HomeMy WebLinkAboutCoelho 24-10-15 1
IN THE MATTER OF AN ARBITRATION
BETWEEN:
HAMILTON HEALTH SCIENCES
(the “Employer”)
-and-
ONTARIO PUBLIC SERVICE EMPLOYEES’ UNION, LOCAL 273
(the “Union”)
Re: Grievance of Coelho – 2021-0273-0026
Decision
Motion to dismiss – Abuse of Process
ARBITRATOR: Daniel P. Randazzo, Arbitrator
FOR THE EMPLOYER: Amanda Cohen, Counsel
Matthew Wronko, Counsel (Student)
Melina Senchyshak, Senior Lab. Rel. Specialist
Denise Riggs, Perioperative Services Clinical Manager
Ivana Melo, HR Business Partner
FOR THE UNION: Anson Cai, Counsel
Lori Reimer, OPSEU, Local 273, President
Marvin Coelho, Grievor
Alex Andrews, Counsel (February 13, 2023 only)
DATE OF HEARING: February 13, 2023
September 18, 2024
October 9 and 10, 2024
1. This matter comes to me by way of consensual appointment. The Union has grieved
the Hospital’s alleged failure to accommodate the Grievor’s family status. The
Grievor’s claim for accommodation arose during the COVID pandemic. The matter
was scheduled for hearing on February 13, 2023, September 18, 2024, October 9,
10, and 17, 2024. On February 13, 2023 I heard the parties’ opening statements and,
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as this is a non-disciplinary matter, the Union called the Grievor as its first and only
witness. The Grievor’s examination-in-chief was completed on September 18, 2024.
On October 9, 2024 the Employer proceeded to cross -examine the Grievor. During
the course of the cross-examination the Grievor refused to answer a question
regarding the name/identity of his partner. The Union objected to the relevancy of
the question regarding the name of the Grievor’s partner, however after hearing from
the parties I determined that the question was relevant and directed the Grievor to
answer. The Grievor refused. The Grievor claimed that the information sought was
private and that he did not have the written authorization to reveal the name of his
partner. The Grievor was, again, informed that the question was relevant and was,
again, directed to answer. The Grievor once again refused.
2. As a consequence of the Grievor refusing to answer the question, I issued an Order
and Direction directing the Grievor to provide the information requested. My
October 9, 2024 Order is reproduced below:
1. This matter concerns the Union’s claim that the Hospital failed to
accommodate the Grievor’s family status claim. The matter was
scheduled for hearing on February 13, 2023, September 18,
2024, October 9, 10, and 16, 2024. On the first hearing date,
February 13, 2023, following an unsuccessful attempt to mediate
a settlement, I heard the parties’ opening statements as well as
the Grievor’s initial examination-in-chief. I note that the
examination-in-chief was not completed on February 13, 2023.
2. On the second day of hearing, September 18, 2024, after a
change in counsel and a lengthy period between the first and
second hearing dates, the parties agreed to re -start the Grievor’s
examination-in-chief. I note that upon agreement of the parties,
although the Grievor’s examination was re-started, the Grievor’s
earlier testimony remained as evidence. The Grievor’s
examination-in-chief was completed on the second day.
3. On the third day of hearing, October 9, 2024, the Grievor’s cross-
examination was commenced. During the Grievor’s cross -
examination, he was asked questions with respect to the details
of family. During the exchange between the Hospital’s counsel
and the Grievor, the Grievor refused to answer a question with
respect to the name of his partner. I dismissed the Union’s
objection to the question finding that the primary issue in dispute
was a claim for an accommodation based on family status and
the details of the Grievor’s family were relevant to that issue. I
note as well, in a previous procedural decision, I had directed the
Grievor to produce unredacted copies of invoices received during
the relevant time period. The name of the Grievor’s partner is
also relevant to issues relating to the invoices produced and
identified by the Grievor in his testimony. I directed the Grievor
to answer the question and again he refused.
