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HomeMy WebLinkAboutHorodnyk 14-10-10 IN THE MATTER OF AN ARBITRATION ~ BETWEEN ~ CENTENNIAL COLLEGE (“EMPLOYER or COLLEGE”) ~ AND ~ ONTARIO PUBLIC SERVICE EMPLOYEES UNION, LOCAL 562 (“UNION”) AND IN THE MATTER OF AN INDIVIDUAL GRIEVANCE (BEVERLY HORODNYK) Board of Arbitration Deborah Leighton, Chair Ann Burke, College Nominee Sherril Murray, Union Nominee APPEARANCES For the Employer Jason Green Nancy Fisher Paul Schwartzman For the Union Sheila Riddell Lesley Gilchrist Deborah Warren Phil Cunnington Hearings were held on this matter in Toronto on: October 12 and December 7, 2011, January 12, 27, March 30, September 6, 21, 28, October 5, 26, November 30, 2012, January 11, February 7, May 10, June 20, September 12, October 4, 11, 18, and December 3, 2013. 2 AWARD Introduction [1] Ms. Beverley Horodnyk, a retired police officer, began teaching for the college in the Police Foundations Program, (PFP), in September of 2009. Ms. Horodnyk worked as a partial load professor from 2009 to 2010. The grievor applied for a full-time position as a professor in the PFP on July 7, 2010. She was successful in the initial phone interview and proceeded to the final interview of the recruitment process. She was not successful in getting the full-time position. Ms. Horodnyk grieved on August 25, 2010 that the “College has violated Articles 4, 6 and the Letter of Understanding, “Employment Equity” of the collective agreement” by not hiring her for a full-time faculty position.” She gave the grievance to the college on September 1, 2010. [2] At the outset of the hearing into this matter, the employer objected to the board’s jurisdiction to hear the case because Ms. Horodnyk was not an employee of the college at the time of this job competition and therefore had no right to grieve. The grievor also filed a human rights complaint regarding the same facts as alleged in the grievance. The preliminary matter on the jurisdictional issue was not argued to the board. The parties entered into negotiations that led to Minutes of Settlement (MOS), which amongst other things provided the board with jurisdiction to proceed with hearing the grievance. Ms. Horodnyk acknowledges that the Board of Arbitration presiding over the Grievance is authorized to and shall consider any and all human rights complaints, concerns or issues arising out of her Grievance against the College and shall exercise such remedial powers as are set out in Article 32.03D of the Collective Agreement and that, as a result, this Memorandum of Settlement constitutes a full and final settlement of the Application in File No. 2010- 07568-I and any planned or possible complaint or complaints against the 3 College or the individuals (names omitted) under the Human Rights Code arising out of or in respect of said employment. [3] Pursuant to the agreement, Ms. Horodnyk withdrew her human rights complaint and the board heard the grievance on its merits. The MOS also provided that Ms. Horodnyk’s partial load employment ended on April 30, 2010, but for the purposes of the grievance Ms. Horodnyk was deemed to be an employee on September 1, 2010. She was not offered a new partial load contract in September 2010. The parties to this memorandum are agreed, for the exclusive purpose of Ms. Horodnyk’s grievance dated September 1, 2010, that she will be deemed to be an “employee” on September 1, 2010 and therefore entitled to file the Grievance presently before the Board of Arbitration chaired by Deborah Leighton. There was also an express provision that Ms. Horodnyk did not become entitled to any rights under the collective agreement, and recognition that she was not an internal candidate for the job posting. [4] It is the union’s position that the college discriminated against the grievor when it denied her the full-time faculty position in the PFP. It retaliated against her when she raised concerns about the lack of female representation in the department contrary to the collective agreement and the Ontario Human Rights Code, R.S.O. 1990, chapter H.19, as amended (Code). The union alleges that the Department Head manipulated the hiring process of the incumbent because she had a personal interest in him. [5] The college took the position it was fully within its rights to choose the best candidate for the position. The college also denied that it breached any of the grievor’s human rights or the collective agreement with regard to its decision to hire the incumbent. Counsel for the college 4 took great exception to the allegations that the Department Head was motivated to hire the incumbent for personal reasons. [6] After approximately seventeen days of hearings, the union closed its case. The employer then sought to non-suit the union and elected not to call evidence. The college submitted that the non-suit motion is based on an assessment of the credibility of the grievor’s evidence. It argued that there is no evidence for a prima facie case that there was a breach of the Code on discrimination or reprisal. [7] During the submissions on the non-suit motion, the union conceded that there was no evidence to support the allegation that the Department Head had a personal interest in the incumbent. The union also conceded that, although Ms. Horodnyk believed that the full-time position was an equity hire, it was not. Given the nature of the allegations against the Department Head and the incumbent, for which there was no evidence, we have not included their names in the decision. The Evidence [8] Much of the evidence in this case is contested. We have reviewed it all carefully. Given the nature of the submissions on the evidence, what follows is a brief summary of the union’s evidence. Further references to the evidence will occur in both the counsels’ submissions and in our decision. [9] Ms. Horodnyk testified in examination-in-chief that the Department Head had been pursuing funding for an additional full-time position since approximately the spring of 2009. The 5 grievor thought that the Department Head had determined by late 2009 that the incumbent should have the position. [10] The Department Head made the incumbent a partial load professor in December 2009, which in the grievor’s opinion was in order to make him eligible to apply for the full-time position. The Department Head assigned the incumbent nine hours of teaching in one day. The grievor said this was unusual. Two professors in PFP, Ken Yates and Harry D’Arcy testified they had never seen the assignment of nine hours in one day. On cross-examination, the grievor said that she had never asked for nine hours of teaching in one day. [11] Ms. Horodnyk testified that the Department Head knew in February or March of 2010 that the full-time position was to start in September 2010. When the funding for the position was approved, the Department Head posted the job internally. It was Ms. Horodnyk’s view that this was in order to reduce the numbers of applications for the positions. This ensured that the incumbent had very little competition for the position. The Department Head also discouraged other partial load professors from applying for the job. She told one male professor not to apply, if he did not have a degree. The Department Head allowed the incumbent to apply as an internal applicant even though per the collective agreement he was no longer eligible to apply for an internal posting. In cross-examination, Ms. Horodnyk acknowledged that she had the same status as the incumbent, since she also was a partial load professor. Her contract ended in April. [12] In Ms. Horodnyk’s view, the college geared the job posting to the incumbent’s experience and education. The initial posting did not list women as an equity group being 6 encouraged to apply for the position, even though women are in her view chronically underrepresented in the program. The grievor said she was troubled that women were not listed in the equity group encouraged to apply for the position. The grievor raised concerns about the posting and it took several emails and calls to various levels of the college before women were added as an acknowledged equity group welcome to apply. A series of emails ensued between the grievor and the Department Head. We will address details on this evidence later in the decision. [13] The grievor was of the view that, because of raising the equity issue, by the time she had her interview both the Department Head and Professor Joe Perino, one of the interview panelists, were angry with her. There was one other person on the panel from Human Resources, Ms. Portia Vidal. The grievor said that she did not get a fair interview. She testified that both the Department Head and Professor Perino were aggressive, and the manner of their questions put the grievor on the defensive. It was also her view that they did not give her appropriate scores to answers she provided and in effect retaliated against her for raising human rights issues. She also said that she was not well prepared for the interview and it went very badly. When the grievor was told that she did not get the position, she raised concerns about the college not considering employment equity in the hiring process. She thought that being reduced to part-time was a reprisal for raising employment equity. [14] We know from the grievor’s evidence and the documents that the Dean Sandra Murphy investigated Ms. Horodnyk’s complaints. After reviewing the documents and speaking to those who were part of the recruitment process, the Dean decided the grievor’s complaints were not 7 founded. She advised Ms. Horodnyk of this at a meeting on September 1, 2010 initially scheduled to provide the grievor feedback on her interview. The Dean asked why Ms. Horodnyk had contacted the Maytree Foundation, an organization outside of the college, about her complaints. Someone at Maytree sent Ms. Horodnyk’s email on to the college. Ms Horodnyk testified in cross-examination that she had never intended anyone in the college to see her email to Maytree complaining about the college. She testified that she felt ambushed by the Dean and the Department Head at this meeting. It was also her evidence that at the end of the meeting she “served” her grievance on the college. [15] Instead of allowing the grievor to file a formal complaint, which she believed she had a right to do, the college terminated her employment the next day, even though she had been scheduled to teach two fall courses and had received her timetable and class lists. Employer’s Introductory Submission on the Non-suit Motion [16] Counsel for the college emphasized that no reasonable person would support discrimination in the workplace. He submitted that when those allegations are made the college takes them seriously and when proven, they lead to serious consequences. It also follows from that principle that it is imperative that allegations of human rights violations be credible and reliable. In this case he argued that the allegations were made against real people, professionals trying to do their best work every day. Given the seriousness of the allegations before the board, counsel argued that we must carefully deliberate on the credibility of Ms. Horodnyk’s allegations. 