Professional Misconduct, Hate Speech, and the Ontario College of Teachers: The Caranfa Discipline Decision
- Mark Sandler
- Aug 17
- 8 min read
Updated: Aug 18
In July 2025, a discipline panel of the Ontario College of Teachers found that a College member, Fernanda Caranfa, was guilty of professional misconduct by posting, replying, tweeting or retweeting antisemitic and anti-2SLGBTQ+ content on X (formerly Twitter) as well as in her communications with the College.
Although the case provides an important precedent for removing teachers who publicly espouse hate, despite claims asserting freedom of speech, it does not relieve us of our obligation to address systemic failure in addressing antisemitism in Ontario schools. What follows is a summary of the discipline panel’s findings and reasons, and commentary that looks more broadly at the issues raised.
The Allegations
It was alleged that Caranfa (1) engaged in disgraceful, dishonourable or unprofessional behaviour, (2) engaged in conduct unbecoming a member, and (3) made remarks or behaved in ways that exposed a person or class of persons to hatred on the basis of a prohibited ground of discrimination under the Ontario Human Rights Code.
Between July 2022 and December 2022, the member’s X account included the following statements (or words to this effect):
(a) “God destroyed Sodom and Gomorrah for the very things we are celebrating and teaching in schools;”
(b) “That is because the Freemasons were started by Jews. Also if you check records most communists in the 1917 Russian insurrection were 90% Jews, many of whom changed their names – why? To hide this fact? Many commies in the USA were also Jews … it is worth checking these records …;”
(c) “I highly suggest that you read E. Michael Jones. Holocaust denial was a term invented in 1993. Then you have the Zundel trials in Canada. Then you have the Poles admitting the crematoriums were built in 1947. Germans have been abused. Truth is usually unpleasant;”
(d) “Idiot wake up. The Jews are nobody’s friend. Their only interest is themselves and Satan – thus the need for abortion – to satiate the demon moloch;” and
(e) “Truth is hard. Jews are the enemies of Christ. They are baby killers. Moloch worshippers. Name calling completely proves my point of your ignorance …”
In response to the College, the member made various statements that demonstrated that she did not intend to cooperate with the College’s investigation, regarded the claims against her as unjust, and that her statements constituted protected speech or opinions. She also amplified certain messages targeting Jews and members of the 2SLGBTQ+ communities.
The College’s case against Caranfa included the evidence accumulated by the complainant, Michael Teper, President of the Canadian Antisemitism Education Foundation (CAEF), and the evidence of Bernie Farber, who was qualified by the panel as an expert in antisemitism, extremism and hate-motivated crimes. (Michael and CAEF have been active in bringing antisemitism in teaching to the attention of the authorities.)
The panel found that Mr. Farber’s opinions were necessary to assist it in understanding the context and history of antisemitism as well as some of the more oblique terms and concepts Caranfa used that were not within the panel’s knowledge. Mr. Farber was also able to explain the negative cumulative impact of Caranfa’s statements on the affected communities.
Mr. Farber explained several key concepts at play here, such as Holocaust denial and minimization, antisemitic conspiracy theories, and testified about the history of tropes and disinformation used to discriminate against Jewish people. He “mapped out” the process of minimization and dehumanization and how these contribute to the harm or hatred towards protected groups, particularly the Jewish community.
The Panel’s Findings
First, the panel stated that College members are expected to foster inclusivity and respect for diverse cultures that form part of school communities. This member did not do so. Instead, her intentional use of social media to publicly espouse discriminatory views against protected groups constituted disgraceful, dishonourable and unprofessional conduct.
Second, her conduct was unbecoming a member of the teaching profession. Although she was not teaching at the time of her conduct, and her actions were not associated with classroom activities, members of the profession are required to refrain from unbecoming conduct, even when they are off duty. Her misconduct had a wide-reaching harmful impact, including but not limited to the profession’s reputation. The trust that parents, students and the public place in teachers is undermined when members publicly express discriminatory views.
Finally, the member’s remarks exposed Jews and members of the 2SLGBTQ+ community to hatred based on prohibited grounds under the Ontario Human Rights Code, on the basis of creed (religion), sexual orientation, gender identity and gender expression.
Freedom of Speech
The panel’s discussion of the interplay between freedom of speech and the profession’s obligations is also an important one:
[84] … The panel recognizes the fundamental importance of freedom of expression in our society. However, not all forms of expression are afforded the same consideration. The panel notes that the Supreme Court of Canada has stated that: “Hate speech is at some distance from the spirit of section 2(b) because it does little to promote, and can in fact impede, the values underlying freedom of expression” (see Saskatchewan (Human Rights Commission) at paragraph 114).
[85] The panel further notes that the right to freedom of expression is not absolute and that there are justifiable limits to free speech, especially as a regulated professional. This was noted in the Peterson decision where the Divisional Court stated that “When individuals join a regulated profession, they do not lose their Charter right to freedom of expression. At the same time, however, they take on obligations and must abide by the rules of their regulatory body that may limit their freedom of expression” (see Peterson at paragraph 1).