4. Following a discussion with counsel, it was agreed that the
Hospital would proceed with their cross-examination until the
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mid-day break at which time I would prepare an Order directing
the Grievor to answer the above noted question.
5. I make the following Order and Direction:
i. The Grievor is directed to provide the information
requested during the course of his cross-examination.
In particular, the Grievor is directed to provide the full
name of his partner.
ii. Following my discussion with Counsel, the Grievor
has until 5:00 pm October 9, 2024 to comply with this
Order and Direction.
iii. In the event that the Grievor complies with this Order
and Direction, the Hospital is entitled to continue their
cross-examination in this area should there be any
follow up questions.
iv. In the event that the Grievor does not comply with the
Order and Direction, the Hospital is directed to advise
the Union of how they intend to proceed.
6. In light of the Grievor’s refusal to answer the question referenced above and his
refusal to comply with October 9, 2024 Order, the Hospital brought a motion
seeking to dismiss the grievance on the basis that the Grievor refused to comply with
my direction and refused to comply with an Order, all of which was an abuse of
process. On October 10, 2024, the next hearing day, I heard the Hospital’s motion
and the Union’s response to the motion. Neither party called evidence in support of
their motion with both parties satisfied to argue the motion based upon the materials
and evidence thus far submitted by the parties. This decision deals with the
Hospital’s motion to dismiss.
BACKGROUND FACTS
7. I am providing a very brief description of the facts giving rise to the dispute. I note
at this juncture that I have made no findings of facts with respect to the merits of the
grievance, and the description of the parties’ positions is for contextual purposes
only. From March 2020 to December 2020, the Grievor was a part-time Respiratory
Therapist employed by the Hospital. In January 2021 the Grievor was successful in
obtaining a full-time position as a Respiratory Therapist with the Hospital. The
Grievor resides in both Canada and the United States. When in Canada he resides
with his mother in Mississauga, Ontario and when in the United States, he resides
with his long-term partner in Michigan.
8. In March 2020 the COVID pandemic erupted. As a result of the pandemic, a number
of health related safeguards were implemented. For example, and importantly, the
Canada-US border was closed. Individuals entering Canada from a foreign country,
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including the United States, were required to self-isolate for fourteen days. Further
as a result of the pandemic, the Hospital instituted a number of polices including a
policy which required employees who traveled abroad to self-isolate for fourteen
days upon their return.
9. The Grievor lives in both Canada and the United States. Prior to the pandemic, on
his workdays he resided in Mississauga, Ontario and on his days off from the
Hospital, the Grievor would travel to Michigan to spend time with his family and to
care for his children. I note that the Grievor, during the relevant time period, had two
young children.
10. As an aside, the Grievor, from March 2020 to approximately May 2021, worked a
second job which required him to travel abroad. Briefly, the second job involved the
medical repatriation of patients from abroad. The Grievor’s second job is not
relevant to the outcome of the Hospital’s motion but is a relevant issue with respect
to the merits of the grievance.
11. During pandemic, as a result of the travel restrictions and more specifically,
Hospital’s policy with respect to the fourteen day self-isolation requirement, the
Grievor claims that was unable to travel to Michigan on his non-workdays to care
for his children. In short, if he traveled to Michigan to be with his family, he would
have to, upon his return, self-isolate for fourteen days, which in turn would interfere
with his employment as a part-time Respiratory Therapist and then, after January
2021, as a full-time Respiratory Therapist with the Hospital. As a result of the
pandemic and a consequence of the Hospital’s fourteen day self-isolation policy, the
Grievor was unable to travel home and see and care for his children from March
2020 until October 2021.
12. It is the Grievor’s claim that in October 2020 he requested an accommodation for
family status which would allow him to visit his family in Michigan. I note that
there is a dispute over when the request for accommodation was made, the Grievor
claims it was made in October 2020, while the Hospital’s view is that the request
was not made until January 2021 or later. I note that I have yet to hear the Hospital’s
evidence and as such I reiterate, for clarification purposes, that these are not findings
of fact but merely a description of the parties’ relative positions.
