On March 30, the Supreme Court of Canada released its decision in Green v. Law Society of Manitoba with the majority agreeing with the courts below that the Law Society of Manitoba (“Law Society”) can impose rules that couple a mandatory CPD program with a possible suspension for failing to meet the program’s requirements.

Justice Abella and Justice Côté authored a dissent, holding (as described in the headnote) that:  “A rule that leads to an automatic suspension for failing to attend 12 hours of continuing professional development is so far removed from ensuring the public’s confidence in lawyers that it is manifestly unjust, and therefore, unreasonable.”