HomeMy WebLinkAbout1997-0383.McQueen.99-04-27EMPLOY& DE LA UWRONNE
DE L’ONTARD
COMMISSION
ReGLEMENT
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DE
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IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Archie McQueen)
Grievor
- and -
The Crown in Right of Ontario
(Ministry of the Solicitor General and Correctional Services)
Employer
BEFORE Felicity D. Briggs Vice-Chair
FOR THE
GRIEVOR
Nelson Roland
Barrister & Solicitor
FOR THE
EMPLOYER
Lucy Siraco
Counsel, Legal Services Branch
Management Board Secretariat
HEARING April 14, 1999
The grievor, Mr. Archie McQueen, was a corrections officer for approximately twenty years
prior to his discharge. On June 20, 1997, he filed a grievance stating that he had been
dismissed without just cause. By way of remedy, he asked to be reinstated with full
compensation and benefits. The parties have agreed that I have jurisdiction of other
grievances and the matters shall be consolidated. At the second day of hearing there was
further discussion about the inclusion of further related matters. However, that issue is not
yet resolved.
At the first day of hearing, two preliminary matters were addressed, the first regarding an
order for production of the Independent Investigation Unit’s (NJ) background notes which
was given by the Board and the second was a request for the production of the entire
personnel files of the employees who complained about the grievor. This second motion was
denied. A written decision was issued regarding these matters.
Also on the second day of hearing, the Employer sought to introduce the evidence that was
acquired subsequent to the grievor’s discharge. To be specific, the Employer intends to
introduce the IIU report and background notes flowing from the investigation. Additionally,
it might call witnesses who were interviewed during the investigation. Counsel for the
Employer said that it would rely upon this information as further grounds for just cause. In
this regard, the Employer relied upon Re Ontario Hydro and Canadian Union of Public
Employees, Local 1000 (1988), 3 L.A.C. (4th) 112 (Brent).
The Union objected to the introduction of any evidence obtained subsequent to the grievor’s
discharge. The Union was concerned of the hearsay nature of that evidence. Additionally,
it argued that the Employer was very specific in its allegations regarding the grievor’s
discharge and the Employer ought not be allowed to expand its case at this juncture. The
grievor has been disciplined and discharged for very specific incidents. The Employer is
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attempting to bolster its case with additional incidents. It would be inappropriate for this
Board to hear evidence about matters for which the grievor was not disciplined at the time.
The Union relied upon Re General Motors of Canada Ltd. and United Automobile
Workers, Local 303 (1981), 2 L.A.C. 252 (Palmer); and Re Rennie Inc. and
Amalgamated Clothing & Textile Workers Union, Local 740 (1993), 39 L.A.C. (4th) 76
(Haefling); Re Newton Ready Mix Ltd. and Teamsters Union, Local 213 (1984), 17
L.A.C. (3d) 333 (Dorsey).
As I understand the Employer’s intentions, it seeks to introduce evidence regarding
additional incidents of threatening and harassing behavior similar to the conduct for which
the grievor was discharged. In Re Rennie (supra), the grievor was originally terminated for
“lack of work”. However, following the submission of the grievance to a board of
arbitration, the Company attempted to argue that the discharge was for just cause. In
General Motors (supra), arbitrator Palmer did not allow the Company to assume that in any
disciplinary case, the total record of the grievor could be taken into account. The Company
had attempted to raise the issue of the grievor’s disciplinary record as a factor to be
considered in determining whether there was just cause at the hearing notwithstanding that
there was no such reference made to it in the letter of discharge. In Newton (supra), the
board of arbitration allowed the introduction of evidence of the grievor’s work history when
it was not referred to in the letter of discharge. However, that evidence could only be
considered for the issue of the Board’s discretion to substitute a lesser penalty than
discharge. In Ontario Hydro (supra) the Board was asked to hear and accept evidence
regarding further misconduct of the grievor. The evidence was not available to the employer
until after the grievor was discharged. However it was related to the reasons the grievor was
discharged in the first instance. The evidence was provided to the Union before the hearing.
i In that decision the Employer undertook a comprehensive audit after the grievor was
i terminated and it was the results of that audit the Employer sought to introduce. The Board I ~_
stated at page 12 1:
It is therefore our conclusion that we must approach the question of the admissibility of this
evidence as a question of whether Hydro can introduce and add new grounds for the
discharge under the circumstances which are before us.