13. Ultimately, the Grievor’s request for an accommodation was not granted. Both
parties point the finger at the opposing side as cause or reason for the refusal or
inability to accommodate the Grievor’s request for a family status accommodation.
14. The Grievor claims that as a result of the Hospital’s alleged failure to accommodate
his request, he suffered significant emotional stress and trauma as he was not
granted the ability or opportunity to be with his family for the period of March 2020
to October 2021. This, according to the Grievor, was particularly impactful as one of
his children was only seven (7) months old at the time. Further, the Grievor has
claimed that as a result of the Hospital’s alleged failure to accommodate his request,
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he incurred additional costs associated childcare. The Grievor produced several
invoices detailing the monthly childcare costs from June 2020 to May 2021. The
invoices produced by the Grievor were redacted presumably to conceal the name of
the individual to whom the invoices were directed. Prior to our October 9, 2024
hearing date, the Hospital sought copies of unredacted or original invoices. I
understand that initially the Grievor refused to provide the unredacted versions on
the basis that that the information redacted was private information. Further, I
understand that the Grievor then advised that the unredacted versions or originals
were no longer available. Following a case management meeting on October 7,
2024, I directed the Grievor to produce the unredacted versions and/or the original
copies of the invoices and to conduct a thorough review of his records. My October
7, 2024 Order is reproduced below:
1. These matters come to me by way of consensual appointment.
2. The Union, as part of the regular production process,
produced various invoices purporting to be invoices the
Grievor received from a daycare provider. The Grievor, in his
examination-in-chief, identified the documents and indicated
that the cost of the daycare was incurred as a result of
grievor’s inability to travel to his home in the US during the
COVID pandemic. The invoices produced by the Union, and
identified by the Grievor in his testimony, were redacted
concealing the name and information of to the individual or
individuals to whom the invoices were directed.
3. The Employer has requested unredacted versions of the
invoices produced. The Grievor has resisted producing the
unredacted versions on the basis that the documents are not
arguably relevant, the documents contain private information,
including private information relating to his partner, and on
the basis that he no longer had in his possession the original
copy or unredacted versions of the invoices.
4. Having heard from the parties, I am making the following
order and direction:
i. The original invoices (the unredacted versions) are
arguably relevant and should be produced by the
Grievor regardless of the fact that they may contain
private information including private information of
a third party and/or the Grievor’s partner.
ii. The fact that the documents contain private
information, including private information of the
Grievor’s partner or another individual, is not a
relevant consideration in assessing whether or not
the document is arguably relevant. There is a
process through which the private information
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contained in documents produced in an arbitration
can be protected.
iii. The Grievor is directed to produce any and all
invoices, in an unredacted form, from the daycare
providers, institutions and/or services, including
private daycare providers or services, who provided
daycare services to the Grievor’s child or children
during the relevant time period.
iv. In the event that the Grievor did not retain a copy of
the original invoices, the Grievor is directed to
undertake a thorough review of his records and
documents. Of note, the Grievor is reminded of the
ongoing duty to produce those documents that are
arguably relevant, which includes the unredacted
copies of the invoices, that are in his possession and
control.
v. In the event that the Grievor is unable to produce the
unredacted versions of the invoices, the weight and
relevancy of the redacted invoices remains an issue
the parties may address during closing arguments.
5. This matter will proceed as scheduled on October 9 and 10,
2024.
