HomeMy WebLinkAbout2011-1335.Union.13-11-20 DecisionCrown Employees
Grievance Settlement
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Commission de
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GSB#2011-1335
UNION#2011-0999-0033
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Union) Union
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The Crown in Right of Ontario
(Ministry of Attorney General) Employer
BEFORE Nimal Dissanayake Vice-Chair
FOR THE UNION Tim Hannigan
Ryder Wright Blair & Holmes LLP
Barristers and Solicitors
Counsel
FOR THE EMPLOYER Len Hatzis
Ministry of Government Services
Legal Services Branch
Counsel
HEARING November 1, 2013
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Decision
[1] This decision deals with a motion by the union for certain remedial orders, which are
opposed by the employer. The following background puts the dispute into context.
[2] A number of grievances, including the instant union grievance dated June 29, 2011
came before the Board on February 21, 2013. At the time, the Board had previously
held in Re Hunt, 2001-0534 (Abramsky) that the work of preparation and certification
of transcripts performed by court reporters is bargaining unit work to which the
collective agreement applied, that OPSEU was the exclusive bargaining agent of the
court reporters for that work, and that the employer could not treat court reporters as
falling outside of the collective agreement in regard to that work. A declaration was
made that the employer had violated collective agreement by not applying it to the
work in question.
[
3] It was agreed that despite those findings and declaration, the status quo continued in
that the employer did not apply the collective agreement to court reporters doing the
transcription work, and continued to treat them as independent contractors not covered
by the collective agreement. In the circumstances, the union filed the instant policy
grievance and sought a cease and desist order and an order that the employer apply the
terms and conditions of the collective agreement to court reporters performing
transcription work. The employer objected to the granting of those orders on a
number of grounds.
[4] In a decision dated March 1, 2013, for the reasons set out therein, the Board rejected
the objections of the employer, and at paragraphs 36 and 37 ordered as follows:
[36] It follows from the foregoing that none of the submissions advanced by the
employer causes the Board to refuse the remedial orders sought by the union.
Therefore, the Board orders as follows:
(1) The employer shall forthwith cease its violation of the collective agreement by
failing to apply the collective agreement to Court Reporters, who the Board has
declared to be employees performing bargaining unit work when producing
transcripts.
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(2) The employer shall forthwith apply the collective agreement to court reporters
performing bargaining unit work of production of transcripts, and shall not treat them
as independent contractors.
[37] The Board remains seized with jurisdiction with regard to any disagreement
between the parties as to the implementation of the orders made herein, and with
respect to all of the other grievances before it.
[5] The union claimed that following the issuance of the foregoing orders the employer
continued to treat the work in question as falling outside the collective agreement and its
terms were not applied to court reporters performing the transcription work. The union
requested that the employer comply with the Board orders. However, the status quo
continued. In the circumstances the Board orders were registered with the Ontario
Superior Court of Justice. On March 27, 2013, union counsel wrote to employer counsel,
inter alia, as follows:
This decision is now a decision of the Superior Court of Justice and is enforceable as
such. Please advise as soon as possible, but no later than April 3rd 2013, if the
Employer will immediately take all necessary steps to fully comply with this order.
Should the Employer fail to comply with the order I will seek instructions from my
client to bring a motion for an order for contempt and pursue the appropriate penalty
for such contempt which could include a fine or incarceration.
[6] The union did subsequently make application before the Superior Court and a hearing is
scheduled before the Court on March 17, 2014. The Court’s endorsement dated April 24,
2013 states that “OPSEU is moving for contempt against the crown”, and lists the issues
to be determined as follows: “1. Can crown be held in contempt? 2. GSB order made an
order of the court: Has the order been violated?” In the instant proceeding, the employer
did not assert that it was applying the terms of the collective agreement to the work in
question or that it had ceased treating court reporters performing that work as
independent contractors as ordered by the Board. Nor did the employer concede that it
had failed to comply with the Board orders. It appears from the fact that the issue of
whether the employer violated the Board’s orders is before the courts, that the issue
would be argued before the court as part of the contempt proceedings. .
[7] It is against this backdrop that the union seeks from the Board the following additional
orders. First, the union seeks an order that the employer identify to the union the
individual or individuals who are responsible for not complying with the Board orders.
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Second, the union seeks an order from the Board against the individual or individuals so
identified, that they forthwith comply with the Board orders issued on March 1, 2013.
The union submitted that if the Board is not prepared to order that those persons
personally comply, they should be ordered to take all necessary steps to ensure
compliance.
