The Law Society of Manitoba announced the disbarment of an 86-year-old lawyer following several complaints and transgressions, including taking on new clients despite her pledge to retire.
In January, Caroline Cramer was found guilty of professional misconduct by a discipline committee panel of the Law Society of Manitoba. She was ordered to be disbarred, and her name was struck from the rolls of barristers and solicitors.
According to the law’s society’s decision, the transgressions stem over several years. It notes that in a citation dated Jan. 9, 2025, the society charged Cramer with 12 transgressions “which in their totality suggest that she had become ungovernable as a member of the Society, and as such, was guilty of professional misconduct.”
The document states that in September of 2020, Cramer went before the law society’s complaints investigation committee (CIC) regarding a number of complaints that had been made about her practice. The committee then imposed several restrictions, including that Cramer confine her practice to the areas of real estate, wills, and powers of attorney. She was also ordered to have no more than 50 active files at a time – which the report said she failed to do,
“Accordingly, the CIC ordered further restrictions on Oct. 21, 2020 with respect to Ms. Cramer’s practice after hearing again from her and her new counsel.”
The decision goes on to say that Cramer did not comply to the restrictions ordered in October 2020. She then informed the law society that she was going to retire no later than Feb. 14, 2021, giving the organization a written undertaking of the timing and windup of her practice.
Since Feb. 14, 2021, Cramer has not been entitled to practice law as she changed her status to non-practicing, the document said. However, the decision states she continued to work on files she opened before her undertaking and accepted new work from clients.
It adds that in May 2021, Cramer set up a business called ‘Value Notary Manitoba,’ which offered to authenticate documents, take oaths, and provide legal documents.
“In the months following May 2021, Ms. Cramer now acknowledges that she took on work and continued to work in the areas of real estate transactions, estate administration and wills and estates,” the decision said.
“This work amounted to the practise of law and went well beyond the services notaries are permitted to perform.”
The law society noted that Cramer also transferred nearly $62,000 from her trust account to her business, which removed the organization’s jurisdiction to audit the funds.
The complaints investigation committee ordered Cramer’s suspension in November 2021, with two custodians appointed to take over her files. She initially contested the law society’s jurisdiction over her on the ground that she had retired, but this argument was dismissed.
“Disbarment is the most serious penalty that can be imposed on a member of the Society and it should not be lightly imposed,” the decision reads.
“In this case, we have no difficulty accepting the recommendation. Ms. Cramer clearly became ungovernable in the final years of her practice... one must conclude that Ms. Cramer completely lost sight of that most fundamental obligation of every lawyer, the duty to treat her clients, her governing body and the Court with integrity.
Cramer, who was called to the Bar of the Province of Manitoba in 1962, has been ordered to pay $13,600 to the Law Society of Manitoba.
The full document can be found online.
