
Trozzi v CPSO: The Doré Framework and the Limits of Physician Speech
The Divisional Court affirms the OPSDT’s revocation of Dr. Trozzi’s licence. The Doré framework, the non-cooperation duty, and the limits of physician speech.
Representing Victims of Medical Malpractice Across Ontario
Discipline decisions are the published reasons of regulatory tribunals that adjudicate professional misconduct and incompetence allegations against Ontario regulated health professionals. Posts in this category analyze decisions of the Ontario Physicians and Surgeons Discipline Tribunal (OPSDT) and, where relevant, decisions of the discipline bodies of other Ontario health colleges, including the College of Nurses of Ontario.
Discipline proceedings are regulatory rather than civil. They do not provide compensation to patients who have been harmed by negligent care. They focus instead on whether the registrant should continue in practice, whether their practice should be restricted, and whether public protection requires sanctions ranging from caution and remediation to suspension or revocation of the certificate of registration. The framework is set out in the Health Professions Procedural Code (Schedule 2 to the Regulated Health Professions Act, 1991) and in the profession-specific acts and regulations.
For patients considering a civil claim, discipline outcomes can be a useful source of information about a practitioner’s history and the regulator’s view of the standard of practice. For lawyers and researchers, discipline decisions are an important parallel jurisprudence to civil case law on standard of care and professional conduct.
Posts in this category analyze recent discipline outcomes, with attention to the underlying clinical or non-clinical conduct, the regulatory provisions engaged, the penalty imposed, and any judicial review or appeal that followed.

The Divisional Court affirms the OPSDT’s revocation of Dr. Trozzi’s licence. The Doré framework, the non-cooperation duty, and the limits of physician speech.

An Ontario tribunal ruled physicians have no Charter privacy interest in their patients’ records. Subsequent proceedings produced a 12-month suspension.

A family physician suspended for 12 months after charging patients for Accessible Parking Permit applications and certifying eligibility his charts did not support.

A diagnostic radiologist conducted hundreds of unauthorized searches of patient records over six years. The OPSDT imposed a four-month suspension, reprimand, and costs.

The OPSDT released two penalty decisions in January 2024 in COVID-19 misinformation cases. One physician received a six-month suspension. The other was found ungovernable and had his licence revoked.

The OPSDT imposed a two-month suspension and a reprimand on a physician for unprofessional COVID-19 commentary, calibrated to the lower end of the discipline spectrum.

A physician was suspended for seven months after a CPSO audit found he had failed to comply with restrictions imposed in 2016 after a finding of sexual abuse.

A Northern Ontario ER physician was found guilty of misconduct and separately found incompetent for sustained COVID-19 misinformation across a two-year period.

A general surgeon was suspended for 18 months after sexual misconduct against an ultrasound technician at his hospital, with a prior discipline history weighing heavily.

A family physician was suspended for five months after using OHIP fraudulently while resident in New York. Discipline for non-clinical conduct under the HPPC.

A Northern Ontario physician’s certificate of registration was revoked for online misinformation, sharing of confidential investigative information, and clinical deficiencies.

A Windsor nephrologist’s certificate of registration was revoked after findings of professional misconduct and incompetence. He was ordered to pay $250,510 in costs.
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