15. On October 9, 2024 the Hospital commenced their cross-examination of the
Grievor. As described in my October 9, 2024 Order, in the course of the cross-
examination, the Hospital asked the Grievor the name of his life partner. The
Grievor refused to answer on the basis that this information was private and that
he did not have the consent or written authorization of his partner to provide her
name. The Union also objected to the question on the basis that it was not
relevant. After hearing from the parties I found that the question was relevant and
appropriate. I note that the Grievor’s claim was for a family status
accommodation. The details with respect to his family were and are central to that
issue. Further, the name of the partner was also relevant to the issue of remedy
where, in this matter, the Grievor was claiming additional childcare expenses, and
as indicated earlier, the payor information on the childcare invoices had been
redacted by the Grievor.
16. I then directed the Grievor to answer the question put to him by the Hospital’s
counsel. The Grievor once again refused stating that the information was private. I
advised the Grievor that I had found the question to be relevant and that I was
unconcerned with his views with respect to the private nature of the information.
He was then again directed to answer and he once again refused. Counsel for the
Union was given an opportunity to meet with the Grievor to discuss the
importance of answering the question and the potential consequences of a refusal.
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17. During the mid-day break, I issued my October 9, 2024 Order and Direction
directing the Grievor to provide the information requested, specifically the name
of his partner. He was given until 5:00 pm on October 9, 2024. Shortly after 5:00
pm on the 9th, Counsel for the Union advised that he had spoken with the Grievor
and confirmed that the Grievor would not be complying with my October 9, 2024
Order and Direction.
18. On October 10, 2024, the Hospital brought their motion to dismiss.
19. The Hospital argued that the Grievor has demonstrated a pattern of dishonesty and
blatant disregard and disrespect for the arbitral process. The Hospital pointed to
the fact that it sought and obtained a production order directing the Grievor to
produce the unredacted versions of the invoices. The Hospital noted that the
October 7, 2024 production order directed the Grievor to produce the unredacted
invoices and to conduct a thorough review of his records. The Hospital submitted
that they had not received the unredacted invoices while noting that the copies
provided, the redacted versions, were in an electronic form that allowed for them
to be easily “unredacted”. The Hospital argued that the Grievor made no effort to
obtain an unredacted version and that the Grievor simply refused to comply with
the production order.
20. The Hospital further argued that the Grievor continued his deceit when he refused
to provide the information regarding his partner’s name, noting that in a family
status accommodation dispute, the details of the Grievor’s family go to the core of
the dispute. The Hospital argued that the Grievor refused to answer the question
notwithstanding a direction to do so and refused to comply with the October 9,
2024 Order.
21. The Hospital argued that the Grievor refused to provide the information because
he did not want the Hospital to be able to test his evidence. The Hospital
suggested that the refusal to comply, the refusal to provide relevant information in
an accommodation case demonstrates a lack of respect to the employer and his
contempt of the proceedings, as well as disrespect to the proceedings and my role
as the arbitrator.
22. The Hospital argued that the Grievor’s refusal to comply with both the October 7
and October 8 Orders, his contempt and disrespect for the proceedings and my
authority are in line with the cases where arbitrators have dismissed grievances
without a hearing.
23. The Hospital relied on the following case law in support of their motion to
dismiss the grievance without a hearing: Serco Des Inc. v USW, Local 9511, 241
L.A.C. (4th) 194; Baycrest Centre for Geriatric Care v. ONA, 2000 CanLII 39447
(ON LA); Re Budget Car Rentals Toronto Ltd. and UFCW, Local 175 (Botan),
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2000 CanLII 50165 (ON LA); Abbeylawn Manor Living Inc. v SEIU, Local 1,
2022 CanLII 76359 (ON LA).
24. The Union argued that the Grievor’s actions have not been an abuse of process,
noting that the Grievor has given testimony regarding the facts giving rise to the
complaint as well as the impact upon him. The Union noted the question
regarding the name of the Grievor’s partner was not centrally relevant to the
issues in dispute.
25. The Union argued that the redacted invoices were not put to the Grievor during
his cross-examination and his credibility with respect to the redaction of those
documents has not been tested.