[8] In the alternative, the union submitted that if the Board denies all of the foregoing orders,
it ought at the very least order that the individuals identified as responsible for not
complying with the Board orders appear before the Board to testify and explain the
failure to comply. The union submitted that once that is done, the union would be
seeking from the Board contempt orders against those individuals.
[9] Employer submissions
The employer opposes the requested orders on three separate grounds. First, it is
submitted that the Board has no jurisdiction to grant the requested orders. Second, the
employer takes the position that the union’s motion for the orders before the Board is an
abuse of process. Third, the employer asserts that in any event, the crown or any of its
officers cannot be held in contempt either by the Board or by the Superior Court of
Justice.
[10] The Board has no jurisdiction to grant the orders sought
The employer made a threefold argument in support of its position that the Board lacked
jurisdiction to grant the requested orders:
(a) The Board does not have enforcement powers.
(b) The Board cannot make an order against particular individuals.
(c) The Board has already decided the matter and is now functus officio.
[11] (a) The Board does not have enforcement powers
Employer counsel submitted that from the documents before the Board and the union’s
opening statement, it was clear that the union is embarking on a two-step process. First,
it intends to obtain compliance orders against particular individual officers of the crown.
Second, if those individuals do not comply with the Board orders, the union intends to
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seek contempt orders from the Board against those individuals. Reference was made to
correspondence dated April 24, 2013 from union counsel to employer counsel, wherein
it is stated inter alia, that “OPSEU will be seeking an order from the GSB against the
individuals responsible for the failure to implement this decision, and will be bringing a
contempt motion before the GSB against these individuals once such an order has been
issued”. Thus, these orders are sought with the ultimate goal of having the Board
enforce the orders it issued on March 1, 2013. It was submitted that the Board did not
have such enforcement powers.
[12] Counsel referred to s. 48(19) of the Labour Relations Act which reads:
Enforcement of arbitration decisions
(19) Where a party, employer, trade union or employee has failed to comply with
any of the terms of the decision of an arbitrator or arbitration board, any party,
employer, trade union or employee affected by the decision may file in the Superior
Court of Justice a copy of the decision, exclusive of the reasons therefor, in the
prescribed form, whereupon the decision shall be entered in the same way as a
judgment or order of that court and is enforceable as such.
It was submitted that the Act has explicitly provided for a mechanism to enforce Board
orders where there is non-compliance. It was pointed out that the union has in fact
resorted to that mechanism by registering the Board orders in the Superior Court, which
therefore are now enforceable as a judgement or order of the court pursuant to s. 48(19).
Counsel referred to the union’s request in the alternative that the Board order individuals
to appear before the Board to explain why the Board orders have not been complied with.
That demonstrates clearly that the union is attempting to have the Board force
compliance of its own orders.
[13] The Board’s attention was drawn to Re Marsh Engineering Ltd. [2000] 89 L.A.C. (4th) 80
(Sarra), at para. 17, where the arbitrator wrote:
17 Where a party fails to comply with any terms of the decision of an arbitrator, any
party, employer, trade union or employee affected by the decision may file in the
Ontario Superior Court of Justice a copy of the decision in the prescribed form
pursuant to section 48(19) of the Labour Relations Act, 1995, supra. The decision is
enforceable as an order of the Court (section 48(19), Labour Relations Act, 1995,
supra). While an arbitrator makes determinations of liability, she or he has no
enforcement powers. Decisions must be enforced through the civil courts.
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[14] The employer also relied on the decision of the Ontario Labour Relations Board in Re
Residential Low Rise Forming Contractors Assn. of Metropolitan Toronto and Vicinity,
[2012] O.L.R.D. No. 4070. There the applicant alleged that the respondent clearly was
non-compliant with an order of the Board and argued that “the Board could simply
enforce its June 27, 2012 decision” (Para. 29). The respondent took the position “… that
the Board could not enforce its own orders. Board orders must be enforced through the
Courts” (para. 30). In agreeing with the respondent that “the Board does not have the
authority to enforce its own decisions and orders”, at para. 32 the Board referred to s.
96(6) of the Labour Relations Act, “which states that the Board determination may be
filed with the court and enforceable as a court order. There is also no specific power
vested in the Board and contained in the Act to enforce its orders”. Employer counsel
submitted that there is no provision in either the Labour Relations Act or the Crown
Employees Collective Bargaining Act that bestows upon the Grievance Settlement Board
the power to enforce its orders. On the contrary, the governing legislation explicitly
provides that enforcement of Board orders must be through the courts.