8 [17] Counsel argued that the college was permitted to choose whomever they thought was the best candidate for the job. He urged us to find that in assessing whether there has been discrimination under the Code, we could conclude that the incumbent meets and exceeds the qualifications for the position. He argued that it is not clear on the face of the grievor’s resume that she meets the minimum criteria. However, counsel emphasized that there was no need to decide who the better candidate was: it was enough to conclude that it was reasonable for the college to choose the incumbent over the grievor. [18] Counsel submitted that the relevant qualifications in the job posting for the purposes of this arbitration are proof of an undergraduate degree or equivalent and at least five years of administrative experience in policing. There were two applications for the position: the incumbent and Ms. Horodnyk. The incumbent was the successful applicant. Counsel for the college emphasized that this was not a case about whether the grievor was a superior or inferior candidate to the incumbent. Instead the central issues before us are as follows: 1. Was the grievor denied a full-time position because she is a woman? 2. Should the grievor have been given the position because she is a woman? 3. Is there any evidence that the grievor suffered reprisal from the college for asserting her right to employment equity and the benefits that flow from that? Counsel submitted that on each of these issues there is no evidence to support a prima facie case. [19] Counsel observed that Professor D’Arcy said that the incumbent was fully qualified and worthy of the position. Thus it is the union’s evidence that the incumbent could have been 9 chosen by the college. He argued that this undermines the union’s premise that there was anything untoward about the job competition. [20] Counsel argued that the above is the starting point of the analysis of the central issues before us, that is, whether there is any evidence upon which it can be said that the union has made a prima facie case of discrimination and reprisal against Ms. Horodnyk. He reviewed the relevant law on non-suit motions and the standard for a prima facie case in human rights jurisprudence by the tribunal. We will address the legal argument in the analysis of our decision later. The Employer’s Submission on the Grievor’s Credibility [21] In counsel’s submission Ms. Horodnyk has not been credible, honest or reliable in her evidence. Counsel points to five examples where the grievor was not credible in her evidence. The first concerns her evidence as to her credentials and the number of courses that she completed at the University of Toronto. In her evidence examination-in-chief Ms. Horodnyk testified that she had taken six courses in the criminology program at the University of Toronto. This was important evidence to the union’s case because the job posting for the full time position required either an undergraduate degree or equivalent. In cross-examination, Ms. Horodnyk testified that she had made an error in her earlier evidence and that she had completed five courses. When presented with her transcript from the University of Toronto for this program it became clear that she had finished four courses. A fifth course indicated on the transcript showed a failure. The grievor testified that she had not realized that she had failed that course. Counsel 10 argued that this evidence showed that the grievor is prepared to say anything under oath to make out her case. [22] Counsel argued that Ms. Horodnyk had misrepresented her evidence to the board on other occasions as well. The second involves the exchange with Professor Perino. In an email exchange with him, the grievor indicated that she had the equivalent of an undergraduate university degree and that her credentials had been assessed by a university. [23] On cross-examination when pressed to reveal the identity of this university, she admitted that the evaluation of her credentials was done pursuant to a job process for a position at Ontario Power Generating (OPG). Counsel for the college argued that that the original statement to Professor Perino was patently false. Both of these examples, in counsel’s submission, are important because Ms. Horodnyk made the statements in pursuit of the full-time position and in her evidence before the board. In her email copied to senior staff, including the president of the college, she stated, “A University has assessed all of my hands on experience, University and College Courses as equivalent to an undergraduate degree.” Counsel urged the board to consider the above when assessing the grievor’s allegations of discrimination or reprisal. [24] The third example of why the grievor’s evidence is not credible involves her testimony around teaching the diversity course she was hired for in 2009. In her evidence in examination- in-chief, Ms. Horodnyk said that when she was notified that she was going to teach the course she began to research and prepare by locating a textbook and reading it cover to cover. She said she researched the topic at the Pickering, University of Toronto and Centennial College libraries. 11 She further stated that she put the course outline together for the students. In July of that year, she proceeded to prepare lesson plans, which she worked on and polished until September. She noted in her evidence that each lesson plan had a learning objective for each class. She wrote the tests, midterms and final examinations. She noted that she “spent way more time than I should have in terms of preparation. I felt that for the first time teaching that course I did it to the best of my ability.” [25] In cross-examination she was presented with materials related to the course on diversity, provided to her by the Department Head. She was taken through the course outlines and tests and examinations that were provided to her and asked to compare them to the ones that she used in the course in 2009. It became clear in cross-examination that she had done almost nothing to create the materials for the class. There were very few changes to the materials given to her. The dates had been changed, but little else. [26] Counsel for the college argued even if we find that she was not dishonest here, there is ample evidence that her evidence was not accurate either in terms of her perception or her memory of events. Thus, the rest of her evidence must be viewed with significant caution and skepticism. Counsel argued further that we cannot give weight to any of the grievor’s testimony unless it is supported by a document. [27] In a fourth example of why the grievor’s evidence is not reliable, counsel for the college submitted that the grievor will not only mislead with evidence but will also omit evidence where it suits her purpose. He noted that there was extensive evidence in examination-in-chief on Ms. 12 Horodnyk’s policing experience. She reviewed her employment history with the Toronto Police Service, Cobourg and Durham in great detail and gave evidence about the specifics associated with each job. On cross-examination she was asked about her work history with the police in Lindsay. This work history was not included on her resume and there was nothing in the documents put forward by the union that identified her work at Lindsay. [28] When she was confronted with omitting her work history from Lindsay she said “I did not know that you knew about that.” In counsel’s submission, this response was telling. He argued that it was omitted because it would not have reflected well on her. There is some evidence to suggest that she left following a motor vehicle accident in a police cruiser. In sum, counsel for the college argued that this example shows a pattern of how Ms. Horodnyk chooses to give her evidence and that she is prepared to tailor it to suit her aims. Thus, whether intentionally or otherwise, she is not a credible witness. [29] A fifth example for why Ms. Horodnyk should not be found to be credible is the grievor’s distorted perception of events. When Ms. Horodnyk saw the job posting for the full time position she noted that women had not been encouraged to apply for the position. Upon seeing this, Ms. Horodnyk contacted the Department Head to see if this had been done in error. A series of emails ensued. The first was from