[86] The Member’s statements, which expose Jewish people and members of the 2SLGBTQ+ community to hate, do little to promote the values underlying freedom of expression. Such speech should be given low value in the proportionality analysis. On the other hand, the effective regulation of teachers in accordance with the standards for the profession and for the protection of the public is very important. The Member’s public statements espouse harmful and discriminatory views and greatly undermine the trust placed in the teaching profession by the public. The Panel would not be fulfilling the objectives noted above if it did not make a finding of professional misconduct against the Member. While the Member is entitled to hold heinous or unpalatable views, she does not have the right to express them publicly as a member of the College. A finding of professional misconduct is an appropriate response to ensure the protection of the public and to demonstrate to the public that the College will effectively regulate its members.
Penalty
The panel concluded that the only appropriate penalty in the circumstances was a reprimand and more importantly, revocation of Caranfa’s certificate of qualification and registration. It cited four other decisions resulting in revocation that involved members publicly sharing derogatory, discriminatory and offensive statements. The panel determined that public confidence in the teaching profession would be jeopardized if the panel ordered anything short of revocation.
My Commentary
The panel’s decision and reasons are excellent. The reasons reinforce the relevance and importance of expert testimony to assist tribunals and courts in understanding, among other things, the manifestations of antisemitism and other forms of hatred, including hatred based on sexual orientation, gender identity and expression. They also reinforce how freedom of speech does not immunize members of the profession from accountability for hate speech. Nor is the public expression of hatred by members of the profession outside the classroom immunized from accountability.
However, this decision does not mitigate nor answer the systemic issues that the Ontario College of Teachers, as the profession’s regulator, has not addressed.
The recent report by Professor Robert Brym on Ontario’s K-12 environment documented not only pervasive antisemitism but found that “nearly one in six antisemitic incidents were initiated or approved by a teacher or involved a school-sanctioned activity.”
This troubling fact prompted me to urge our readers to call upon the Ontario College of Teachers to publicly articulate what action it intends to take to systemically address teacher-initiated antisemitic incidents at K–12 schools.
JEFA’s newly released report, End the Crisis in Education: A Plan for Equal Rights and Real Learning cited these figures and added that, “however, there are only 14 disciplinary decisions from the [Ontario College of Teachers] regarding antisemitism in over 20 years - the OCT is simply not doing its job. Self-regulation cannot work if teachers aren’t interested in regulating themselves.”
JEFA's report submits that the teaching profession has forfeited any right to self-regulation, and that the Ministry of Education should assume responsibility for discipline and professional regulation. I certainly understand what prompted that submission. That being said, as JEFA’s report also states, the systemic issues at play are not confined to the Ontario College of Teachers or to the disciplining and regulation of teachers. In my view, the Ministry of Education, despite its encouraging, stated intention is to address antisemitism in schools, has not yet proven that it will do so effectively and in a timely manner.
Accordingly, the onus is now squarely placed on many institutions – including the Ontario College of Teachers, faculties of education, and the Ministry of Education to publicly articulate what they intend to do, on a priority basis, to address the issues identified in the Brym report. And then do what is needed or be held accountable if they don't.
Returning to the Ontario College of Teachers, the Caranfa decision addresses traditional forms of antisemitism and blood libels: for example, Jews as Christ-killers.
However, some of the most virulent and prevalent antisemitism we are dealing with in schools relates to the misuse of anti-Zionism to marginalize Jewish students based on their support or presumed support for the existence and legitimacy of the State of Israel. This isn’t about criticism of Israel, its conduct or policies. This is about Jewish students, teachers and staff being demonized or labelled as racists for supporting Israel’s existence as a Jewish state, often an integral part of their core identity. This is about Jews in the educational system being held collectively responsible for the actions of a foreign state, one recognized illustration of contemporary antisemitism.
The Ontario College of Teachers must demonstrate an understanding, drawing on mainstream expertise in antisemitism, of this form of antisemitism. And take concrete and timely action.
In summary, the Caranfa decision represents a helpful precedent for the principle that public expressions of hatred are incompatible with the responsibilities of educators. It underscores that teachers carry professional obligations beyond the classroom and that discriminatory speech cannot be excused as mere personal opinion or free expression.
However, the Jewish community and its allies must call upon the College to demonstrate how it intends to address the full range of antisemitism, too frequently teacher-led, that is documented in the Brym report.
So, I renew my request for our readers to call upon the College to publicly articulate what action it intends to take to systemically address teacher-initiated antisemitic incidents at K–12 schools.
ALCCA will continue to follow developments closely. We invite our readers to stay tuned for upcoming programming, including a planned webinar, and analysis focused on systemic antisemitism in our educational institutions, and the urgent reforms needed to safeguard students and ensure equal rights in our schools.
About the Author
Mark Sandler, LL.B., LL.D. (honoris causa), ALCCA’s Chair, is widely recognized as one of Canada’s leading criminal lawyers and pro bono advocates. He has been involved in combatting antisemitism for over 40 years. He has lectured extensively on legal remedies to combat hate and has promoted respectful Muslim-Jewish, Sikh-Jewish and Black-Jewish dialogues. He has appeared before Parliamentary committees and in the Supreme Court of Canada on multiple occasions on issues relating to antisemitism and hate activities. He is a former member of the Ontario Human Rights Tribunal, a three-time elected Bencher of the Law Society of Ontario, and recipient of the criminal profession’s highest honour, the G. Arthur Martin Medal, for his contributions to the administration of criminal justice.