[15] The employer relied further on the decision of the B.C. Labour Relations Board in Re
Haebler Construction Ltd., (1993) 21 C.L.R.B.R. 81. The factual background to the
dispute is set out at p. 81 as follows:
The Council issued an Order on December 7, 1992, following a determination that
the Employer has committed an unfair labour practice by dismissing Colin Smith:
Haebler Construction Ltd., IRC No. C203/92 (affirmed on reconsideration BCLRB
No. B31193). Under the terms of that Order, the Employer was to cease and desist
its contravention of the Industrial Relations Act, and to immediately reinstate Smith
“to his former position and continue to provide him work on the same basis that it has
in the past” (p. 17). The Employer was also ordered to pay Smith for all wages and
benefits lost between the time of layoff and the date of his reinstatement. On
December 7, 1992, at the Union’s request, a copy of the Order was filed in the
Supreme Court registry pursuant to Section 30 of the Industrial Relations Act. The
Employer reinstated Smith on December 11, 1992. On December 23, 1992, the
Employer again laid him off. Smith has not worked for the Employer between
December 23, 1991, and the date of this application.
The union sought a hearing before the Board to call evidence relating to losses sustained
by Smith and to make argument with respect to the remedies sought. The employer
opposed the union’s request on several grounds including the following:
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The Board, by virtue of Section 135(2) of the Code, loses jurisdiction over Orders once
they are filed in the Supreme Court registry. If the Union feels that the Employer has not
complied with the Order, the Union must seek a remedy by way of enforcement in the
courts. It is not a proper application of Section 143 to use it to declare that a previous
order has not been complied with.
The Board rejected the employer’s position that the Board loses jurisdiction over its
orders for all purposes once they are filed in the court, under s. 135(1) of the Code. It
held that the Board retains jurisdiction over an application under s. 143 to reconsider,
vary or clarify an order that had been registered in the court. However, the Board went
on to make the following finding:
In this case, however, the Union is not seeking reconsideration, variation or
clarification of the original Order. Instead, it argues that the Employer breached the
terms of the original Order and as a remedy asks the Board to issue further Orders. The
Union’s application is totally concerned with enforcement of the original Order. The
Board has no independent authority or means to enforce its own orders. Traditionally, it
has relied on the enforcement powers and procedures available to the Courts: Cominco
Ltd., BCLRB No. 283/83, (1984), 4 CLRBR (NS) 45; Citation Industries Ltd., IRC No.
C206/88, (1989), 19 CLRBR (NS) 262; Citation Industries Ltd. v United Brotherhood of
Carpenters and Joiners of America, Local 1928, et al, supra. The Union appears to have
recognized this because it initially requested that the Order granted in IRC No. C203/92
be filed under the former Section 30 (now Section 135).
I agree with the Employer’s submission that where a party asserts that an order of
the Board, filed in Court, has not been complied with, it is not a proper use of Section
143 to seek a declaration to effect enforcement. This is precisely the function that the
Legislature has bestowed upon the Court. Thus, the proper forum to decide whether the
Employer has complied with the Order and to ensure its enforcement is the Court.
Neither is it proper use of Section 143 to seek new orders on matters which have already
been decided. In its application, the Union alleges that Smith was laid off when work
was still available for him to perform. The implication of this allegation is that Smith
may been improperly terminated. If the Union believed that to be the case, and if it could
prove a new violation of the Code, it should have filed a new application under the
appropriate unfair labour practice provisions of the Code.
In summary, I conclude that, while the board does not lose jurisdiction simply
because its Order has been filed in the Supreme Court registry it does not have
jurisdiction to ensure enforcement of its Orders. Therefore, the Union’s application is
dismissed.
[16] Also cited was the award of arbitrator Shime in Re Dana Corp. [2005] 143 L.A.C. (4th)
251. In that case there was disagreement as to whether the issues to be determined were
properly before arbitrator Shime or whether arbitrator Burkett, who had previously issued
two awards, which inter alia, had imposed certain conditions on the grievor, was seized
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of those issues. At para. 8 arbitrator Shime set out a number of principles derived from
the case law which included the following:
(4) And finally, an arbitration board does not have the authority to enforce its award
and should be cautious not to enforce its award under the guise of implementing
conditions. Consumer’s Gas Co. and International Chemical Workers’ Union,
Local 161 supra.
