The Discipline Committee of the College of Nurses of Ontario has ordered the immediate revocation of the registration certificate of nurse Melissa Dore after finding she issued over 300 medical exemption letters for the COVID-19 vaccine to individuals who were not her patients and whom she did not assess1. The panel found Ms. Dore’s conduct to be disgraceful, dishonourable, and unprofessional. The decision, which also requires Ms. Dore to appear for a formal oral reprimand, was delivered following a penalty hearing held by videoconference on March 24, 2025. This penalty phase followed an earlier hearing on October 28, 2024, where the panel first made its findings of professional misconduct against Ms. Dore. The panel determined that Ms. Dore had failed to demonstrate any insight into her actions, describing her as “ungovernable” due to the repetitive nature of her conduct, and concluded that revocation was the necessary penalty to protect the public and maintain confidence in the nursing profession.
The case against Ms. Dore, who held registration number 0000257, centered on her practice of providing vaccine exemption letters. College Counsel, Jean-Claude Killey, submitted to the panel that Ms. Dore’s conduct was “fundamentally dishonest.” The evidence presented showed that individuals would contact Ms. Dore to request an exemption. In response, she would email them a presentation she had developed. After the individual emailed back to confirm they had watched the presentation, Ms. Dore would send them a signed exemption letter. The College noted that Ms. Dore often included exemption letters for other individuals in the same email and did not track who had actually watched her presentation. She simply issued the letters to those who requested them. Crucially, the College established that these individuals were not her patients, she conducted no assessments, and she kept no records of the interactions. When the College requested the medical records for the individuals who received letters, Ms. Dore “recreated” records in response.
During the penalty hearing, College Counsel argued that Ms. Dore’s practice demonstrated a “total disregard for patient health and safety, as well as public safety.” The College submitted that by placing her nursing designation on the exemption letters, she legitimized them, which could have been misunderstood by employers or other organizations requesting proof of vaccination. There was no evidence that the individuals receiving the exemptions had serious health issues or worked in high-risk settings like long-term care facilities. The College highlighted one specific instance where Ms. Dore provided an exemption letter to an individual after a physician had already refused to do so. Ms. Dore admitted she did not conduct any further investigation into the person’s circumstances, nor did she contact the physician to understand the reason for the refusal. She also did not consult with other practitioners for advice. College Counsel argued that Ms. Dore was “essentially hiring out her professional designation for political purposes,” as she did not agree with vaccine mandates and believed unvaccinated individuals should not be prevented from entering public spaces.
To support its request for revocation, the College submitted several prior discipline cases. It cited CNO v. Freyer (2018), where a member’s registration was revoked for various acts of misconduct, including medication errors and using profanities with patients, after the member showed no insight or remorse. It also presented CNO v. Sircar (2014), where revocation was ordered for a member who acted deceitfully by continuing to practice while suspended. The College distinguished the case of CNO v. Pomerleau (2024), where a nurse received only a three-month suspension for faking her own vaccine with saline. Counsel noted that Ms. Pomerleau’s case involved a single incident related to her own status, and she had expressed remorse and gained insight, which stood in stark contrast to Ms. Dore’s case involving over 300 individuals and a complete lack of insight. The College also referred to cases from the College of Physicians and Surgeons of Ontario (CPSO), including CPSO v. Phillips (2023) and CPSO v. Trozzi (2024), where physicians’ certificates were revoked for making misleading or inflammatory public statements about COVID-19.
Ms. Dore, who did not have legal representation at the hearing, made submissions on her own behalf. She stated that the College made “multiple inaccurate representations” and disputed the characterization that she did not care who attended her presentation. She defended her actions by stating that the COVID-19 vaccines “did not stop the transmission” and described them as “novel experimental” vaccines. Ms. Dore heavily relied on the Nuremberg Code in her defense, arguing that “the voluntary consent of the human subject is absolutely essential” and that individuals must be able to exercise free choice without any “constraint or coercion.” She submitted that individuals have the right to choose and decline care. Ms. Dore disputed that she was deceptive and argued that she provided the written medical exemptions because she “felt they were necessary for an individual’s mental health.” She characterized her actions as “public education,” submitting that the College accused her of professional misconduct merely for taking drug monograms and putting the information into plain language for the public.
Ms. Dore also challenged the cases cited by the College, arguing they were not comparable to her situation. She submitted that the members in Freyer and Sircar had “numerous infractions” and that the member in Pomerleau engaged in “fraud.” She also argued that the physicians in the CPSO cases had received “multiple warnings” before facing revocation, whereas she had received none. Instead, Ms. Dore submitted the case of CNO v. Soos (2024) for the panel’s consideration. In that case, a member who falsified vaccine documents for colleagues and family members received only a four-month suspension. Ms. Dore claimed the College suspended her license for “no reason” after reviewing her slide deck and that this material was not properly considered. She concluded her submissions by stating that she “will not waiver from the Nuremburg Code or her ethics.” The panel noted that Ms. Dore did not make any other specific submissions on what she believed an appropriate penalty order should be.
In its reply, College Counsel submitted that Ms. Dore’s submissions “further demonstrated her lack of insight into her misconduct,” arguing that she incorrectly believed she was being disciplined for her education sessions rather than for the serious findings of professional misconduct. The Discipline Panel, chaired by Grace Fox, NP, agreed with the College’s position. In its reasons for the penalty, the panel stated that its purpose is to protect the public and enhance public confidence in the College’s ability to regulate the profession. The panel wrote it was “disappointed to see that the Member had not gained the necessary insight into her actions” even after her certificate had been suspended on an interim basis for many months. The panel found that revocation was the appropriate order to protect the public, as Ms. Dore had demonstrated no remorse or insight. The decision stated that the penalty satisfied the principles of specific deterrence, by preventing Ms. Dore from engaging in similar conduct in the future, and general deterrence, by signaling the seriousness of the misconduct to other members of the profession. The panel found that the goals of rehabilitation and remediation were not applicable, given the revocation. A publication ban remains in effect that prohibits the disclosure of the names or any identifying information of the patients who received the exemption letters from Ms. Dore.
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