the Department Head with a typographical error that women were indeed included. It is clear from the context that the Department Head meant “not included.” The grievor responded that she was happy that the Department Head agreed with her that women should be listed with the equity groups encouraged to apply. The grievor stated further that she would contact Human Resources to point out the omission of women. The Department Head 13 responded to Ms. Horodnyk’s email and copied Ms. Vidal in Human Resources. Ms. Vidal responded the next day agreeing that it was a valid concern, that the posting would be revised to include women in the equity groups. The email was sent to the Department Head and the grievor was copied. [30] When the grievor was asked by counsel for the college what she thought of the response from Human Resources, Ms Horodnyk answered, “I was already very suspicious, I did not know why she was thanking the Department Head for something I had done.” She also testified that she was puzzled why Ms. Vidal had copied her. [31] Counsel for the college argued that it was not reasonable based on these emails to be suspicious of Department Head or Human Resources. He emphasized Ms. Horodnyk’s misperception in this particular case to argue that she also misperceived her treatment in the interview for the full-time position. Ms. Horodnyk testified in examination-in-chief that during the interview the Department Head maintained a mean look and kept her arms crossed. The grievor perceived the interview as intentional discrimination. In counsel’s view, the board cannot have faith in her perceptions to support a finding of a breach of the Code. [32] Counsel for the college argued further that we get tremendous insight into Ms. Horodnyk’s views given these email exchanges and her views of how to understand them. This can also be seen in her human rights complaint, wherein the grievor explains the Department Head’s “reprisal” by alleging that the Department Head was angered by the grievor going over her head to get the job posting amended to include women. The grievor says that the Department 14 Head ignored her complaint about the posting. Counsel notes that this was just not true: if one examines the email exchange, it is evident. [33] Thus, in counsel’s submission there is ample documentary evidence in front of us, even in the absence of responsive evidence from the college for us to have concerns about Ms. Horodnyk’s credibility with respect to the allegations that she suffered discrimination because she was a woman and was subjected to prohibited reprisal. He argued further that it is not necessary to find that she is dishonest, but she is not credible because her perception is not objective and her memory, not clear. [34] Counsel for the college also argued that the above examples should inform the board about Ms. Horodnyk’s perceptions of the interview for the full-time job and the final meeting on September 1, 2010. Counsel reviewed these examples to make the point that the union bears the burden of demonstrating a prima facie case and Ms. Horodnyk was the only witness to the events. Human rights jurisprudence indicates that a prima facie case is established if there is evidence “if believed” to support the allegation of a breach. Counsel urged the board to be very cautious about making any findings of fact in respect of critical issues in this case based only on the grievor’s testimony. We are not required to accept her evidence in support of her allegations. The Central Issues 1. Was the grievor denied a full-time position because she is a woman? [35] Counsel for the college submitted that there is no evidence for this allegation to succeed. In fact, Ms Horodnyk’s own evidence establishes that the allegation must fail. The grievor is 15 obliged to show two things. First, there has to be some evidence that gender was a factor in the college’s decision not to hire her. Second, the reason that the incumbent was hired was because, as the union alleged, the Department Head wanted the incumbent in the position of full-time faculty because of her personal relationship with him. [36] Counsel for the employer argued that the union in its opening statement undertook to prove this. They alleged that the Department Head had a fixation on the incumbent and this precluded the grievor being successful in the full-time competition. Counsel argued that these were bald assertions and there has been no evidence to support the allegations. Counsel reminded the board that he took umbrage with this position at the beginning of the case. It was his view that this was slander, only protected by a legal proceeding. However, he emphasized then, and he emphasized again in his submission on the non-suit, that the allegations affected real people. [37] Counsel underscored that the union counsel adopted the particulars, which provided in part and in summary: Ms. Horodnyk observed that the incumbent was promoted to a partial load position in December 2009 and began to fixate on the incumbent. The incumbent was given nine hours of teaching on one day in the week while he worked full time as a Toronto police officer. Ms. Horodnyk noticed the incumbent and the Department Head together at an end of the year barbecue and that they seemed to have arrived and left together. Counsel for the college argued that not one of the three union witnesses had the “guts” to allege an inappropriate personal relationship between the two. All three suggested that they saw them together at social functions and that they sat close. Counsel for the college noted that three witness saying this three different 16 ways does not make it truth, that there was no evidence of anything inappropriate between the two. He concluded that the allegations should not have been made. [38] The union took the position that the college tailored the posting for the full time faculty position for the incumbent to be the successful candidate. Counsel argued that it is not enough to say this. The union must show that the Department Head did something to tailor the job posting. In Ms. Horodnyk’s own evidence, she said that she asked about who had prepared the job posting and the Department Head replied to her in the September meeting that it was the Program Advisory Committee (PAC) who wrote it. She further stated that PAC wanted the university degree and administrative experience. The grievor also said that she asked the Department Head if she wrote any of the posting, and the Department Head was emphatic that she did not write any of it. [39] Counsel argued that we are left with four bald allegations about the extreme favouritism shown to the incumbent without evidence to support one of them. Counsel asked the grievor in cross-examination whether she had any other evidence of extreme favouritism of the incumbent. She said no. Thus, there is no evidence to support the allegation that Department Head favoured the incumbent over Ms. Horodnyk. Further even if there was evidence that Department Head wanted the incumbent in the job for personal reasons there is still no evidence that there was a breach of the Code for discrimination against Ms. Horodnyk, in counsel’s submission. [40] Counsel submitted that Ms. Horodnyk believed the posting had been tailored for the incumbent and that women had been left out was further evidence of the tailoring. The grievor’s 17 evidence was that she had a dilemma about raising this concern with the college. However, the grievor did speak to a male professor in the program who said he did not apply because Department Head said not to apply if he did not have a degree. Another male professor was also discouraged from applying. The grievor testified she could not understand why these people were being discouraged unless the goal was to get the incumbent in the position. [41] Counsel argued that the uncontroverted evidence, taken in the best light for the union, is men were told not to apply, if they had no degree. Counsel argued that this undermines the union’s discrimination allegations, particularly when Ms. Horodnyk, who did not have a degree, was not discouraged from applying. In conclusion, counsel said there is no evidence on which to support an inference that the Department Head wanted the incumbent in the job or that she favoured him as compared to anyone else at all. [42] In counsel’s submission, all of the above undermines the allegation that Ms. Horodnyk did not get the job because she was a woman. Of all the people interested in the job she was the only woman and she did not have a university degree and she was not discouraged from applying. Thus there were only two facts that support her allegations: 1. She is a woman and 2. She did not get the job. The test in Sosoo, infra, makes it clear that this is insufficient to ground a prima facie case of discrimination. There is no evidence for the board to conclude that she has made a connection between the prohibited ground and the alleged discrimination, that is, the failure to get the job. Therefore, the allegation is fatally flawed. 