Counsel submitted that the caution expressed in that principle is clearly applicable here,
in that the union was seeking the enforcement of the Board orders in the guise of an
exercise of jurisdiction retained for purposes of determining disputes as to
implementation.
[17] (b) The Board has no power to make orders against particular individuals
The employer submitted that the Board derives its remedial powers from s. 48(12) of the
Labour Relations Act and that the orders sought by the union in this proceeding do not
fall within its scope. Reliance was placed on s. 48(18) of the Act which provides:
(18) The decision of an arbitrator or of an arbitration board is binding,
(a) upon the parties;
(b) in the case of a collective agreement between a trade union and an employers’
organization, upon the employers covered by the agreement who are affected by the
decision;
(c) in the case of a collective agreement between a council of trade unions and an employer
or an employers’ organization, upon the members of affiliates of the council and the
employer or the employers covered by the agreement, as the case may be, who are
affected by the decision; and
(d) upon the employees covered by the agreement who are affected by the decision, and the
parties, employers, trade unions and employees shall do or abstain from doing anything
required of them by the decision.
It was submitted that any decision or order of the Board, therefore, could only be binding
on the employer, the trade union and the employees covered by the collective agreement
who are affected by the decision. Since individual members of management are not the
“employer” nor “employees covered by the collective agreement”, the Board has no
power to make binding orders against them in their individual capacity.
[18] Reference was also made to s. 56 of the Labour Relations Act, which provides:
56. A collective agreement is, subject to and for the purposes of this Act, binding upon
the employer and upon the trade union that is a party to the agreement whether or not the
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trade union is certified and upon the employees in the bargaining unit defined in the
agreement.
Counsel submitted that it follows that the only parties to the collective agreement are the
employer, the trade union and individual employees who are members of the bargaining
unit defined in the agreement. While the employer may be held responsible for actions of
individual managers, managers are not bound in their individual capacity by a collective
agreement and cannot be held to be in violation of the collective agreement. If the
legislature intended to make arbitration decisions and orders binding on individual
managers it could and would have included individual managers in s. 48(18) and s. 56. It
has chosen not to do so. Reliance was placed on London Life Insurance Co. v. Dubrevil
Brothers Employees Assn., [2000] 190 D.L.R. (4th) 428, (Ont. C.A.), Re Blake et al,
1987-1276 (Shime); Re Hunt 2001-0534 (Abramsky).
[19] (c) The Board has already decided the matter and is now functus officio
Employer counsel acknowledged that at para. 37 of its decision dated March 1, 2013, the
Board remained seized with jurisdiction “with regard to any disagreement between the
parties as to the implementation of the orders made herein”. The “orders made herein”
were an order that the employer forthwith cease its violation of the collective agreement
by failing to apply the collective agreement to court reporters and an order that the
employer forthwith apply the collective agreement to court reporters performing
bargaining unit work of production of transcripts and not treat them as independent
contractors. Counsel submitted that the additional orders the union was seeking in this
proceeding do not arise from any disagreement between the parties as to what the Board
ordered in its March 2013 decision. The Board’s orders are specific and clear. The
union is not seeking an interpretation from the Board as to what the orders mean.
Rather, it was seeking new and additional orders,
[20] Counsel submitted that in the original proceeding the union had argued that the only way
the violation could be brought to an end is through a direct order to cease and desist the
violation and to comply with the collective agreement”. (Decision of March 1, 2013,
para. 16). The employer opposed the issuance of those orders. However, the Board
determined that the orders sought were within its jurisdiction and proceeded to issue the
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exact orders sought by the union. Now the union was seeking additional orders. Counsel
submitted that if the Board grants those orders, that would be a clear case of enforcing its
original orders in the guise of implementation, which would be contrary to the principle
expressed in Re Dana Corp., (Supra at para. 16)
[21] Employer counsel submitted that the present motion is about forcing the employer to
comply with the orders previously sought and issued. The motion would require the
Board to hear new facts about events that post-date the issuance of its original orders.
This is clear since the union has explicitly requested an order that employer
representatives appear before the Board to testify as to why the Board orders have not
been complied with. Counsel referred to another principle set out by arbitrator Shime in
Re Dana Corp. (supra) to the effect:
An arbitration board may complete an award but must be careful that it does not
adjudicate new facts or new issues or substantive events that occur subsequent to the
award. Re Lake Ontario Steel Co. And United Steelworkers, Local 6571 (1992) 24
L.A.C. (4th) 355 (L. Mikus), Re Overwaitea Ltd. And Retail Clerks Union, Local 1518
(1980) 25 L.A.C. (2d) 289 (A.M. Somjen).