The Board then considered Re U.S.W.A. and Aerocide Dispensers Ltd. (1965), 15 L.A.C.
416 (Laskin). In stated further on page 122:
Quite clearly the board was not dealing with the question of new evidence acquired after the
discharge which gave rise to a new and separate charge against the employee. It was dealing
with an attempt to change the grounds for discipline, after the evidence was heard, while
effectively abandoning the stated grounds because the evidence brought forward at the
hearing could not support the stated grounds. It was an attempt to recharacterize the grounds
for discharge to fit the evidence it actually had as opposed to the evidence it thought it had.
The case says nothing about a situation where prior to arbitration the employer gives notice
to the union that subsequent to the discharge it has discovered additional examples of
wrongdoing for which it would have disciplined the employee had it known of them while
the employee was still in its employ.
At page 123 it was said:
With respect, though, we consider that following Loblaw reasoning Aerocide should be read
as limiting the employer to the stated grounds for discharge only in the sense that it
precludes the employer from trying to fashion a new ground for discharge out of the incident
it acted upon in order to fit the evidence it has rather than the evidence it thought it had.
However, if the employer learns of something new after it has decided to discharge and that
“something new” would justify discharge on its own, should the employer be precluded
from raising it as a new and separate ground of discharge as of the date that it determined
that the “something new” should be relied on as cause for discharge, provided that all
procedural safeguards are complied with? Lobhv answers that question by allowing the
introduction of the after-acquired evidence. Therefore, it seems that one must distinguish
between cases where the evidence has not come out as expected and employers try to bolster
a weak case by trying to turn what is now seen to be a sow’s ear into something resembling
a silk purse, and those cases where employers come forward with newly acquired evidence
which could have been relied on as grounds for discharge had the person still been employed
when the evidence became known to the employer.
The Loblaw decision is one which arrives at a fair solution to a difficult problem. The
employer is allowed to introduce a separate ground for discharge, evidence of which only
came to its attention following the discharge. This precludes any possibility of the employer
being able to use that evidence to support a discharge following a reinstatement as occurred
in the Wuxana case, supra. The requirement that the union receive full notice of the new
grounds before the hearing means that it is not taken by surprise and so is not deprived of
its ability to present its case. . . . . . . .
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The Board also cited from a decision of Arbitrator Howard Brown Re St. Joseph’s
Hospital, Hamilton and Ontario Nurses’ Association (1978), 17 L.A.C. (2d) 404 wherein
it was stated at page 406:
. . . ..the evidence sought to be introduced by the employer of incidents involving the grievor
discovered following the grievor’s discharge but which occurred prior to the discharge and
which relate to the basis on which the employer’s action was taken is admissible.
The general rule is that employers are held by arbitrators to substantiating their cases on the
basis of the grounds on which they originally took the disciplinary action, and they are not
allowed to submit evidence in support of reasons different than the stated basis for the
disciplinary action. Nor it the employer entitled to submit evidence to justify the disciplinary
action on new and unrelated matters to the action which precipitated the discharge.
Here, according to the submission of counsel, the evidence sough&to be introduced concerns
incidents relating to the allegation of the grievor’s incompetency which were not within the
knowledge of the employer at the time the decision to discharge was taken, nor was that
knowledge available to it at that time. This evidence is not produced to support new or
different grounds for discipline, but it is submitted as further examples of the reasons for
discharge and in corroboration of the reasonableness of the employer’s initial action. If that
evidence related to an alleged offence separate and apart from that on which the disciplinary
action was taken, and even though it was not know to the employer at the time of the
disciplinary action with certain limited exception expressed in the Carter Carburetor and
DougZas Aircraft decisions, the evidence would not be admitted. That kind of evidence is
distinguishable from the evidence which counsel for the employer in this case has advised
us he intends to produce, which would relate to other examples of the grievor’s work
performance, which, had they been known at the time of the discharge, would have
supported its position.
The St. Joseph Hospital decision is similar to the matter at hand. As I understand the
submission of employer counsel, it seeks to introduce evidence arising from the IIU report
and documentation which only came into its possession approximately three months after
the grievor was terminated. The evidence that will be introduced relates to the reasons given
for the grievor’s discharge, that is evidence regarding threatening and harassing behavior
towards others including his co-workers. Accordingly, I will hear the evidence. What
weight, if any, that evidence should be given will be a matter for argument in the parties’
final submissions.
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Dated in Toronto this 27th day of April, 1999.