What is the test for presumptive revocation of a lawyer’s licence for misappropriation?

Presumptive revocation also applies to misappropriation: Wilkins at paras. 99-104. This fits easily with the reasoning in Abbott. Misappropriation is “in a different register, or of a different quality, than other lawyerly misconduct.” In cases of misappropriation, at issue is whether “in the public interest, the profession can accept the continued licensing of a person who has shown himself to be willing to participate, for personal gain, in stealing someone else’s money; does the member have the moral character to continue to be in a position of trust?”. We also note that the appeal panel in in Law Society of Ontario v. Bahimanga, 2019 ONLSTA 25 observed at para. 106 that “recent jurisprudence has treated serious cases of dishonesty or intentional misrepresentation in billing with the same severity as mortgage fraud” and applied presumptive revocation at para. 108.