Reference was also made to a further principle set out by arbitrator Shime to the effect
that an arbitrator,
Should be cautious, when remaining seized, not to arrogate to itself under the guise of
implementing conditions, the right to decide about subsequent new facts and new issues
of a substantive nature that should properly be the subject matter of a further grievance
and a further independent arbitration.
[22] Counsel submitted that it was open to the union at the original arbitration to seek
whatever orders as it deemed necessary. It chose to seek certain orders and they were
granted. The Board’s orders were final and binding. The Board is now subject to the
doctrine of functus officio and cannot issue any further orders. It has no power to
reconsider the remedy it has granted and to make new and additional remedial orders.
[23] Union Submissions
Union counsel submitted that the employer’s submission, when “all the dots are
connected”, is to the effect that the employer does not have to comply with Board orders
and that “the Board has no power to order the employer to do anything”. Counsel
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submitted that if that is accepted, it would rip apart the fundamental and basic right of the
parties to a final and binding decision from the Board.
[24] Counsel pointed out that while the employer submits that Board orders may only be
enforced through the courts, it also has made it clear that before the court it would be
taking the position that the crown and its officers enjoy immunity against contempt
orders. If that position is correct, this means that all of the arbitration proceedings before
the Board would be meaningless, because the employer would be free to choose which
orders of the Board it would comply with. If the employer decides not to comply with a
Board order there would be nothing the union can do.
[25] Counsel submitted that it is very clear that the employer has not complied with the
explicit Board order that it shall not treat court reporters performing the work of
producing transcripts as independent contractors. It was submitted that despite the Board
order, the employer has continued to post vacancies, for court reporter positions, which
includes an explicit stipulation that “transcripts are prepared on incumbents’ own time
with own equipment within prescribed timelines, and will receive a prescribed fee”. A
posting with a closing date of November 6, 2013, containing that provision was filed in
evidence as an example.
[26] Union counsel referred to the retention of the Board’s jurisdiction in its decision.
Counsel pointed out that the employer was in effect stating that it does not have to
comply with the Board orders. The union has taken the position that the employer is
obliged to comply. This, submits counsel, is a fundamental disagreement between the
parties about the implementation of the Board orders. The Board has retained jurisdiction
in that regard and is not functus.
[27] Union counsel stated that at this time it was premature to seek contempt orders against
any individuals because to date the Board has not made any orders directed at
individuals. The union made it clear that it was not pursuing any contempt orders in the
instant proceeding and that it was not necessary for the Board at this time to decide
whether or not it had authority to make such orders. Counsel argued that the union has
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been forced to seek additional orders against individuals because that was the only means
available for it to obtain a final and binding settlement to its grievance. Reference was
made to s. 7(3) of the Crown Employees Collective Bargaining Act, which provides:
Every collective agreement relating to Crown employees shall be deemed to provide for
the final and binding settlement by arbitration by the Grievance Settlement Board,
without stoppage of work, of all differences between the parties arising from the
interpretation, application, administration or alleged violation of the agreement, including
any question as to whether a matter is arbitrable.
It was submitted that the additional orders the union seeks against individuals responsible
for the non-compliance are necessary to meet that statutory requirement of “a final and
binding settlement by arbitration by the Grievance Settlement Board”. Counsel argued
that due to the employer’s non-compliance, the union has been denied finality to its
grievance, and section 7(3) gives the Board the power to provide that finality.
[28] The union referred the Board to its decision in Re Brosseau et al and Union, 2010-1600
etc. (Gray). At para. 13 of that decision, the Board ordered as follows:
[13] I hereby confirm the directions I gave orally on November 8, 2011 that
(a) David Logan, Assistant Deputy Minister, Ministry of Government Services,
is directed to ensure compliance by the Crown with the provisions of the order
of June 16, 2011 herein by no later than the close of business on Monday,
November 28, 2011; and
(b) Unless the parties agree or the Board hereafter orders otherwise, Mr. Logan
is directed to attend the hearing in this matter on December 20, 2011, and to
bring with him and produce at that time any documents of the sorts described in
paragraph 7 of the order of June 16, 2011 in this matter that have not been
produced to union counsel before that date, and to show cause why he should not
be punished for any failure to take all necessary steps to timely comply with the
aforesaid order.
It was submitted that the foregoing order is authority for the proposition that the Board
has the power to make orders against individual members of management and that such
individuals may be ordered to appear before the Board to explain the reasons for non-
compliance.
