
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
The Ontario Physicians and Surgeons Discipline Tribunal (OPSDT) is the independent tribunal that adjudicates allegations of professional misconduct and incompetence against Ontario physicians. It replaced the CPSO Discipline Committee on September 1, 2021 and now operates as part of the Health Professions Discipline Tribunals group, which shares a common set of rules and processes across several Ontario health colleges.
Allegations are referred to the OPSDT by the College of Physicians and Surgeons of Ontario after investigation by the Inquiries, Complaints and Reports Committee. The Tribunal’s findings and penalties, which can include reprimand, conditions on a certificate of registration, suspension, or revocation, are public and searchable on the OPSDT website. Decisions are subject to judicial review and, in some cases, statutory appeal.
OPSDT proceedings are regulatory rather than civil. They do not provide compensation to patients. However, the underlying conduct in many discipline cases overlaps with the kinds of clinical failures that also support medical malpractice claims, and the Tribunal’s reasons can be a useful source of information for patients considering a civil action.
Posts tagged OPSDT analyze recent discipline decisions involving Ontario physicians, with attention to the clinical context, the penalty imposed, and the implications for patient safety.

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.

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.

A family physician refused to cooperate with multiple CPSO investigations during the pandemic. The OPSDT held that the refusal was itself professional misconduct.
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