When ‘professional judgment’ is used as a blank check to violate basic math without explanation, it’s no longer regulation. It’s a cartel.
By Bob Uttl
Imagine a system where a modern Canadian citizen’s intelligence test score is evaluated by comparing it to the scores of segregated U.S. soldiers from the World War II era. Now imagine the Alberta Ombudsman ruling that this is completely reasonable—but refusing to explain why.
Welcome to the looking-glass world of professional self-regulation, where basic mathematics can be subverted by the phrase “professional judgment.”
The Illusion of Competence
Dr. Troy Janzen, Deputy Registrar and Complaints Director for the College of Alberta Psychologists, decided—among many other astonishing things—that comparing Ms. T’s WAIS-IV CDN (2008) FSIQ to the General Classification Test (GCT) mean scores of U.S. White enlisted men from World War II was at least “minimally competent” conduct.”
Dr. Troy Janzen gave no reasons for his decision. He provided no rational connection between the psychometric evidence before him and his conclusion that a comparison across different tests, different standard scores, different historical eras, and completely different populations was scientifically sound.
Similarly, the College’s Complaints Review Committee (CRC), chaired by Dr. Lorraine Breault, decided that Dr. Janzen’s decision was “reasonable”—but gave no reasons of its own. The CRC didn’t even mention the WWII comparison in its text. It merely stated that Dr. Janzen considered Ms. T’s complaints and decided that whatever the three psychologists involved (Dr. Mary Westcott, Dr. Allan Mandel, and Dr. John Braxton Suffield) did—including the use of 80+ year-old military GCT norms and other decades obsolete norms—constituted acceptable professional practice.
How the College of Alberta Psychologists concluded that this cross-test time travel was reasonable remains a complete mystery. Any minimally competent psychologist ought to know that:
- Incompatible Metrics: The WAIS-IV CDN and the GCT are standardized with different standard deviations. Directly comparing incomparable standard scores violates the basic laws of mathematics and statistics.
- Non-Representative Demographics: The WAIS-IV CDN was normed in 2007 on the Canadian population. The GCT was normed around 1939 on U.S. military personnel, and the GCT means used in the comparison were based on a highly selective, segregated pool of U.S. White enlisted men in World War II era.
- The Flynn Effect: Because IQ norms rise by roughly 0.3 points per year, comparing tests standardized nearly 70 years apart is psychometrically invalid and plain ridiculous.
Accordingly, the College of Alberta Psychologists’ dismissals for Ms. T’s complaints was appealed to Alberta Ombudsman. The Complaint against Dr. Allan Mandel, College of Alberta Registered Psychologists, was assigned to Ms. Madi Didychuck, Acting Senior Investigator, Alberta Ombudsman.
The Ombudsman and the Vanishing Rationale
For an administrative decision to be legally “reasonable,” it must be justified, transparent, and intelligible in light of the facts and the law (the standard established by the Supreme Court of Canada in Dunsmuir and reaffirmed in Vavilov).
Initially, Ms. Madi Didychuck, Acting Senior Investigator for the Alberta Ombudsman, outlined her role in an email dated April 15, 2026:
“I understand you have concerns about the technical aspects of your complaint. It is important to clarify that the Ombudsman does not re-evaluate the evidence considered by the original decision-maker and does not act as a substitute decision-maker. Instead, my review assesses the information that was before the CRC to determine whether the decision is reasonable—that is, whether it falls within a range of possible outcomes based on the information and arguments presented. Accordingly, my review focuses on whether the CRC’s process and decision meet the requirements of administrative fairness.”
Ms. Madi Didychuk, April 15, 2026
The Alberta Ombudsman’s own published guidelines on “Adequate Reasons” state:
It is not enough to outline the evidence and arguments made by the parties. There must be a rational connection drawn between evidence and conclusions, including a clear explanation of how relevant legislation, regulation or policy was applied.
Alberta Ombudsman, Administrative Fairness Guidelines
Yet, astonishingly, Ms. Didychuck dismissed Ms. T’s appeal. She agreed with Dr. Troy Janzen and the CRC that comparing a modern WAIS-IV CDN score to a 1939 based U.S. military mean scores of White enlisted men was reasonable.