18 2. Should the grievor have received the job because she is a woman? [43] Counsel for the employer argued that there are several problems with this position. First, there is no individual right or entitlement under the Code or the collective agreement to employment equity. Counsel noted that Section 5 of the Code provides that every person has a right to equal treatment with respect to employment without discrimination because of race, ancestry, place of origin, color, ethnic origin, citizenship, creed, sex, sexual orientation, gender identity, gender expression, age, record of offenses, marital status, family status or disability. [44] Counsel emphasized that the grievor’s allegation of discrimination came up after step two in the grievance procedure. During step two, the only thing that the grievor referred to was a breach of employment equity. Counsel argued this case has always been about employment equity. He argued that the grievor based her assumptions on something that was incorrect. The grievor believed that the college was under an obligation to hire a woman in its next full- time position. She believed this in part because she had spoken to a professor previously appointed pursuant to a special hiring program. [45] While the grievor believed the job she was seeking was an equity hire, it was not. The evidence of Professor D’Arcy was that he understood at the time that the posting was not an equity hire. Thus, there was no evidence except the grievor’s belief that it should have been an employment equity hire, that is, that a woman should have been hired. Her belief here is irrelevant. Therefore, the grievance on this point has to fail in counsel’s submission. 19 3. Is there any evidence that the grievor suffered reprisal from the college for asserting her right to employment equity and the benefits that flow from that? [46] Counsel for the college addressed the grievor’s position that she suffered reprisal for raising her employment equity concerns with the employer. The first reprisal occurred when she was reduced from partial load teaching to part-time. The second occurred when the college did not renew her contract in September 2010. Counsel argued that reprisal is a statutory claim and noted the language of section 8 of the Code, which states: Every person has a right to claim and enforce his or her rights under this Act, to institute and participate in proceedings under this Act and to refuse to infringe the right of another person under this Act, without reprisal or threat of reprisal for so doing. Counsel submitted that there is no right under the Code for a protection to assert employment equity. There is specific protection against reprisal in the parties’ collective agreement at Article 4.02 3 (2) which protects against reprisal or complaining about sexual harassment. However, there are no other protections in the collective agreement or under the Code. [47] Counsel argued that in order to establish a reprisal the grievor must show some evidence that there was an intent to punish or retaliate against her, as found in Noble, infra. Counsel noted that the grievor never raised an allegation of discrimination until after her contract was not renewed. Since the college had no knowledge of the grievor asserting discrimination they could not be found to have reprised against her. [48] Counsel also maintained that given the grievor’s contract ended at the end of April 2010, she had no right to any hours in the future. In his submission the employer is not obliged to produce hours for someone who is not an employee. There is also evidence that Professor Perino 20 emailed partial load and other professors that given the full-time hire and someone returning from maternity leave, hours for partial load and part-time professors were not clear. Therefore, in Counsel’s submission, there is no prima facie evidence to show reprisal under the Code. [49] Counsel emphasized to the board that he reviewed every email and contact the grievor had with the college in her cross-examination. Ms. Horodnyk confirmed that she only raised employment equity and never discrimination. The first time she raised the issue of employment equity as a concern for the full-time faculty job posting was at a summer barbecue. Counsel reviewed the exchanges with the college’s equity office and Ms. Horodnyk confirmed that what she raised had to do with equity issues. He noted that Ms. Horodnyk acknowledged that prior to the posting going up she had never raised concerns about favouritism towards the incumbent. There were no equity issues raised during the telephone interview that the grievor had for the job position. Ms. Horodnyk did raise issues about employment equity at the job interview with the panel. [50] Counsel for the college also reviewed the grievor’s email to the Department Head on August 20, 2010 wherein the grievor reacts strongly to having her hours reduced to part-time. She asserts that this is the first time she had any idea that her hours would be reduced and states as follows: I sincerely hope this is not disguised punishment because I took exception to the noncompliance of this hiring process in terms of employment equity. I felt when I requested that women be included as an equity group in the posting, you were hostile towards me. In fact I had to go above the h iring manager and prove that females were und errepresented as professors in the Police Foundations Program. (There are now 5 full-time male professors and 0 female professors.) 21 This research also included the extreme under representation of females enrolled as students in the police foundation’s program. As you may or may not know, the Minister of Equity Stockwell Day very recently announced a review of public sector employers around the issue of equity positions and compliance for under represented groups. I believe the entire process of this specific posting needs to be reviewed. As you are aware I exceed the job requirements in terms of experience and equity and have concerns of how I was treated throughout the process. I am requesting an internal review by Centennial College but I am also open to an independent review under the jurisdiction of Stockwell Day’s Office. (bolding and underlining in original) But at no time did she claim that she had suffered discrimination. It was not until August 23, 2010 that the grievor refers to the incumbent being groomed for the position. [51] The grievor’s email to Professor Perino on August 23, 2010 was the last correspondence before the college met with her on September 1, 2010. In this email, the grievor is reacting to Professor Perino’s disappointment that the grievor believed the hiring process was biased against her. In giving his reasons for why she was not the chosen candidate he said she had not obtained an undergraduate degree, that she had not met the benchmarks of the questions, and he also said that she lacked the necessary supervisory experience required by the position. In responding to him, the grievor stated: Your response only confirms my assertions that the panel was biased towards me in all areas of the process. A University has assessed all of my hands on experience, University and College Courses as equivalent to an undergraduate degree. (bolding in original) [52] The grievor further asserted that bringing up the issue of employment equity visibly agitated the Department Head. She concluded by stating: “I meet and exceed the threshold for the job call.” Counsel questioned the grievor on the August 23, 2010 email to Professor Perino 22 referred to above. He asked her whether she thought it was appropriate and professional to use bolding in the email. Ms. Horodnyk said it was professional. When asked whether referring to Stockwell Day in the email was appropriate, Ms. Horodnyk laughed and said she was being flippant and sarcastic. She also stated: “the systemic barriers I’ve faced during the process are further amplified by the reality that women are not included as professors in the Police Foundations, and there are identified systemic barriers to keep them out.” She ends the email by stating that she had sought advice, both internally and externally and intends to follow through “with requests to have this process investigated and reviewed, as per the Employment Equity Act, Ontario Human Rights Code, collective agreement, etc.” Thus, in counsel’s submission, before the meeting of September 1, 2010, there is no evidence to support a finding that the grievor had asserted a right under the Code against which a reprisal could be committed. Moreover, there was no evidence that any action taken by the college was taken with the intent to reprise. [53] Thus the only evidence that the grievor can use to argue a reprisal is what occurred during the September 1, 2010 meeting. In counsel’s submission this is why he made a substantial argument on why the grievor is not a credible witness. Ms. Horodnyk said she went to the September 1, 2010 meeting to discuss and get feedback on the job competition. All the board has before it is her evidence with regard to this meeting. He urged us to find that we could not rely on her perception of events to defeat the non-suit motion. [54] The grievor testified that she was “ambushed” at the meeting on September 1, 2010. We know from the grievor’s evidence that the Dean had investigated her allegations against the 23 Department Head regarding the unfairness and bias of the hiring process. Ms. Horodnyk testified that the Dean told her that there was no support for the allegations against the Department Head. [55] Ms. Horodnyk also gave evidence of this meeting that the Dean challenged her on why she had taken her story to the Maytree Foundation. The Dean stated that she had defamed the Department Head. It was Ms. Horodnyk’s evidence that, when asked by the Dean, “Did you speak to people outside the college about the complaint?” “I said yes, I knew she was talking about the Maytree email.” The grievor went on to testify that the Dean said she had a problem with Ms. Horodnyk contacting Maytree. Ms. Horodnyk said that she could understand why the Dean was upset, but that she had no intention of anyone in the college ever seeing the email to Maytree. Counsel submitted that the grievor recognized that the email to Maytree was inappropriate, or she would have had no concern that the college saw it. Ms. Horodnyk knew that Maytree had informed the college of her complaint before her meeting with the college on September 1, 2010. On August 27, 2010, she