[29] Counsel referred to the statement of the Board at para.26 of its decision dated March 1,
2013 to the effect:
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The Board sees no merit in the employer’s argument that the union is not entitled to seek
the orders in this grievance because it failed to seek them as part of the remedy in Re
Hunt. When the Board makes a declaration that certain conduct is in contravention of the
collective agreement, the Board as well as the grieving party is entitled to reasonably
expect that the offending party would cease that conduct and comply with the collective
agreement. The union is not obligated to seek explicit orders to comply, in anticipation
that the employer may not comply.
Counsel submitted that similarly, when it sought a cease and desist order and an order
that the employer apply the collective agreement to the work in question, the union was
entitled to reasonably expect that when the Board grants those orders the employer would
comply. At the time the union could not have reasonably anticipated a need for any
orders against individuals. Therefore, it is reasonable for the union to seek further orders
so that it may obtain a final and binding settlement to its grievance.
[30] Reply of the employer
Counsel submitted that the Board’s decision in this proceeding must be based on whether
or not it has legal authority to grant the orders the union seeks, and not based on its view
as to what is fair or reasonable. He disagreed with the union’s assertion that if the Board
denies the orders sought, the union has no recourse and the employer would be free to
pick and choose what Board orders to comply with. It is not true that if the employer
fails to comply with a Board order “there will be nothing the union can do”. To the
contrary, the legislation has explicitly provided a forum where the union can seek
enforcement of the Board orders. In fact the union has resorted to that enforcement
mechanism and a hearing is scheduled before the Superior Court of Justice. The union
has accessed the appropriate forum and should proceed with it. The court’s endorsement
explicitly says that at that hearing the court would be determining two issues. First,
whether the employer had violated the orders of the Board, and second, whether the
crown has immunity from contempt orders. The court would receive submissions from
both parties and rule on those disputed issues. It was submitted that the union was not
entitled to circumvent that statutorily mandated enforcement procedure and engage in
“forum shopping”.
[31] Counsel denied that it was the employer’s contention that the Board has “no power to
order the employer to do anything”. To the contrary, the Board has that power, and
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exercised it when it ordered that the employer cease violating the collective agreement,
and that the employer apply the collective agreement to the disputed work. Thus the
Board has rendered, and the union has obtained a final and binding decision. What the
union is attempting to do here is to have the Board enforce those orders. The union was
not denied finality because the Board has made clear and specific orders as to what the
employer is required to do. To enforce compliance with those Board’s final and binding
orders, the union must resort to the courts as provided by statute.
[32] Employer counsel distinguished the authorities relied upon by the union, Alberta Union
of provincial Employees v. Lethbridge Community College, [2004] 1 S.C.R. 727
(S.C.C.); Re Carol Berry [1986] 36 A.C.W.S. (2n) 504 (nt. Div. Ct.0; Re Anderson et al,
[1990] 75 O.R. (2d) 212 (Ont. Div. Ct.); Re Howe/Dalton/Loach [1994] 42 L.A.C. (4th)
342 (Dissanayake). In each of those cases, the issue was whether the arbitrator had the
power to make certain orders. Following the principle that “where there is a violation
there must be a remedy”, the orders sought by the union were granted. Counsel pointed
out that that was exactly what the Board did in this case also. None of those cases assist
the union because they were about the arbitrator’s authority to make remedial orders, and
not about enforcing orders already made.
[33] Employer counsel submitted that Re Brosseau, supra, is also clearly distinguishable. It
makes no findings and thus could not serve as a precedent. More importantly, there was
no objection to the Board’s jurisdiction to make orders against individuals, and it appears
that the orders were made on consent. There is no analysis or discussion in the decision
about the source of the Board’s jurisdiction to grant the orders. Counsel submitted that in
any event in Re Brosseau, the Board was dealing with a situation of in facie contempt.
The orders not complied with were interlocutory orders made during the course of the
proceeding. In contrast, here the orders of the Board were final and binding orders, and
the contempt alleged against the individuals is ex facie.
[34] In summary, employer counsel submitted that the Board has already rendered a final and
binding decision. The orders made are clear. There is no misunderstanding as to what
was ordered and no clarification is required. The union has in fact submitted that in its
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view the employer has failed to comply with the clear orders of the Board. Thus in
reality the orders sought by the union are about enforcement of the Board orders. The
union has accessed the appropriate forum for enforcement, the courts. It is open for the
union to make the arguments it made in this proceeding at the court proceeding. The
court, which has much broader remedial powers than the Board does, would receive
submissions from both parties and rule as it deems fit.
