Winnipeg lawyer disbarred at age 86 after 'a litany of transgressions'

An 86-year-old Winnipeg lawyer who practised for nearly 59 years has been disbarred after defying law society orders to limit the scale of her work — well after she told the society she planned to retire.

Caroline Cramer was cited in early January for 12 separate 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," says a written decision by a panel of the Law Society of Manitoba.

In response, Cramer agreed. The disbarment was a joint recommendation put forward by counsel for the law society and Cramer during a hearing on Jan. 14.

The panel's written decision, which also ordered Cramer to pay $13,600 in costs, was released March 31.

In the decision, the panel tipped its hat to Cramer for her fortitude in becoming a lawyer in the first place. She was the only woman in her 1962 University of Manitoba law school graduating class.

'Sad' end to career

"It is sad to see a legal career of almost 59 years with only a very modest, previous record, end in disbarment," the decision says. 

"In Ms. Cramer's case, we can acknowledge that her choice of law for a profession was particularly challenging in a day when almost no women chose it and those who did frequently were not respected or encouraged to continue.

"No doubt, over the decades she conscientiously served many clients who were helped and grateful for her assistance."

The panel also thanked Cramer for admitting to her conduct and, by agreeing to the joint recommendation, sparing former clients from having to testify.

The misconduct dates back to September 2020, when Cramer appeared before the law society's complaints investigation committee to respond to "a number of complaints made regarding her practice," says the panel's explanation in the decision, which did not elaborate on the nature of those complaints.

The committee imposed a number of restrictions on her practice, primarily that she confine it to the areas of real estate and the preparation of wills and powers of attorney. She was also told to manage her workload by taking on no more than 50 active files at a time.

She failed to comply, which led to the CIC ordering further restrictions in October 2020. She was directed to close or transfer all files unrelated to the restrictions imposed on her and ordered to co-operate with a review of her practice.

Cramer again failed to comply and in December 2020, she gave the society a written undertaking (legal promise) to retire no later than Feb. 14, 2021. Since that date, she has not been entitled to practise law, the panel decision says.

However, she not only continued to work on files she opened prior to the undertaking, she accepted new work from clients.

In May 2021, "well after the date she was to have ceased doing any legal work," Cramer set up a business as a notary public, offering to review and authenticate documents, take oaths and provide legal documents, the panel decision says.

She also continued to work on real estate transactions, estate administration and wills and estates, which "went well beyond the services notaries are permitted to perform," the decision says.

"Ms. Cramer improperly represented to members of the public that she was still entitled to practise law."

Further, Cramer transferred more than $61,000 from her trust account to that of a corporation she controlled, thereby removing it from the audit jurisdiction of the law society. She then created inaccurate trust accounting records that were given to the society to make it appear she was in compliance with the undertaking, the decision says.

Discrepancies in finances

She transferred client money to herself with no basis for doing so, and there were also discrepancies in financial ledgers around cheque payments, the decision says.

Cramer also attempted to persuade other members of the law society to allow her to use their names to facilitate real estate transactions as she could no longer complete registrations through the Land Titles Office, and improperly used the name of one member to file a request for probate of a will.

In November 2021, she was suspended from practising law in any capacity. Court-appointed custodians were directed to take custody of all files and funds belonging to her clients.

But Cramer didn't co-operate with the custodians and didn't respond completely or accurately to requests for information from the society's auditors and investigators, the decision says. She also contested the society's jurisdiction over her on the grounds that as of Feb. 15, 2021, she was retired.

That argument, though, was dismissed by a law society panel in May 2023.

In its March 2025 decision, the panel said 17 clients and three other people were affected by Cramer's failure to wind up her practice when she was supposed to, and by her repeated failures to provide complete and accurate information.

By the date of the January hearing, however, all trust money had been accounted for.

"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," the panel wrote in its March decision.

Her conduct "amounted to a litany of transgressions that reflect poorly on the legal profession and could not help but erode trust in her on the part of the public and most certainly the society," the panel said, agreeing the "only reasonable course is to disbar her."