emailed someone at Maytree that she had just learned that her email to them had been forwarded to her employer. [56] On September 2, 2010, Ms. Horodnyk was told that there was no part-time contract for her. In counsel’s submission this is not a surprise, the college had decided it could not deal with her anymore. In an email dated September 9, 2010 to Maytree the grievor wrote, “I was just fired from Centennial College for the following reason: the way your complaint was put out there, the fact that you sent an email about your complaint to outsiders.” Counsel argued that the grievor recognized that this was why she did not have her contract renewed. It was her own behaviour in 24 handling her complaint that led to the college’s decision not to renew her contract. There has been no statutory reprisal based on the Code. [57] In summary, counsel argued that not many cases will lead to a non-suit motion. In this case, there is no evidence to support a prima facie case on the three issues before the board. Since there is no case for the college to meet, it decided not to call evidence. Counsel did note that there had been a decision by the parties to bifurcate the issues and if they lose the non-suit motion, they wish to speak to remedy. The college cited the following cases in its submission: Toronto (City) v. Toronto Civic Employee’s Union, Local 416 (Espinola Grievance), (2000) 93 L.A.C. (4th) 372 ( Surdykowski); Sosoo v. Winners Merchants Inc, 2010 HRTO 1367 (Ontario Human Rights Tribunal); Noble v. York University, 2010 HRTO 878 (Ontario Human Rights Tribunal); Patterson v. Hamilton Health Sciences-Chedoke, 2011 HRTO 1582 (Ontario Human Rights Tribunal); Owen Sound Lumber Co. v. Seaman Kent Co, The Ontario Weekly Notes, October 7th, 1913; Ontario v. Ontario Public Service Employees Union (OPSEU), (1990) 37 O.AC. 218 (Ont. Divisional Court) Parfitt v. Lawless, (1872) Vol. 41 Probate and Matrimonial Court; Nor-Man Regional Health Authority Inc. v. Manitoba Association of Health Care Professionals, [2011] 3 S.C.R. 616 (S.C.C.); Mississauga (City) v. A.T.U., Local 1572 (Pendov), (2012) 109 C.L.A.S. 74 (P. Craven); Manminder Jagait v. IN TECH Risk Management Inc, 2009 HRTO 779, (Ontario Human Rights Tribunal). 25 The Union’s Submission on the Non-suit Motion Introduction [58] Counsel for the union submitted that there is enough evidence before the board to defeat the non-suit motion. Moreover, the union submitted that on a balance of probabilities there was enough evidence to show that the grievor had suffered discrimination contrary to the Code, when the college denied her the full-time position. It further discriminated against her when it terminated her contract. Counsel argued that Ms. Horodnyk was an employee at the end of August 2010. The college breached section 5 of the Code, which prohibits discrimination because of a person’s sex in two ways. The first is that Ms. Horodnyk was denied a fair chance at competing for the position because of the systemic discrimination in the program. The second discrimination occurred when the grievor raised concerns about employment equity and she suffered a reprisal, which is prohibited by section 8 of the Code. [59] The union submits that even if the grievor was mistaken about the original job posting being discriminatory for not including women in the equity groups encouraged to apply and even though she was wrong about the posting being an “equity” hire, she had an honest belief that there had been discrimination and she had a right to have her case addressed. The college retaliated against her because she raised concerns about equity and that in itself amounts to discrimination under section 8 of the Code. Ms. Horodnyk suffered the ultimate reprisal when she was terminated from a job that had been promised to her. [60] Union counsel emphasized that the grievance claims a violation of Articles 4, 6, and the Letter of Understanding on employment equity. Counsel submitted that Article 4, provides that 26 there shall be no discrimination or harassment against any employee of the college. Counsel for the union submitted that this shows recognition between the parties that, when human rights are an issue, all employees deserve protection no matter what the protected ground. Article 4.02 A 9 provides that the normal timelines for grievances do not apply to discrimination and harassment complaints. This shows the parties’ intention to deal with human rights on the merits rather than being defeated for technical irregularities. It is significant that the parties recognize a qualitative difference between human rights complaints and other grievances. This amounts to an implicit acknowledgment of the significance of human rights cases, and is consistent with Supreme Court cases that have held that human rights codes are quasi-constitutional in nature. [61] Counsel for the union submitted that Article 6 of the collective agreement gives the college the right to hire. The hiring must be consistent with the rest of the collective agreement. (See Article 27.11 B) Management actions must also be consistent with human rights provisions of the collective agreement, which incorporate the Code. Counsel also referred the board to the Letter of Understanding on employment equity and the acknowledgement of a shared responsibility between the parties to achieving employment equity. Women are listed as a designated group. The Letter of Understanding also states that the parties at the local level will work together to implement policies to enhance hiring of designated groups. [62] The union has conceded that there was no special program to hire women in place for the position that Ms. Horodnyk sought in the PFP. However she submitted that the collective agreement, the Letter of Understanding and the policies still provide a context in which the board must examine this job competition. These documents recognize a commitment and an obligation 27 for the college to actively address the under representation of certain designated groups. Every job posting that goes up in the college includes the first paragraph that was included for the job posting that is before us. Diversity, equity, and inclusion are fundamental to our mission to educate students. We are committed to education that places strong emphasis on global citizenship, social justice and equity. We live this value through the strength and richness that diversity brings to our workforce and welcome contributors from equity groups including: Women, Aboriginal Peoples, Visible Minorities, Persons with Disabilities, Lesbian, Gay, Bisexual, Transgender and Queer persons. Counsel for the union also cited “Framework for Equity and Inclusion at Centennial College.” Counsel submitted that the college had not considered its equity obligations. [63] There was an objection at this point by counsel for the employer that this is the first time an allegation of systemic discrimination had been raised. Counsel for the union submitted that they had given a significant amount of evidence on systemic discrimination and employment equity. The grievor believed she was the victim of systemic discrimination when she did not get the position. The Union’s Response to the Employer’s Submission on the Credibility of the Grievor [64] Counsel for the union reviewed the five examples and reasons submitted to the board to consider Ms. Horodnyk not credible in her evidence and argued that not one of the employer’s arguments raise legitimate credibility issues. She argued that the best predictor of present behaviour is past behaviour. The most important information about Ms. Horodnyk’s credibility and integrity is that she had a thirty year blemish free police career. She had excellent performance reviews and commendations for, amongst other things, kindness, compassion, and 28 team work. She has exhibited ethical behaviour and these traits do not change overnight. In counsel’s submission the college is grasping at straws to attack the grievor’s credibility. She is a credible witness and therefore the board must accept her evidence in the most favourable light. [65] Counsel argued that the grievor’s evidence will establish each of the essential elements of the claim: 1. She is a member of a protected group. 2. She was subject to adverse treatment. 3. Gender was a factor in the adverse treatment, or 4. Raising her concerns about the gender issue was a factor in the adverse treatment. The union submits that is has established the following: 1. The grievor met the qualifications of the position. 2. The grievor is a woman. 3. Female professors are underrepresented at the college. 4. The grievor raised human rights concerns when the posting for the job came out without women listed in the equity group. 5. The interview panel treated her unfairly, that she had no real chance at the job and that there was no effort by the college to turn its mind to the fact that she was a woman in a male dominated program. 6. The grievor was treated unfairly at the interview because she had raised human rights concerns. That is, there was an intentional reprisal against her during the final interview for the job. 7. The college further reprised against the grievor when she was terminated from employment in September 2010. 