[35] DECISION
The employer’s first ground of objection to the motion is that the Board has no
jurisdiction to grant the orders requested. The employer’s jurisdictional grounds of
objection include submissions to the effect that the Board has no enforcement powers and
that the Board is functus officio. The Board turns to these objections.
[36] No enforcement powers
The union characterizes the additional orders sought as a necessary part of its entitlement
under s. 7(3) of the Crown Employees Collective Bargaining Act, to a final and binding
settlement of its grievance. The employer disagrees and takes the position that the Board
has already issued, and the union had obtained, final and binding orders, and that the
additional orders sought are an attempt by the union to have the Board enforce the orders
it had granted. The employer submits that the Board lacks such enforcement powers.
[37] Upon a review of the submissions, the case law reviewed herein and the applicable
statutory provisions, the Board agrees with the employer. In its decision dated March 1,
2013 the Board granted the exact remedies the union sought as redress for the employer’s
violation. The Board agrees with the union’s submission that it would have been
reasonable for the union, having received those orders, to expect that the employer would
comply and do what it had been ordered to do. However, if the employer does not do so
and fails to comply, that is not a result of the Board’s orders being not “final and
binding”. It is the result of the employer’s failure to comply with the Board’s final and
binding orders. The employer acknowledged, and indeed insisted, that the union had
received final and binding orders from the Board exactly as it had requested. That was a
substantial component of the employer’s submissions in objecting to the motion.
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Employer counsel did not assert that the employer had applied the collective agreement
to the disputed work as ordered. However, he did not concede that the employer had
thereby failed to comply with the Board orders. To the contrary, he relied on the fact that
the court, in its endorsement, had taken jurisdiction to determine whether or not the
employer had violated the Board orders as part of the union’s motion for contempt orders
scheduled before the court for March 17, 2014.
[38] All of the additional orders sought herein by the union are based on an assumption that
there has been non-compliance with the Board’s original orders. Although that appears
to be the case, the employer has not conceded non-compliance. On the contrary, whether
or not there was compliance is one of the issues the court would be determining as
indicated in its endorsement. In Re Haebler Construction Ltd, (supra) the B.C. Labour
Relations Board held that its statutory authority to reconsider, vary or clarify its decisions
did not provide jurisdiction, inter alia, “to decide whether the employer has complied
with the order”. In the Board’s view, this Board also has no jurisdiction to determine
whether or not its previous orders have been complied with. That is a power bestowed
upon the Superior Court of Justice under s. 48(19) of the Labour Relations Act and the
court has in its endorsement stated that it would be exercising that power.
[39] From the union’s submissions themselves, it is clear to the Board that the union is
seeking these orders as a means of enforcing the orders it had obtained in March 2013.
Had the union been satisfied that the employer had complied with those orders, it would
not have returned to the Board seeking these additional orders. Indeed, the thrust of the
union’s submissions was to the effect that the only way the union could enforce the
Board orders, was by obtaining these additional orders against individuals responsible for
non-compliance. While the union attempted to characterize the orders as necessary to
make the Board’s March 2013 orders “final and binding”, the Board is convinced that in
reality, the union is seeking the enforcement of those orders through the Board.
[40] The Board has reviewed in some detail the law relied upon by the employer in support of
the proposition that the Board lacks the authority to enforce its orders. That law is
consistent and clear. In the absence of a specific statutory grant of enforcement powers,
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an arbitrator has no such power. In the case of this Board the relevant statutory provision
is s. 48(19) of the Labour Relations Act. Under the title “Enforcement of arbitration
decisions” it spells out the process to be followed where there is a failure to comply with
a Board order. The union did not make any submissions as to why it is legally entitled to
seek enforcement through the Board in light of this explicit statutory provision.
[41] In light of the applicable statutory provisions, and the well established case law, the
Board concludes that it has no jurisdiction to enforce its orders. The governing statute
has explicitly addressed the issue of enforcement of Board orders. It sets out a process
for enforcement through the courts. The union has accessed that process and it is not
open to it to seek enforcement through the Board in the alternative.
[42] Functus Officio
The parties appear to be in agreement to the extent that the Board, having issued its
remedial orders dated March 1, 2013 is functus officio, except for the specific purposes
for which it retained jurisdiction in para. 37. It is the union’s contention that the
jurisdiction retained authorizes the Board to issue the additional orders it seeks.