26. The Union noted that a dismissal without a hearing is an extraordinary remedy
and should only be exercised in the clearest of cases. The Union argued that the
Grievor’s actions fall far short of the “clearest of cases” threshold and added that
there are lesser sanctions, such as the rejection of the Grievor’s evidence in this
area, that could address the concerns.
27. The Union argued that the name of the Grievor’s partner was an ancillary fact not
relevant to the central issue of family status and care of the Grievor’s children.
28. The Union suggested that the Grievor’s reasons for refusing to provide the name
of his partner, specifically the private nature of the information requested and the
lack of consent from the partner, were relevant considerations. I note at this time,
I interrupted Counsel and advised that I had ruled on October 9, 2024 that the
question regarding the name of the partner was relevant and the Grievor’s stated
reasons for refusing to answer were rejected. I further noted that I found the
Grievor’s refusal to answer and his failure to comply with my October 9, 2024
Order to be a blatant disregard for the arbitral process and my authority.
29. The Union argued that the Grievor had, to the best of his abilities, complied with
my direction to answer and my October 9, 2024 Order and Direction.
30. The Union relied on the following case law in support of their position: Re Budget
Car Rentals Toronto Ltd. and UFCW, Local 175 (Botan), 2000 CanLII 50165
(ON LA); Ontario (Ministry of Community, Family and Children Services) v.
Crown Employees Grievance Settlement Board, 81 O.R. (3d) 419, 2006 CanLII
21173 (Ont. C.A.); and Serco Des Inc. v USW, Local 9511, 241 L.A.C. (4th) 194.
DECISION
31. There is no dispute that an arbitrator has the power to dismiss a grievance without
a hearing. An arbitrator, pursuant to Section 48(12)(d)(e), and (j) of the Labour
Relations Act (“LRA”) and pursuant to the arbitrator’s duty to ensure a fair
hearing in accordance with natural justice, has the authority to provide remedies
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to ensure a fair hearing. This includes providing appropriate remedies to address
allegations of an abuse of process.
32. In Re Budget Car Rentals Toronto Ltd. and UFCW, Local 175 (Botan), Arbitrator
Davie was confronted with a situation in which a grievor failed to attend the
hearing and failed to comply with an order and direction. Arbitrator Davie
commented at paragraph 13 of her decision,
13. … Logic dictates that, if arbitrators have the power to
make these types of orders, there must also be authority to
enforce the orders made. Arbitral jurisprudence indicates that
as part and parcel of the authority to enforce, an arbitrator has
jurisdiction to dismiss a grievance where there has been
noncompliance with an order. Thus, a grievance may be
dismissed or held to be inarbitrable under the "abuse of
process" rubric, where a party fails to produce documents or
matters ordered to be produced by an arbitrator (Re.
Thompson Products (1970), 22 L.A.C. 85 (Roberts); Re.
National Standard Company of Canada (1994), 39 L.A.C.
(4th) 228 (Palmer)), or where a grievor refuses to participate
in the grievance/arbitration process, or refuses to otherwise
accept the authority of the arbitrator or arbitration process
(Re. Beacon Hill Lodges Inc. (1990), 15 L.A.C. (4th) 323
(Craven)).