29 [66] Counsel for the union submitted that the grievor met the qualifications in the job posting and despite efforts to “dig up dirt” the college could not find any. Ms. Horodnyk was an exemplary police officer. In counsel’s submission there is not a sliver of doubt that she was qualified for the full-time position. Counsel cited the grievor’s cover letter and her resume, noting that each bullet point in the cover letter addressed the requirements of the job posting. Counsel submitted that the grievor’s transcript from the University of Toronto showed that she had completed four courses in the certificate program in Criminology. She submitted that she also had a Canadian History course from the University of Toronto although that was not shown on the transcript. Thus, given all the special training and the university courses it is clear she met the job requirement of an undergraduate degree or equivalent. Counsel argued that at no time was the grievor trying to mislead the interview panel. [67] Counsel stated that the job posting required at least five years of police administration experience. However, none of the courses listed in PFP are on the administration of policing. She argued that this suggests that the college wanted someone to teach police administration but there was no evidence put forward of this. In counsel’s submission that the posting requires administrative experience is because it would meet or match the incumbent’s qualifications. [68] Thus, in counsel’s submission Ms. Horodnyk was qualified for the job and her evidence on her qualifications should not be seen as discrediting her credibility. [69] Counsel for the union submitted that Ms. Horodnyk worked for the Lindsay Police for only a short time in 1989. The only reason it was not included on her resume was because she 30 did not believe it was important. She said that there was no requirement that every position one works at must be on a resume. She said that the employer had insinuated that Ms. Horodnyk omitted references to this employment in order to conceal an accident with a police cruiser. It is the union’s position that this should not support a finding that she is not a credible witness. [70] In sum, Ms. Horodnyk was fully qualified for the full time position that she applied for in PFP and at least equal to the incumbent. Counsel acknowledged that the incumbent’s credentials on paper were impressive. However, Ms. Horodnyk has been a trailblazer in a male dominated field. She has experience as a police officer. She has teaching experience and is a role model for students. In counsel’s submission the hiring panel should have considered the fact that she “had lived” the experience of discrimination. Ms. Horodnyk’s Work Performance at the College [71] Counsel argued that the evidence before the board shows that there were no problems with the grievor’s performance. The grievor testified that she had one verbal assessment by the Department Head which was positive. On cross-examination counsel for the employer presented hand written notes from a classroom visit on October 15, 2009, conducted by the Department Head. [72] Counsel for the union argued that Ms. Horodnyk testified that she had never received the document or the criticisms that were found within the document. The union submitted that it had doubts about the document and suspected that it had been fabricated after the fact. 31 The Department Head’s Favouritism Towards the Incumbent [73] Counsel for the union summarized the evidence provided by the grievor on favouritism shown to the incumbent by the Department Head as follows. The Department Head allowed the incumbent to teach nine hours in one day rather than spreading the teaching out across the week. Professor Yates testified that in his years at the college he had never seen a professor teach nine hours in one day. He also stated that, “since January is always a smaller intake of students than September, it was strange to decide to increase a professor’s hours to nine.” He also testified that the Department Head and the incumbent had a close relationship, that the two of them had a better rapport than the rest. At social functions they sat side by side or close to each other. [74] Counsel for the union submitted that the job posting was geared to the incumbent’s experience because it called for five years of practical experience in police administration, an odd requirement, and a post secondary degree or equivalent. At the September 1, 2010 meeting, the Department Head denied having anything to do with drafting the requirements of the job posting. She indicated that the PAC had done so. Counsel for the union argued that this was not true that a document provided pursuant to a freedom of information request in a letter dated September 23, 2010 shows that PAC had no documents regarding the job competition. [75] Thus, the union is asking this panel to draw a reasonable inference from the above facts that the incumbent was in fact the Department Head’s favourite candidate for the full-time position. At the end of this submission on favouritism, union counsel conceded that there was no evidence to support a personal interest in the incumbent by the Department Head, which led her to make sure the incumbent, would be hired in a full-time position. 32 The Internal vs. External Job Posting [76] Counsel for the union submitted there was a dispute early on as to whether the posting was an internal or an external one. The collective agreement provides that partial load professors can only apply for internal postings while on contract or for one month after their contract ends. Counsel for the union argued that the Department Head took steps to “narrow the field” and give the incumbent the better chance to succeed in the job competition. Counsel stated that this evidence was important because both the grievor and the incumbent had contracts that ended in April, 2010 and the job competition was posted in June of 2010. Thus it is clear that both the incumbent and the grievor had completed their partial load contracts and should not have been permitted to apply for an internal posting. The First Posting [77] Counsel for the union submitted that the following evidence proves that Ms. Horodnyk had good reason to have human rights concerns about the initial job posting. The grievor believed the July 2010 posting was an equity hire because of conversation she had with another professor who had been an equity hire. 1. The grievor also believed it would be an equity hire because of the special program she believed was still in effect. 2. The first posting excluded women from a list of equity groups encouraged to apply. 3. Women are underrepresented in police foundations at the college. In the history of the police foundation’s program at the college there has only ever been one full time female professor who did not remain at the college for long. At the time the grievor was hired as a partial load professor she was the only female partial load professor. There were five full time professors all of them male and seven part time professors six of whom were male. 33 4. The grievor emailed the Department Head on July 2 explaining her concern that the posting did not include women as an equity group. When the Department Head responded she said “you’re right the posting does specifically include women.” So the grievor felt compelled to email her again on July 6. 5. The Department Head responded to this email of the grievor “you’re right, I mean it doesn’t.” 6. Since the second email from the Department Head did not say the posting would be changed, the grievor emailed the college office of Global Citizenship to Dr. Aboagye and Dr. Margaret Brigham and pointed out that women were underrepresented in police foundations and asked that women be included as an equity group in the posting for the full time position. 7. Later that same evening the grievor emailed Dr. Aboagye information about the male-female balance of professors in the department. She also provided information about under representation of women in the police service and noted that women were a recognized equity group in police constable job postings in the Durham regional police service. 8. The grievor testified in cross-examination that she was forced into a position of disadvantage because she had to go to the hiring manager to try to get “women” put into the job posting, then had to go over her head to get it done. [78] Counsel for the union submitted that all of the above evidence proves that Ms. Horodnyk had a legitimate right to raise her human rights concerns about the initial posting. Counsel further submitted that the change to the posting only occurred because the grievor advocated for herself as a woman because she knew women were underrepresented in the PFP. She was worried that there were systemic barriers preventing them from being hired and took action to protect her human rights. 