A Further Lesson on Upholding Professional Boundaries
Further to our blog of October 6, 2025, Professional Boundaries Matter: Lessons from a Recent Disciplinary Decision, a recent Ontario case provides another reminder of how easily professional boundaries can be blurred, and how serious the consequences may be.
Background
In August 2025, the Ontario Physicians and Surgeons Discipline Tribunal (OPSDT) rendered a decision in the case of Ottawa-area doctor. The doctor was found to have engaged in sexual abuse of a patient and to have demonstrated serious boundary violations with two other individuals under her care. The case was in the news (here) and the tribunal decision is available online (here).
As reported in the OPSDT decision, starting in 2002, the doctor began to develop a “wellness practice” out of her private clinic with a focus on therapies such as vein therapy, lipotherapy, platelet-rich plasma and esthetics. By 2018, she had stopped practicing family medicine altogether and continued to build an “executive practice.”
It was through this “executive practice” that the doctor began to engage in misconduct including a sexual relationship with a patient while he was under her care. This included repeated physical encounters and a proposed business venture during the course of the therapeutic relationship. The panel found that the doctor had engaged in inappropriate and unprofessional communications with two other patients, including emotionally charged and romantically suggestive messages.
The misconduct further extended to the administration of unconventional treatments, including “procaine” injections, at informal gatherings hosted in her clinic space—events that also involved alcohol and a blurred line between social and clinical contexts.
The panel concluded that the doctor failed to “...see her patients as patients..” and described her conduct as indicative of “a physician without boundaries.”
The tribunal’s decision underscores a foundational principle: a consensual act does not legitimize crossing a boundary that the profession has deemed off‑limits. In Ontario, any sexual contact between physician and patient is considered sexual abuse, regardless of perceived consent.
That said, boundary violations are not limited to overt sexual misconduct. The tribunal also emphasized the doctor’s financial, social, and business entanglements with patients — situations where the power imbalance becomes dangerously blurred.
A few key points worth highlighting:
Avoid dual relationships: club or team memberships, business ventures, and social gathering are all risky relationships that could easily lead to a boundary violation. If a doctor is considering any secondary relationship with a former patient, they should check regulatory policy about a cooling-off period and/or seek legal advice.
Be aware of “boundary crossings” vs “violations.” Accepting a small token gift may be a crossing, but repeated crossings or ignoring discomfort signals can lead to violations (see here).
Be extra vigilant in non‑traditional practice settings. This particular case involved a holistic/wellness practice setting, social gatherings in clinic space, and injections outside standard care. While a modern or non-traditional practice does not of course necessarily lead to boundary violations, it most likely does require special attention to what the practice policies and boundaries should be in those novel settings
When in doubt, refer or step back. If a doctor is uncertain as to whether they can keep a strictly professional relationship, the ethical choice is to refer the patient elsewhere.
Conclusion
This case serves as a reminder of the importance of maintaining clearly defined physician-patient relationships, without any other associated roles or ventures. Physicians must remain committed to maintaining clear, appropriate boundaries so that their care remains clinically sound, ethical, and would be defensible if called into question.
Please contact us if you require guidance tailored to your practice.