33. The power to dismiss a grievance has been confirmed in several decisions
including, Serco Des Inc. v USW, Local 9511, Re Budget Car Rentals Toronto
Ltd. and UFCW, Local 175 (Botan), Baycrest Centre for Geriatric Care v. ONA;
Abbeylawn Manor Living Inc. v SEIU, Local 1, and Ontario (Ministry of
Community, Family and Children Services) v. Crown Employees Grievance
Settlement Board, 81 O.R. (3d) 419, 2006 CanLII.1
34. In Serco Des Inc. v USW, Local 9511, Arbitrator Luborsky stated,
47. These cases support the principles that: (a) an arbitrator
has authority to allow or dismiss a grievance without a
hearing on the merits in response to a party’s non-compliance
with a clear production or other valid procedural or
evidentiary order; (b) provided such non-compliance is shown
to arise out of a deliberate disregard for the arbitrator’s order;
(c) which is an extraordinary sanction that should only issue
1 Serco Des Inc. v USW, Local 9511, 241 L.A.C. (4th) 194, see paragraph 47; Re Budget Car Rentals
Toronto Ltd. and UFCW, Local 175 (Botan), 2000 CanLII 50165, see paragraph 13; Baycrest Centre for
Geriatric Care v. ONA, 2000 CanLII 39447 (ON LA), see paragraphs 25, 31, and 32; Abbeylawn Manor
Living Inc. v SEIU, Local 1, 2022 CanLII 76359 (ON LA), see paragraph 101; and Ontario (Ministry of
Community, Family and Children Services) v. Crown Employees Grievance Settlement Board, 81 O.R. (3d)
419, 2006 CanLII, see paragraph 28.
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in the clearest of cases where other less extreme measures
could not fairly remedy the offending party’s refusal to
comply, such as (but not limited to) drawing adverse
inferences, prohibiting the admission of a document that has
not been produced supporting the offending party’s side,
granting an adjournment or possibly awarding costs, etc.,
subject to the provisions of a collective agreement on these
matters.
35. In Baycrest Centre for Geriatric Care v. ONA, Arbitrator Gedalof, in dismissing a
grievance without a hearing, relying on Re: Budget Care Rentals Toronto Ltd. and
UFCW 175 (Baron), stated,
25. I agree with arbitrator Davie that one ought not to
exercise this discretion lightly, particularly in a matter as
significant as a discharge grievance, and that the exercise of
such a power should be reserved for the clearest cases. But I
equally agree with her statement that in processing a
grievance—a dispute resolution procedure that is intended to
provide a resolution to the dispute in a reasonably expeditious
and inexpensive manner—it is reasonable to expect that the
grievor would cooperate with reasonable requests made by the
union and would comply with the directions and orders of the
arbitrator. It is, after all, the grievor that seeks to obtain the
benefit of this process. Where the grievor fails to cooperate
and comply with orders, without good excuse, and where this
failure frustrates the arbitration process and results in
additional time and expense to the union and the employer,
there may be good reason to dismiss the grievance.
36. It is also clear from the case law, that the power to dismiss a grievance should
only be exercised in the clearest of cases and where a lesser measure, such as the
exclusion of evidence, does not address the impugned conduct.
37. In Serco Des Inc. v USW, Local 9511, Arbitrator Luborsky, following a review of
the case law, referenced the following principles:
a. An arbitrator has authority to allow or dismiss a grievance without a
hearing on its merits in response to a party’s non-compliance with a
production, procedural or evidentiary order.
b. Did the non-compliance arise out of a deliberate disregard for the
arbitrator’s order.
and
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c. A dismissal is an extraordinary sanction that should only issue in the
clearest of cases where other less extreme measures could not fairly
remedy the offending party’s refusal to comply.2
38. In the circumstances of this matter and motion to dismiss before me, the Grievor
was asked the name of his partner. He declined to answer. I found, that in the
circumstances of this case, the question was relevant and appropriate. I directed
him to answer the question. He, once again, refused to answer stating that the
reason for his refusal was the private nature of the information sought and that he
did not have the consent or written authorization from his partner to provide the
partner’s name. I again directed him to answer while advising that his reasons for
refusing to answer were not acceptable. He refused again. During a brief
adjournment, Counsel for the Union was given an opportunity to speak with the
Grievor. Following this exchange and a mid-morning break, I issued an Order and
Direction directing the Grievor to provide the information, namely the name of
his partner. He was given until 5:00 pm to comply with the Order and Direction.
(The contents of the October 9, 2024 Order and Direction are reproduced above).
