Harris v. Levine, 2014 ONCA 608:
 Where there has been a finding of guilt that has been undisturbed on appeal, allegations of ineffective representation generally should be made by way of a direct attack in the context of the criminal proceeding, (Folland v. Reardon (2005) 74 O.R. (3d) 688 (C.A.) at para.100) and not by way of a separate civil proceeding. The abuse of process in particularly pronounced in the present case where the conviction has not been overturned and Mr. Harris raised but did not pursue the issue of competence of counsel on appeal.