Permanent Undertaking

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Case comment on CNO v Coyle, 2025 CanLII 146790 (ON CNO), Discipline Committee of the College of Nurses of Ontario decision imposing permanent undertaking equivalent to revocation on registered nurse who hand-altered the Medication Administration Record of an elderly patient to authorize substantially higher morphine doses, documented administration of doses that were not given, and misappropriated the controlled substance. Patient subsequently died of morphine toxicity from doses administered overnight by an incoming nurse who relied in good faith on the altered order. By Paul Cahill, LSO Certified Specialist in Civil Litigation.

CNO v Coyle: Patient Abuse, Falsified Documentation, and the Permanent Undertaking Framework

Discipline Committee of the College of Nurses of Ontario imposes permanent undertaking on registered nurse who altered morphine records before patient’s death.

February 23, 2026

Case comment on College of Physicians and Surgeons of Ontario v Nahvi, 2024 ONPSDT 31 (Ontario Physicians and Surgeons Discipline Tribunal), accepting joint submission for permanent resignation in surreptitious-drugging case. On the DDU standard, the resignation + permanent undertaking framework, and the parallel regulatory, criminal, and civil tracks. By Paul Cahill, LSO Certified Specialist in Civil Litigation.

CPSO v Nahvi: Drugging of a Patient/Employee, Cover-Up, and Permanent Resignation

OPSDT accepts joint submission for permanent resignation after physician surreptitiously drugged a patient/employee with Rohypnol and Lorazepam, then self-administered to evade detection.

December 23, 2024

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Permanent Undertaking

CNO v Coyle: Patient Abuse, Falsified Documentation, and the Permanent Undertaking Framework

CPSO v Nahvi: Drugging of a Patient/Employee, Cover-Up, and Permanent Resignation

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Concerned about medical negligence? Talk to Paul directly.

Concerned about medical negligence?
Talk to Paul directly.