34 The Job Interview and Post Interview [79] Counsel for the union argued that there is clear evidence that Ms. Horodnyk’s job interview was conducted in bad faith and was discriminatory. She relied on the grievor’s testimony that she felt an unwelcoming atmosphere right from the beginning of the interview. Ms. Horodnyk said that Professor Perino was sarcastic and cynical, challenging her on her supervisory experience and on her credentials. On question one, Ms. Horodnyk said that she did not have proof of her credentials with her. Professor Perino’s reply to the statement was “so you have no credentials.” Counsel submitted that Professor Perino’s score sheets for the interview reflect his skepticism. He wrote on the assessment under the first question “no degree.” Counsel argued that this showed that he did not consider whether Ms. Horodnyk had the equivalent of a degree even though he had recorded on the sheet that she had taken five or six criminology courses at the University of Toronto. Counsel argued that we have to question why Professor Perino would doubt that Ms. Horodnyk “met the most basic requirements of the job when she had made it past the initial screening.” [80] Professor Perino’s assessment of questions two, three, four and five were a one out of five. In response to her question six answer, which was to give an example of what she did when she was in a dysfunctional team, Professor Perino made a comment about the age of the example. Ms. Horodnyk testified that this hurt her self confidence and she felt like she had to defend herself rather than promote herself. The last question which counsel for the union described as a “gimme type of question” has no wrong answer. Yet again Professor Perino gave Ms. Horodnyk one out of five. 35 [81] Counsel submitted that Ms. Horodnyk testified extensively about the detailed answers that she provided to the panel during her job interview. She submitted that although Ms. Horodnyk acknowledged she had not performed well during the interview she clearly remembered the information she provided the hiring panel for each question. Counsel argued that the board is required to accept the truth of that testimony. She submitted that reviewing the marks from Professor Perino makes it clear that Ms. Horodnyk had no chance of succeeding at the job interview. She submitted further that something had happened before the job interview to turn Professor Perino against her. She argued it is the union’s position that the only reasonable inference is that Professor Perino was upset by Ms. Horodnyk’s pursuit of her human rights and her insistence that women be added to the job posting. [82] The Department Head’s scoring was slightly better than Professor Perino’s assessment, but still not reflective of the answers Ms. Horodnyk gave, in counsel’s submission. The Department Head gave two out of five on question one, despite the fact that the grievor’s resume indicates that she has the education and experience for the job. The Department Head wrote “no degree, diploma, certificate, credential?” on the assessment sheet. Counsel further noted that there was no recording on an equivalent of a post secondary degree, which was acceptable according to the posting. [83] Thus, in counsel’s submission the panel did not turn its mind to the possibility that the grievor had equivalent credentials to an undergraduate degree and the failure to do so was evidence of bad faith and discrimination. 36 [84] In the remainder of the questions the Department Head assessed the grievor’s answer as a two out of five for questions two and three. She gave Ms. Horodnyk two out of six in question six and two out five for question seven. In counsel’s submission this scoring clearly demonstrates bad faith. The Department Head was ensuring that Ms. Horodnyk had no chance at the job. Counsel urged the board to make the inference that the Department Head was angry about the grievor’s concern about having women listed in the job posting as an equity group. She also urged us to infer that the Department Head felt threatened that Ms. Horodnyk might win the position when she had clearly earmarked it for the incumbent. [85] Union counsel argued in reply to the college’s submission that Ms. Horodnyk had misled the board about her credential, that Ms. Horodnyk was clearly qualified for the job. She asked the board to decide whether Ms. Horodnyk had the equivalent of a university undergraduate degree. [86] Counsel also emphasized the evidence that the grievor raised employment equity and her view that women were underrepresented in the program at the end of the interview. Counsel argued that this shows that Ms. Horodnyk was clearly raising issues of systemic discrimination. [87] Counsel submitted that the college’s treatment of the grievor after the interview also shows bad faith and discrimination. In an email dated August 4, 2010, Ms. Horodnyk asked the Ms. Vidal who had received the full-time position. The Ms. Vidal’s response on August 6, 2010 said that Human Resources did not normally inform a candidate of another candidate’s status. However, the grievor would be informed when the other candidate had accepted the offer. Ms. 37 Horodnyk testified that she believed that after August 6, 2010 Ms. Vidal blocked her emails. The grievor’s emails kept bouncing back to her. She subsequently spoke to someone at IT who told her that Ms. Vidal had blocked her emails. [88] Ms. Horodnyk also emailed Professor Perino on August 5, 2010 to ask him if he knew who got the job. Professor Perino was on vacation and replied to Ms. Horodnyk on August 18, 2010, that the incumbent had been offered the job. Ms. Horodnyk emailed the Department Head on August 20, 2010, to ask about a meeting that had been set up for September 1, 2010, for feedback on her performance in the interview. The grievor also questioned why her schedule had been reduced to two courses. The Department Head responded stating that she had discussed this with Ms. Horodnyk during a classroom visit in May. The Department Head also noted that Professor Perino had sent an email before he went on vacation advising all non full-time faculty which courses they would be teaching. Counsel for the union argued that neither of these statements was true. She noted that the grievor responded that same day and corrected these false statements and copied Professor Perino. She also testified in examination-in-chief that no one told her that her hours might be reduced and that Professor Perino’s email did not say what hours faculty would be teaching. It said that there would be teaching opportunities for everyone, even though there was to be a person hired full-time and someone was returning from maternity leave. Counsel for the union noted that in that email Ms. Horodnyk raised the possibility of the reduction in her hours being a disguised punishment because she had raised equity concerns about the hiring process. 38 [89] Counsel for the union stated that Professor Perino replied to the grievor’s email, explaining that his scoring was based on the following criteria: the grievor did not have an undergraduate degree; the grievor had lack of supervisory experience; the grievor failed to meet the benchmarks in answering the interview questions. Counsel submitted that the benchmarks were not met because Professor Perino assigned the mark of one out of five to every single answer she gave. Thus in counsel for the union’s submission Professor Perino’s actions in awarding one for every answer shows he was acting in bad faith, and in an arbitrary and discriminatory manner. [90] The union argued that the grievor’s view was that Professor Perino did not believe she had supervisory experience because she is a woman and women are much less likely than men to hold positions of power in the police force. Union counsel noted that the grievor responded to his email the next day pointing out his “faulty conclusions” and referred to her belief that there were systemic barriers to women gaining positions as professors in the PFP. In counsel’s submission this email shows that the grievor raised issues of systemic discrimination from the time the job was posted, during the job interview itself, right through to the post interview phase before she was fired. [91] Ms. Horodnyk had wanted to file a formal complaint under the college’s policy for filing harassment or discrimination complaints. She testified that she was not permitted to do this. At the September 1, 2010 meeting, Ms. Horodnyk told the Dean several times that she wanted to make a complaint under this policy. Counsel argued that while the college may have preferred Ms. Horodnyk to file a grievance rather than a complaint under the harassment and 39 discrimination process, she was clearly entitled to do both. The fact that the college denied her the right to file a complaint establishes bad faith and discrimination in her view. [92] Counsel for the union further argued that the grievor knew by the September 1, 2010 meeting that her hours had been reduced to part-time. During that meeting, Ms. Horodnyk said that she believed the reduction in her hours was a reprisal for complaining that the college had not complied with its employment equity responsibilities. Thus in union counsel’s submission the issue of reprisal for trying to enforce her human rights was not something dreamed up for this hearing. The meeting on September 1, 2010 ended with Ms. Horodnyk handing her grievance to the Dean. The grievor was informed the next day that the college was not renewing her contract. [93] In sum, counsel for the union submitted that not only was Ms. Horodnyk denied the full- time position that she deserved but she was terminated in retaliation for trying to enforce her human rights. She submitted that the facts here establish that she was an employee in August although she had not signed a contract yet she had been scheduled to teach two courses in the fall term. Systemic Discrimination [94] Counsel for the union emphasized the following evidence to support the claim that the grievor had suffered systemic discrimination. Women are underrepresented as professors in PFP at the college and in policing in general. The college markets itself as ‘the diversity college” and the Letter of Understanding in the collective agreement refers to a “shared commitment to achieving employment equity within the college.” The college has made no efforts to support 40 employment equity in the PFP. For example when Ms. Horodnyk asked for statistics about the representation of women in the program she was told that none had been collected. During the job interview, Professor Perino was skeptical that the grievor had supervisory experience. Counsel argued here that the only reasonable inference to be drawn is that he was skeptical because he believed that women do not always fill these positions. [95] Further, during the interview the Department Head made the comment in reply to the grievor’s concerns about female representation in the program “there are enough women working at the college.” In union counsel’s submission she did not make a distinction between the number of women at the college in general and