Shortly after 5:00 pm on October 9, 2024, Counsel for the Union advised, via
email, that the Grievor would not be complying with the October 9, 2024 Order
and Direction.
39. I find that the Grievor refused to comply with a valid procedural and production
order and that his refusal demonstrated a deliberate disregard for the arbitral
process, the order, and my arbitral authority. The first two elements of the factors
referenced by Arbitrator Luborsky in Serco Des Inc. v USW, Local 9511 have
been clearly established.
40. I note at this time, that I firmly rejected the Grievor’s justification or reasons for
his non-compliance. It is not unusual, in fact it is expected, that in a claim for
accommodation, the individual claiming the accommodation will be required to
provide private personal information, and in a claim for accommodation based on
family status, it is expected that the individual claiming accommodation will be
required to reveal private personal information regarding his or her family.
41. The Union argued that I should consider the Grievor’s non-compliance as less
serious given that the information sought, the name of the Grievor’s partner, was
an ancillary fact and not relevant to the central issue of family status
accommodation. Although I agree with the Union that the information was likely
not crucial to the central or core issue, this however is not the test and glosses
over a deliberate non-compliance to a procedural and production order. The
Hospital is entitled to the information. They raised concerns regarding the
redacting of the invoices and they are entitled to test that information and/or probe
into their concerns. It is not the Grievor’s role to determine what evidence will or
will not be canvassed. The Grievor is not curator of relevant facts. The analysis is
whether the Grievor deliberately or blatantly disregarded a direction and order.
2 Serco Des Inc. v USW, Local 9511, 241 L.A.C. (4th) 194, para.47.
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That question is answered definitely in the affirmative. The importance of the
information or facts withheld has little if any weight in the analysis of whether
there has been a deliberate non-compliance.
42. The Union argued that the Grievor, to the best of his abilities, attempted to
comply with the direction and order. I disagree. As described above, the Grievor’s
non-compliance was deliberate and blatant. His refusal to answer, what can only
be described as a simple straightforward question, defies logic and common
sense.
Is there a less extreme measure than dismissal, that can fairly remedy the
Grievor’s non-compliance with the directions given on October 9, 2024 and
the October 9, 2024 Order and Direction?
43. Having considered the parties’ submission and the case law, I am of the view that
dismissal is the appropriate remedy. I have considered the fact that the non-
compliance was deliberate and blatant. The Grievor was given a number of
opportunities to correct the course of his actions/decision but chose non-
compliance and did so after having an opportunity to speak to Union Counsel.
44. I also considered the seriousness of the matter before me. A claim for
accommodation based on family status is an important or serious matter that can
have potential future consequences. However, in the matter before me, the claim
or need for accommodation has lapsed. The need for accommodation arose due to
the COVID pandemic and the Hospital’s requirement that employees who are
returning from abroad (including the United States) were required to self-isolate
for fourteen days. The requirement to self-isolate for those who were fully
vaccinated was lifted by the Hospital in July 2021. Further, the requirement to
self-isolate, for all employees, including those who were fully vaccinated and
those who were unvaccinated, was lifted by the Hospital in or around October
2021. The Grievor’s requirement to self-isolate for fourteen days, and therefore
the need for an accommodation, ended as early as July 2021 but no later than
October 2021. The case before me does not involve a continuing liability or a
continuing claim for accommodation. The Union argued that the case, despite that
an accommodation was no longer needed, remained important to the Grievor.
Briefly put, the Grievor was unable to see his family for over one and half years,
an affirmative decision in this matter could or would be of great benefit in the
Grievor’s need to remedy the lost time and perhaps repair an injured relationship
with his family. I have a great deal of sympathy for those traumatically affected
by the pandemic. However, in the context of a motion to dismiss, this is not a
consideration in determining the importance of this case. When assessing the
importance of a case, we are looking at a labour relations importance. A
termination, obviously, has a high level and ongoing, importance. A claim for an
ongoing need for accommodation carries with it a high level of importance. In the
matter before me, the Grievor’s claim for accommodation commenced either in or
around October 2020 or in January 2021 or later and ended either in July 2021 or,
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at the latest, October 2021. A remedy following a potential finding in favour of
the Union upholding the Grievance in this matter, would not result in an ongoing
family status accommodation and most likely, and importantly, would not have an
impact on the ongoing or future employment rights for the Grievor and would not
affect the ongoing relationship with his employer.
