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Reliance on Antisemitic Trope Constitutes Misconduct for Ontario Lawyer

  • Writer: Rochelle Direnfeld and Mark Sandler
    Rochelle Direnfeld and Mark Sandler
  • 6 days ago
  • 5 min read
Image Credit: Canadian Lawyer Magazine
Image Credit: Canadian Lawyer Magazine

On February 6, 2026, a hearing panel of the Law Society of Ontario found Christos Vitsentzatos of London, to have engaged in multiple particulars of professional misconduct and conduct unbecoming a licensee, including participation in fraudulent or dishonest activities. A Law Society hearing panel revoked his licence. 


One of the particulars of misconduct he was found guilty of, was, contrary to Rule 6.3.1-1 of the Rules of Professional Conduct, failing to honourably carry on the practice of law and to discharge all responsibilities to clients and the public by making discriminatory comments in text messages to his client, AX. 


AX sought legal advice from Vitsentzatos who recommended that an acquaintance, Elias, could assist. AX was taken aback when she received a substantial invoice from Elias. In response, AX consulted Vitsentzatos for guidance on how to handle the situation with Elias.

AX and Vitsentzatos exchanged text messages about negotiating with Elias. During this exchange, and in anticipation of a forthcoming meeting between AX and Elias, Vitsentzatos sent AX a message stating: “But ok guess that you are pulling a Hebrew on him Wednesday.”


Vitsentzatos claimed that his comment was meant to encourage strength rather than being an antisemitic slur. He also claimed not to understand what “pull a Hebrew” meant when interviewed by the Law Society investigator. His evidence appeared to be an attempt to provide a positive meaning to an apparent antisemitic statement.


The hearing panel rejected his claim. The panel found that this was, and was intended to be, a reference to the antisemitic trope that Jewish people are stingy or cheap.

Similarly, on another occasion, AX texted Vitsentzatos about one of her pets. She texted “Any chance that you want to adopt a cute cat named Emma? I can’t care for all these guys any more … too much for me”. After several messages, Mr. Vitsentzatos responded “if you toss in some garlic and basil, I think that I know some Asians that may want her for dinner”.

Before penalty was determined, the hearing panel invited ALCCA to file a community impact statement. Our statement included the following:


The connection made between Jews and greed has been a feature of antisemitism through its long history. The American Jewish Committee accurately states that “the theme of greed in antisemitic rhetoric is so widespread that it has led to a long list of Jewish stereotypes, including being excessively materialistic and money-oriented, exploiting others for personal gain, being overly wealthy, and controlling the world’s finances.”


The stereotypical trope appears to have originated in the Middle Ages when the Church prohibited Christians from moneylending for interest. This meant that moneylending represented one of the few professions that Jews were permitted to engage in. This activity led to accusations of usury, and ultimately to the antisemitic trope already described. The trope has figured prominently in conspiracy theories that Jews control the world economically or are conniving to do so. It is of course deeply troubling that these conspiracy theories have figured prominently in Jewish history’s darkest moments, used for example, in Nazi propaganda including the Protocols of the Elders of Zion, a document originating in early 20th century Russia that falsely promoted the existence of an international Jewish conspiracy to dominate the world. The Protocols of the Elders of Zion is still disseminated to demonize Jews around the world, despite its exposure as a fraudulent, forged document.


Of course, we do not suggest that, from the Jewish community’s perspective, this respondent bears the weight of responsibility for the impact that stereotypical tropes have had and continue to have on the Jewish community. But it is significant that antisemitism, in all its manifestations, is now pervasive in Canadian society. Antisemitic hate crimes and reported non-criminal hate incidents have dramatically increased in recent years. Statistics Canada recently reported that in 2024, over 70% of religion-based hate crimes in Canada target Jews, a staggeringly disproportionate percentage as Jews represent about one percent of the Canadian population (See the Canadian Handbook on the IRHA Working Definition of Antisemitism, page 12 and footnote 23, Government of Canada)


What we do suggest is that the use of antisemitic tropes in mainstream Canadian society targets a community already fearful and reeling from the antisemitism they are experiencing first-hand or second-hand in K-12 schools, universities and colleges, in our professions, and at times, within governments.


……


We do not purport to speak for members of the Asian community, but we know based on our work in combatting both antisemitism and other forms of hatred, that it is a community that has also experienced profound racism historically and continues to experience it today. For example, members of the Asian community have been held collectively responsible for the Covid 19 virus, in the same way that Canadian Jews have been held collectively responsible for the actions of a foreign government, Israel, for its conduct or perceived actions. Such collective responsibility amounts to antisemitism and racism.


The hearing panel found that the community impact statement:


...explained the significant prevalence and adverse impact of antisemitism on the Jewish community and of the significance of antisemitic tropes. This statement thoughtfully takes care not to say that Mr. Vitsentzatos bears the weight of this racism. However, he has contributed to it. While not supported by an impact statement, anti-Asian statements have a similar effect. Further, we note that statements such as the ones Mr. Vitsentzatos made can normalize the making of discriminatory statements to recipients such as AX. It can compromise the professional credibility of a lawyer who makes such statements and the reputation of lawyers generally.


While the totality of the lawyer’s charges explains the revocation of his licence, it was important that his antisemitic conduct be identified, form part of the disciplinary case against him, and ultimately be found to have constituted professional misconduct and conduct unbecoming a licensee.


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About the Authors

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.

Rochelle Direnfeld is ALCCA’s Senior Criminal Counsel. She was called to the Ontario bar in 1990 and has served in the Ontario Public Service for over 32 years as an assistant crown attorney, deputy crown attorney, crown counsel, and finally as Deputy Director for Toronto Crown Attorneys in the Criminal Law Division of the Ministry of the Attorney General. Rochelle retired from public service at the end of 2023. During her career, she prosecuted a wide variety of Criminal Code cases in the Ontario Court of Justice, Superior Court of Justice, and the Ontario Court of Appeal.


Rochelle is also the Chair of the Canadian Criminal Law Working Group, a national initiative bringing together leading criminal lawyers to strengthen the legal response to antisemitic hate crimes and support victims across Canada.


She has also been selected to join the Toronto Police Service Board’s Jewish Community Advisory Table, an initiative aimed at strengthening dialogue and collaboration between the Jewish community and the Toronto Police Service on issues of community safety and policing.



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