The Discipline Committee of the College of Nurses of Ontario, or CNO, has ordered the immediate revocation of the certificate of registration for nurse Laura Ruth Orsatti1. The decision, released following a hearing that concluded on March 3, 2025, found Ms. Orsatti committed multiple acts of professional misconduct, including failing to maintain professional boundaries with a patient, accepting nearly $64,000 from him, and later attempting to influence him to provide false evidence to College investigators. A publication ban was ordered to protect the identity of the patient, who is referred to as Patient 1 in the proceedings.
The hearing, which took place over several dates beginning on October 18, 2024, heard allegations that Ms. Orsatti engaged in an inappropriate personal and romantic relationship with Patient 1 between August 2020 and September 2021. Ms. Orsatti was employed as a Registered Nurse at Closing the Gap Healthcare Group – Rehab Express in Toronto at the time. The relationship began while she was involved in his care and continued for nearly a year after the therapeutic nurse-client relationship had formally ended. Ms. Orsatti, who was self-represented during the hearing, initially denied the allegations. Because her plea was not entirely clear, the College proceeded as if all allegations were denied, placing the onus on the CNO to prove its case.
The Notice of Hearing detailed several allegations. The first was that Ms. Orsatti contravened the standards of practice by failing to maintain boundaries. This included carrying on a personal relationship involving non-therapeutic communication and discussions of co-habiting; requesting and accepting gifts of money or loans on multiple occasions totaling approximately $67,000; requesting and accepting Patient 1’s assistance as a financial guarantor for a rental accommodation; and accepting multiple gifts of alcohol, food, and restaurant meals. The second primary allegation was that Ms. Orsatti failed to co-operate with the College’s investigation in or about August 2021 by attempting to influence Patient 1 to give false evidence. The third allegation was that this conduct, taken as a whole, would be reasonably regarded by members of the nursing profession as disgraceful, dishonourable, or unprofessional.
The College presented its case through 17 exhibits and the testimony of two witnesses. Ms. Orsatti did not present any evidence. The College’s first witness, CNO investigator Remy Pearson, introduced documents that formed the core of the evidence. These included email threads and WhatsApp messages between Ms. Orsatti and Patient 1, which had been provided to the College by Ms. Orsatti’s prior legal counsel. Health records from the Facility were also entered, which established that Ms. Orsatti was involved in Patient 1’s care between May and November 2020. Other evidence included emails from a real estate agent, provided by the College, showing Patient 1 negotiating a rental unit on Ms. Orsatti’s behalf in June 2021. Critically, the evidence also included Ms. Orsatti’s own written responses to the College’s Inquiries, Complaints and Reports Committee, or ICRC.
In final submissions, College Counsel argued that the facts were not in dispute and were admitted by the Member in her own submissions to the ICRC. Counsel pointed to a letter dated September 16, 2022, in which Ms. Orsatti admitted to accepting multiple sums of money from Patient 1 between October 2020 and June 2021, totaling $63,964.50. College Counsel described the text message exchanges as having a “unique dynamic,” suggesting the relationship was “dysfunctional and profoundly exploitative on both sides.” The evidence showed that when Ms. Orsatti requested financial help, Patient 1 would attempt to extract personal benefits, such as weekly visits. Counsel submitted that while Ms. Orsatti resisted a direct quid pro quo, she did not refrain from using leverage to get the money.
The College’s second witness, Advanced Practice Consultant Emily Markelovassy, testified about the standards of practice in place at the time. She referenced the Professional Standards, the Code of Conduct, and the Therapeutic Nurse-Client Relationship Standard. These standards require nurses to maintain boundaries, prohibit the acceptance of gifts, and forbid engaging in financial transactions with patients unrelated to their care. In her own submissions, Ms. Orsatti apologized for accepting money and gifts, stating she realized her actions “made it worse for all involved” and that in trying to keep her job, she “lost everything.” She denied, however, that her conduct was disgraceful, dishonourable, or unprofessional.
The Discipline Panel found that the College had proven the allegations on a balance of probabilities. It accepted the evidence of the College’s witnesses as credible. The Panel found Ms. Orsatti breached the Professional Standards, the TNCR Standard, and the Code of Conduct. The Panel noted that Ms. Orsatti’s own ICRC submissions admitted to the inappropriate relationship and the acceptance of $63,964.50. The Panel highlighted evidence that Ms. Orsatti was aware of the boundary issues early on; she had even submitted to the ICRC that she thought Patient 1’s request to be transferred to her work location was inappropriate and had asked her manager to deny it. Despite this, the Panel found she “established and maintained a personal relationship with Patient 1 over the next year.”
Regarding the allegation of non-cooperation, the Panel was satisfied the evidence supported the finding. It pointed to an August 18, 2021 email from Ms. Orsatti to the College investigator claiming Patient 1 was making “fictitious accounts.” The Panel noted the College’s evidence showed the complaint was not fictitious. Furthermore, text messages from August 2021 showed Ms. Orsatti repeatedly pressuring Patient 1 to withdraw the complaint, with messages such as “say it’s not true,” “please remove it,” “you need to withdraw the complaint to CNO,” and “I will sue.” The Panel also found that Ms. Orsatti admitted to this pressure in her ICRC submission.
The Panel also agreed that the conduct was disgraceful, dishonourable, and unprofessional. It was deemed unprofessional for its “serious and persistent disregard” for professional obligations. It was found to be dishonourable as it “demonstrated an element of moral failing,” given that the Member admitted she knew she was breaching ethical obligations but continued. Finally, the Panel found the conduct disgraceful. It stated, “Despite knowing that she was crossing a boundary with Patient 1 for almost a year, she deliberately and repeatedly asked Patient 1 for money, exploiting his finances, to cover her own needs.” This, combined with her “aggressive” attempts to influence the investigation, cast “serious doubt on her moral fitness.”
During the penalty phase, College Counsel sought revocation, arguing that aggravating factors far outweighed mitigating ones. Aggravating factors included the significant sum of money, the lack of any restitution, the protracted and deliberate nature of the misconduct, and the Member’s lack of repentance. Mitigating factors included that Patient 1 was also “persistent and aggressive” and exploited Ms. Orsatti’s financial vulnerability, and that she had no prior disciplinary history. The College contrasted her case with others where nurses received suspensions, noting those members typically showed remorse, cooperated, and repaid funds, none of which were present here.
Ms. Orsatti, in her penalty submission, read a 13-page statement. She asked the Panel to reinstate her certificate of registration, drop all allegations, and compensate her for time lost. She apologized to Patient 1’s family for the humiliation they felt because of Patient 1’s conduct. College Counsel, in reply, argued that any expressions of remorse were “undone” by her other statements. Counsel quoted her submission: “When should another person, employer, have a say in what occurs in one’s private life with two consenting adults outside of work? Isn’t this an infringement of another’s personal liberties?” This demonstrated, the College argued, a complete failure to appreciate her professional obligations.
The Panel accepted the College’s submission and ordered an oral reprimand and the immediate revocation of Ms. Orsatti’s certificate of registration. In its reasons, the Panel stated Ms. Orsatti “has not taken accountability or shown insight into her conduct” and “has also shown contempt for the College proceedings and standards.” The Panel cited an email from Ms. Orsatti referring to the College’s “dumb rules that really are just arbitrary” and her suggestion that if she worked at Taco Bell “none of this would have happened.” The Panel concluded, “The Member fails to understand the professional obligations and expectations of a regulated health professional and the privilege of public trust. The Member has shown in her words and actions that she is ungovernable.”
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