The “Highlight in Yellow” Test
On May 20, 2026, I wrote back to Ms. Didychuck seeking clarification on how this conclusion met the legal threshold of administrative reasonableness:
I would also appreciate clarification regarding the reasoning supporting the conclusion that Dr. Mandel’s reliance on 80+ years obsolete, invalid, and non-representative norms from a foreign country constituted reasonable and minimally competent professional conduct.
I am not asking the Ombudsman to reweigh the evidence or substitute its own decision for that of the CRC. Rather, I am seeking to understand the actual reasoning process connecting the facts, the applicable Standards of Practice, and the conclusion that no breach occurred. As explained in Canada (Minister of Citizenship and Immigration) v. Vavilov, administrative reasonableness requires a transparent and intelligible chain of analysis connecting the evidence, the governing legal framework, and the outcome reached.”
Dr. Bob Uttl, Email to Ms. Didychuck, May 20, 2026
On May 25, 2026, Ms. Didychuck replied:
“Regarding your concerns about obsolete, invalid, and non-representative norms, the Complaints Director considered your arguments on pages 10 and 11 of his decision. The CRC considered your arguments and the Complaints Director’s analysis on page 10 and 11 of its decision. Again, while I understand you disagree with these findings, I am satisfied the CRC decision is reasonable because your arguments [were] adequately considered and the findings sufficiently explained.”
Ms. Madi Didychuck, May 25, 2026
Because those specific pages contained absolutely no psychometric or logical justification, I responded with a simple challenge:
Ms. Didychuck:
Unfortunately, your explanation fails to provide the required chain of authority connecting the evidence before the decision-maker to the outcome through the application of the law (Health Professions Act, Standards of Practice, and Code of Ethics). To be clear: the specific pages in the Complaints Director’s and the CRC’s decisions you refer me to do NOT provide a chain connecting the evidence to the outcome.
… Please highlight in yellow the exact lines in Dr. Janzen’s or the CRC’s decisions detailing the rationale as to why it is acceptable to use 1939 U.S. segregated military norms to evaluate Canadians in 2010 on a different psychometric test. I assure you that not only the complainant, but all Albertans, have a right to and are looking forward to see this chain of reasoning.
Dr. Bob Uttl, Email to Ms. Didychuck,
The Magic Word: “Professional Judgment”
On June 1, 2026, Ms. Didychuck sent her final refusal:
Good afternoon,
I understand you disagree with the Complaints Director’s and CRC’s finding that it is a matter of professional judgment. I also understand you believe it is unfair that they did not specifically address all the concerns you raised. From an Ombudsman perspective, it is not necessary for the CRC to respond to every argument made by a party; they are only obliged to respond to significant and relevant portions of a submission. Of note, the CRC acknowledged that not every submission is addressed in the decision; however, the CRC did consider the entire submissions advanced on Ms. T’s behalf. As a result, I am satisfied the CRC adequately addressed your arguments and the decision is reasonable.”
Ms. Madi Didychuck, June 1, 2026
Unsurprisingly, Ms. Didychuck did not highlight a single line in yellow. She couldn’t. No such rationale exists in Dr. Troy Janzen and the CRC’s decisions.
Instead, Ms. Didychuck hid behind a standard bureaucratic defense: an administrative body doesn’t have to answer every single argument. But under Canadian administrative law (Vavilov), decision-makers must address arguments that are central to the matter. Using 80-year-old, obsolete, cross-test norms is not a minor peripheral detail—it is a foundational flaw that invalidates the entire assessment.
By declaring a decision “reasonable” when it contains a complete absence of logic and rationality, the Ombudsman’s office transforms the phrase “professional judgment” into a magical incantation.
If a regulatory college can invoke “professional judgment” to override the basic laws of mathematics and statistics without explaining why, then professional self-regulation is dead. It has devolved into a medieval guild system—a cartel operating solely to protect its own members and institutional power rather than the public interest.
The record now clearly demonstrates a multi-tiered failure of accountability:
- The Psychologists used scientifically invalid data to evaluate a Canadian woman.
- The College of Alberta Psychologists shielded them by refusing to address the science.
- The Alberta Ombudsman validated this silence, ruling that a mathematical impossibility requires no explanation.
When logic and science hit the wall of institutional self-protection, accountability disappears. We are left with nothing but administrative witchcraft and magical incantations.