Is a lawyer's prior disciplinary record an aggravating factor?

British Columbia, Canada

The following excerpt is from Geller (Re), 2017 CanLII 149972 (BC LS):

The Respondent’s prior disciplinary record is an aggravating factor. The principle of progressive discipline means that the Respondent will be subject to a more significant disciplinary sanction than someone without any prior discipline (Law Society of BC v. Batchelor, 2013 LSBC 9, paras. 49-50). The principle applies to a lawyer who has a prior disciplinary record, whether for the same or different conduct and whether the conduct is joined in one proceeding or by successive proceedings.

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