Decision record
CHRISTINA MARIE CHANG
Allegation / charges
Professional Misconduct. Referral to Supreme Court (full bench) recommending name be removed from the roll of practitioners
Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision
The State Administrative Tribunal of Western Australia found legal practitioner Christina Marie Chang guilty of professional misconduct on three grounds: (1) knowingly misleading a former client by email statements falsely claiming she had notified/corresponded with her insurer, to defer the client from suing her; (2) knowingly misleading the Magistrates Court and the client at pre-trial conferences by falsely claiming an insurer was involved, to delay proceedings; and (3) without reasonable excuse failing to respond to three notification letters and two summonses from the Committee. The Tribunal expressly found her conduct dishonest and grossly unfair. On penalty (2020 decision), the Tribunal held she was permanently/indefinitely unfit to practise, rejected her medical/mitigation arguments (finding her PTSD/Depression did not cause the dishonesty, though it partly explained the failure to respond), and made and transmitted a report to the Supreme Court (full bench) recommending her name be removed from the roll. She was ordered to pay the Committee's costs fixed at AUD 20,761.35.
Duties found breached:
- No taking unfair advantage
- Not mislead third parties or opponents
- No baseless or threatened misconduct report
Aggravating factors:
- Conduct involved deliberate dishonesty, not an isolated error - three instances forming a course of dishonest conduct over about four months
- Knowingly misleading a court, which goes to the heart of a practitioner's duty as an officer of the court
- Failures to respond to the regulator were sustained and repeated over three stages of investigation and continued for over one-and-a-half years
- No genuine remorse or insight demonstrated; failure to understand the significance of the misconduct
- Practitioner never sought an extension or engaged with the Committee
Mitigating factors:
- Diagnosis of Post-Traumatic Stress Disorder and Depression/Anxiety; medical evidence that avoidance behaviour helped explain (though did not excuse) failure to respond to notification letters and summonses
- Engagement with psychiatric and psychological treatment
- Five character references filed (though given little weight)
- Complainant suffered no loss and did not enforce the default judgment
- Prior disciplinary history not treated as an aggravating factor
- Conduct in grounds 1 and 2 occurred in personal/migration agent capacity rather than in legal practice
Duties engaged
Other decisions involving this respondent
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