45. With respect to less extreme measures to remedy the Grievor’s non-compliance,
the Union suggested the exclusion of some of the evidence in the area that there
was a refusal to answer a relevant question. It is my view that this was the
purpose or the Grievor’s intended result by the refusing to answer and does not
address or remedy the Grievor’s non-compliance.
46. I considered the alternative remedy of excluding all of the Grievor’s testimony.
This, at first glance, is less extreme than a dismissal and would address the
Grievor’s non-compliance. However, it is not lost on me that this is a claim for an
accommodation, as such the Union carries the onus. The exclusion of the
Grievor’s testimony, when the Grievor is the Union’s only witness, is tantamount
to a dismissal. Further, the exclusion of the entirety of the Grievor’s evidence
could adversely affect the Hospital’s case as they, very likely, would seek to rely
on some of Grievor’s evidence in support of their defence.
47. Finally, I considered the alternate remedy of addressing the Grievor’s non-
compliance when assessing the Grievor’s reliability and credibility. Although this
was the Hospital’s alternative position, it is my opinion that this measure did not
properly address the Grievor’s deliberate and blatant disregard for the arbitral
process and my orders and directions. The Grievor’s decision to not comply with
my directions and order must have sanctions that fit the misconduct. The Grievor
has demonstrated a blatant d isregard for the arbitral process and my authority as
an arbitrator and as a consequence he has forfeited his right to proceed.
CONCLUSION
48. Before concluding, I want to address two matters.
49. First, the Hospital argued that the Grievor was deceitful in his failure to comply
with my October 7, 2024 order directing him to produce unredacted copies of the
invoices and directing him to conduct a thorough review of his records. The
Hospital’s argument and position were primarily based on their view that the
invoices were redacted electronically and the electronic copies, provided in PDF,
could be unredacted in mere seconds. The Hospital suggested that the Grievor
would be aware of this and was, therefore, at all times in possession of unredacted
copies of the invoices. I note that it is likely that the Hospital is correct in that the
invoices would be easily electronically unredacted. However, the Grievor’s
information or understanding of how the documents could be unredacted was not
tested in evidence and I am therefore unable to conclude that the Grievor knew
the documents could be easily redacted, and was therefore deliberately or
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blatantly in non-compliance with my October 7, 2024 Order. In coming to the
conclusion that the grievance should be dismissed without a hearing into its merits
for an abuse of process, I did not consider the Hospital’s argument that the
Grievor was in deliberate non-compliance of the October 7, 2024 Order
50. Second, I want to be clear that it is my view that the parties, and their Counsel,
have conducted themselves professionally and commendably throughout this
hearing. I thank both Counsel for their patience and professionalism in how they
dealt with a very difficult situation. The dismissal for an abuse of process is a
direct consequence of the Grievor’s conduct and does not reflect upon the parties
or their Counsel.
51. In conclusion, I find that the Grievor’s deliberate and blatant refusal to comply
with my procedural directions and orders and his deliberate and blatant refusal to
comply with my October 9, 2024 Order and Direction was an abuse of process. In
the circumstances of this matter, which include the Grievor’s disregard and
disrespect towards the arbitral process and my arbitral authority, the fact that in
this matter the Union carries the onus, and the fact that the Grievor is the Union’s
only witness, I find that it is appropriate to dismiss the grievance without a
hearing into its merits.
52. The hearing date scheduled for October 17, 2024 is cancelled.
Dated at Ancaster this 15th day of October 2024.