[43] In the Board’s view, to do so would be to do exactly what arbitrator Shime cautioned
against in Re Dana Corp., (supra), that is to enforce Board orders in the guise of
implementation. It is significant that neither party to this motion has taken the position
that there is any disagreement as to the proper meaning and interpretation of the Board
orders dated March 1, 2013. To the contrary, the union argued repeatedly that the Board
orders are specific and clear as to what the employer is required to do. The employer did
not disagree. Therefore, there is no dispute as to implementation which would fall within
the jurisdiction the Board retained.
[44] In Re Haebler Construction Ltd., (supra) the B.C. Labour Relations Board, in denying the
orders sought by the union stated as follows: “In this case, however, the Union is not
seeking reconsideration, variation or clarification of the original order. Instead it argues
that the employer breached the terms of the original order and as a remedy asks the Board
to issue further orders. The union’s application is totally concerned with enforcement of
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the original order. The Board has no independent authority or means to enforce its own
orders”. That reasoning applies to the instant motion also. There the Board held that its
statutory power to reconsider its decisions did not empower it to enforce its decisions.
Similarly, here the jurisdiction retained does not, and cannot include the power to enforce
the Board orders. The Board has already concluded that the additional orders sought
herein are about enforcement of the Board’s prior orders, and that the Board does not
have such enforcement powers. Therefore, it necessarily follows that the Board cannot
retain for itself a power which it does not possess under the law in the first place.
Therefore, the retention of jurisdiction, however broadly it is interpreted, cannot include
the jurisdiction to enforce Board decisions.
[45] The Board appreciates and understands the union’s frustration which was vigorously and
passionately expressed by union counsel. The union had engaged in protracted litigation
with the employer and obtained the remedial orders it had sought. The union reasonably
expected that the employer would comply with the Board orders and that the violation
would cease. When it felt that there was no compliance, the union resorted to the
statutorily mandated enforcement procedure thorough the Superior Courts. Now it faces
a legal argument from the employer that the Crown as the employer and its officers enjoy
legal immunity against contempt orders from the court. The union is concerned that if
the court upholds that argument, it may be left with no means of enforcing the Board
orders. As counsel put it “the union will be left holding a Board order which is of no
value”. The union believes that in that eventuality the whole process of arbitration before
the Grievance Settlement Board would become meaningless because the employer would
be free to act with impunity and decide what Board orders it would comply with and
disregard other Board orders it does not agree with, and there would “nothing the union
can do”.
[46] The Board observes that while all of the foregoing are reasonable concerns on the part of
the union, they are premised on speculation as to how the courts may or may not rule
upon the legal arguments that will be made on the issue of enforcement of Board orders
and how the employer may or may not act in the event the court does not take jurisdiction
to enforce those orders. The Board only observes that the Superior Court of Justice has
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much broader powers, including equitable powers, than arbitration boards do. It is not at
all clear that the court’s remedial and enforcement powers are confined to contempt
orders. Both parties to the motion before the courts will undoubtedly make submissions
to the court on the issue of enforcement of Board orders and the court would make
rulings as it deems fit.
[47] Assuming, however, that the worst case scenario envisaged by the union in fact
materializes, and it is left with no means of enforcing the orders it had obtained from the
Board, does that make any difference in the scope of the Board jurisdiction? The answer
has to be in the negative. The Board is a creature of statute and possesses only such
powers as vested upon it by law. The Board must act within its jurisdiction. Even
though it may be tempting to intervene and provide justice and equity, the Board cannot
assume such equitable jurisdiction which is not legally conferred upon it.
[48] As a result of the foregoing findings that the Board upholds the employer’s position that
it lacks jurisdiction to grant the additional orders the union seeks because these orders are
an attempt to enforce Board orders, and the Board lacks enforcement powers. The
retention of jurisdiction by the Board does not empower the Board to grant the orders
sought.
[49] In light of the foregoing conclusion, it is unnecessary for the Board to deal with the
employer’s submission that the Board has no jurisdiction to make orders against
individuals. Nor is it necessary to determine the employer submissions to the effect that
the instant motion by the union is an abuse of process because the issue of enforcement of
the Board orders is properly before the court, and the argument that the crown and its
officers cannot be found in contempt by the Board or the Superior Court of Justice.
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[50] The orders sought by the union in this motion are therefore denied.
Dated at Toronto, Ontario this 20th day of November 2013.
Nimal Dissanayake, Vice-Chair