Kumarasamy, only in Al Zahid, where the lawyer engaged in criminal harassment of his former partner and not physical assault, did a panel accept a joint submission for a reprimand and mandatory counselling.

53In Aujla, the lawyer was charged with a criminal offence of threatening his wife and he also failed to report the charges to the Law Society. He was sentenced to a conditional discharge, followed by 18 months’ probation, including rehabilitative counselling programs. The panel ordered a three-month suspension on a joint submission.

54Prior to this matter, there have been only two other contested hearings on penalty involving intimate partner violence where the parties were not proceeding on a joint submission: Widz, above, and Ahmed, 2026 ONLSTH 27.

55In Widz, the panel ordered a one-month suspension. The lawyer assaulted his intimate partner on two occasions in 2020, pled guilty to one count of common assault, and received a conditional discharge and one year of probation. The lawyer sought a motion to convert the notice of application to an invitation to attend, or in the alternative, a reprimand. The Law Society sought a suspension. Then panel rejected a reprimand as outside the acceptable penalty range and ordered a one-month suspension. In rejecting a reprimand, the panel recognized that compelling rehabilitation could shorten, but not eliminate, suspension, stating,

46For many of the same reasons and having regard to the case law cited by the parties, we regard a reprimand as an inappropriate penalty, outside the proper range for the serious misconduct in this case. Indeed, but for the impressive rehabilitative and mitigating steps taken by Mr. Widz, the Law Society might well have proposed a different penalty. In that case, we might well have considered a longer suspension in this case. Again, the interests of general deterrence and public confidence in the professions must prevail.

56The reasons for decision in Ahmed were released the day after the close of argument in this matter. We therefore invited supplementary submissions from the parties. In Ahmed, the lawyer committed a series of violent acts over the course of one day against his former intimate partner inside her home. His violent acts included physical assault, forcible confinement as she tried to escape, and destroying her security camera, causing property damage. He pled guilty to common assault, mischief under $5,000, and forcible confinement. He was given a six-month conditional sentence which included three months of house arrest, followed by one year of probation. He sought no suspension of his licence, or alternatively, a suspension of one to two weeks. The panel ordered a suspension of three months.

57Reviewing the penalty orders of the same Tribunal jurisprudence we have summarized, the panel in Ahmed weighted the seriousness of the conduct and stated,

33These cases provide us with some general guidance about penalties in cases involving intimate partner violence; however, we recognize that each case has unique facts. Assessment of penalty is not as simple as considering the circumstances of assault or the number of violent acts. It is far more nuanced than that. By their nature, instances of intimate partner violence demonstrate contempt for, or at minimum a disregard of, the dignity of victims. They are harmful to the parties involved, to society at large and to the public’s perception of the legal professions. For this reason, we reject Mr. Ahmed’s submission that there should be no suspension of his licence to practise law. We adopt the panel’s statement in Kumarasamy that, “any case of spousal violence, absent particular mitigating circumstances, should include a suspension to emphasize the profession’s condemnation of such conduct”: Kumarasamy at para 11.

58In their supplementary submissions, the parties offered differing interpretations of the significance of Ahmed. The Law Society submits that Ahmed confirms a presumptive penalty of suspension in cases of intimate partner violence, emphasizing that such conduct harms victims, erodes public confidence in the professions and requires a response that reflects contemporary societal expectations and the profession’s denunciation of violence. The Licensee, in contrast, submits that Ahmed does not establish a rigid presumptive suspension and each case must be considered on its own unique facts. Further, the conduct in Ahmed was significantly more serious, occurred more recently and involved no meaningful rehabilitation, unlike the significant mitigating actions taken by the Licensee in this case which should operate to displace the need for a suspension.

59We follow the Ahmed panel’s lead in adopting the Kumarasamy panel’s statement as a foundational principle such that “any case of spousal violence, absent particular mitigating circumstances, should include a suspension to emphasize the profession’s condemnation of such conduct”: Kumarasamy at para 11, adopted by Ahmed, para 33.

60In our view, the parties’ supplementary submissions collectively establish that intimate partner violence will ordinarily attract a suspension to demonstrate the professions’ condemnation of such conduct, while the Licensee’s position properly highlights that the extent and nature of the mitigating circumstances remain relevant to determining the appropriate duration of that suspension.

61For these reasons a reprimand is not a proportionate response. A suspension is necessary. However, the duration of suspension is informed by the Licensee’s commitment to rehabilitation and mitigating steps he continues to take.

62We have considered mitigating factors that were articulated in Law Society of Upper Canada v Aguirre, 2007 ONLSHP 46, to be informative in this case.

63The Licensee has no prior discipline history. He entered into a joint submission in the criminal proceedings and an agreed statement of facts at the Tribunal obviating a contested hearing on the merits.

64We recognize that the Licensee’s remorse, counselling, and insight are not to be disregarded. On the contrary, his efforts demonstrate a continued commitment to rehabilitation. This and his lack of prior discipline and co-operation are significant, but do not outweigh the need for general deterrence and public confidence that the professions have and will continue to take intimate partner violence seriously: Widz, para 46; Kumarasamy, para 11; Ahmed, para 33.

65Mr. Angle has taken seriously the terms of his conditional discharge and continues with therapy. His character evidence affirms that he is supported by loving family and friends that continue to support him and express witnessing a transformation informed by their own professional insights. He has spent a tremendous amount of time in therapy and one day will have to explain his wrong and unacceptable behaviour to his son. He has apologized to his former spouse. He apologized to us and to the profession.

Failure to report

66On the facts agreed upon, the Licensee’s failure to report his criminal charge is a compounding factor in our penalty consideration as it was in Kumarasamy and Aujla. Failure to report criminal charges, especially intimate partner violence, is professional misconduct.

67We accept the Licensee’s evidence that his failure to report was not a deliberate attempt to mislead; however, it remains professional misconduct.

68In our view professional misconduct and conduct unbecoming a licensee in Kumarasamy is more similar to the present case than are the circumstances in Aujla and we consider a two-month suspension to be within the appropriate range of penalties for both Mr. Angle’s conduct unbecoming for criminal conviction for intimate partner violence of his former spouse and professional misconduct for his failure to report.

COSTS

69The parties also reached agreement on costs and we see no basis upon which their joint submission should not be accepted. The Licensee agrees to pay costs of $7,500 within 12 months.

ORDER

70We order:

The respondent’s licence shall be suspended for a period of two months beginning April 14, 2026.
The respondent shall comply fully with the terms of the Law Society’s Guidelines for Lawyers Who Are Suspended or Who Have Given an Undertaking Not to Practise while suspended pursuant to this order.
The respondent shall pay costs to the Law Society in the amount of $7,500 by March 31, 2027. Interest shall accrue on any overdue part of those costs at a rate of 4% per year.

Law Society of Ontario v. Angle, 2026 ONLSTH 66

Case Summary