the number in the program. When asked by the grievor what it meant that the college “welcomed applications from equi ty groups,” she said she did not know. In counsel’s submission these two statements point to a stunning lack of understanding of the significance of the under representation of women in a male dominated field. This lack of understanding creates a barrier to women like Ms. Horodnyk being successful in a PFP job competition for a full-time position. [96] Counsel argued in reply to the college’s submission that Ms. Horodnyk did not raise discrimination as an issue until after she had grieved. She submitted that this is not the case. She argued that the grievor repeatedly raised issues of systemic discrimination before the job posting, during the interview and after. She submitted that the grievor also raised more direct bad faith discrimination from the panel during her interview for the full-time position. Counsel noted that when the grievor was being cross-examined she claimed systemic discrimination. Contrary to the employer’s argument that systemic discrimination was part of the union’s case until argument, 41 [97] To the college’s position that the grievor cannot claim reprisal under section 8 of the Code because employment equity is not a protected right under that legislation, counsel emphasized that the grievor, in addition to claiming systemic discrimination and employment equity violations also claimed direct discrimination, which is clearly protected under the Code. Counsel submitted that Ms. Horodnyk also raised concerns about the “special program” that she thought was in effect. Counsel reiterated that even if Ms. Horodnyk was wrong about the special program and that the full-time position was to be an equity hire, she is deserving of protection from reprisal under the Code. Counsel argued that the college cannot take the position that they did not know that she was raising discrimination as a ground in her grievance. In this case, intent to reprise against the grievor has been shown in two ways: first, the evidence that she did not get a fair chance during the job interview and second, the evidence that she did not get the full-time job and lost all work with the college. [98] Counsel argued again that Ms. Horodnyk did not need to be correct about whether the college owed her a duty to hire her under employment equity. The law permits an employee to be wrong or unable to prove discrimination and still requires protection under the Code for reprisal. Further, counsel argued that the grievor should be forgiven for using the phrase employment equity even though she meant discrimination. The college submits that Ms. Horodnyk deserves nothing because she did not assert a right under the Code. However, counsel for the union submitted that the grievor was merely not using the right language. 42 [99] In sum, counsel argued that the complainant must introduce some evidence of the essential elements of the claim. Here the claim is that Ms. Horodnyk suffered discrimination from the college. Counsel argued that the union has shown that the grievor met or exceeded the qualifications of the job; she is a woman; women are underrepresented in the PFP; Ms. Horodnyk raised human rights concerns when the job was posted and throughout the process of the hiring; she was treated unfairly during the interview for the full-time position and was not given a fair chance; the panel engaged in this treatment because the grievor had raised human rights issues about the posting. [100] Thus in counsel’s submission having provided some evidence of each element of this discrimination claim she asked the panel to find that Ms. Horodnyk had suffered discrimination by the college because of her sex and reprisal. Counsel asked us to dismiss the non-suit motion and grant the grievance. [101] The union relied on the following cases in support of its submission: Toronto District Board of Education and The Canadian Union of Public Employees, Local 4400, (2001) 168 L.A.C (14th) 339 (Swan); Ontario Public Service Employees Union (Sager et al.) and Ministry of Transportation (2004) 134 L.A.C. (4th) 218 ( Mikus); Southern Alberta Institute of Technology and A.U.P.E., Local 39 (1994) 43 L.A.C. (4th) 261 ( McFetridge); Canada (Attorney General) v. Mossop, [1993] 1 S.C.R. 554 (S.C.C.) Employer’s Reply Argument [102] Counsel for the college submitted that the union claimed that the grievor is a victim of systemic discrimination for the first time in its argument against the non-suit. Counsel argued 43 that the union has thus fundamentally changed the case in its argument. The union should not be able to make a wholesale substitution of its case in closing argument. [103] The union provided detailed particulars of the allegations against the college. They included an allegation that the Department Head had a personal interest in the incumbent and this is why he got the job. The college knew that there was no evidence to support this position. However, the union maintained this position until counsel acknowledged that there was no evidence to support this allegation during her submission against the non-suit. Thus from a legal perspective the union’s case must fail. The purpose of particulars is to define the issues in dispute, so there are no surprises at the hearing. The employer relied upon the particulars to argue the non-suit motion and thus there is prejudice to the employer to allow the union to make out a case that is completely different than what was originally alleged. [104] Counsel argued that the board is not required to simply accept Ms. Horodnyk’s evidence as being true. Counsel for the college reviewed the union’s submissions on evidence and what they alleged were facts in the case. He urged us to separate material facts from bald conclusions. As an example counsel argued the union stated as a “fact,” the Department Head had been pursuing funding for an additional full-time position since the spring of 2009 and had determined by late 2009 that the incumbent should have the position. Counsel urged us to find that there is no evidence to support this statement. It is not a fact in any event. It is a conclusion. A second fact is that the Department Head made the incumbent a partial load professor in December of 2009 in order to make him eligible to apply for a full-time position. Again, counsel for the college submitted that there was no evidence to support this and it is not a fact. 44 [105] Further, it is not relevant to an analysis under the Code because there is no evidence to suggest that the Department Head knew Ms. Horodnyk would apply for the position. If she was trying to get the incumbent the job she was trying to block any and all applicants. A third fact alleged by the union was that the Department Head took an exceptional step by assigning nine hours of teaching in a single day to the incumbent. The union stated that this could not possibly be for a legitimate business reason. Counsel for the college said this is not a fact. It is an argument. Further, just because nobody had ever seen this does not mean that it was wrong. [106] In counsel’s submission, facts may lead to inferences, if the inferences are reasonable. A fourth fact alleged by the union is that when the funding for the position was secured, the Department Head posted the job internally to reduce the number of applications and ensure very little competition for the incumbent. Again, counsel argued this is not a fact. It is an argument. [107] Further, contrary to the union’s position that the college discriminated against Ms. Horodnyk, everyone was discouraged from applying for the position, except the grievor. Moreover, there is no nexus between any of these allegations and a violation of the Code. The professors discouraged from applying were all men. The union relies on the incumbent being allowed to apply as an internal applicant as wrong even though Ms. Horodnyk and the incumbent were both treated as internal candidates for the purposes of the competition. Thus Ms. Horodnyk got the same treatment as the incumbent. 45 [108] The union also alleges that the job posting was tailored to meet the incumbent’s experience and education. Further, the initial posting did not list women as an equity group despite the fact that women are chronically underrepresented in the PFP. Counsel for the college submitted that if this was truly the case then why would the college allow a university degree or “equivalent” when it was clear the incumbent had a university degree and the grievor did not. [109] Counsel for the college said that the union has asked the board to conclude that because Ms. Horodnyk raised issues about the posting, both the Department Head and Professor Perino were angry enough not to give her a fair chance in the job interview. Counsel stated that the particulars never asserted that Professor Perino had a role in this case. Counsel argued further that the union is trying to use the scoring of Professor Perino to bolster a weak case against the Department Head. He emphasized that there was absolutely no evidence of collusion or conspiracy between the Department Head and Professor Perino. More importantly, in counsel’s submission, the union acknowledged that there is no evidence that Professor Perino was aware of Ms. Horodnyk’s challenges to the posting in the pre-interview period. The problem here for the union is that the Department Head scored Ms. Horodnyk higher than Professor Perino and the union was forced to try to address a gaping discrepancy in its case. [110] Regarding the union’s systemic discrimination argument, counsel submitted that there is no evidence that women are underrepresented in the program. The only evidence that we have on this is the grievor’s opinion. Other union witnesses gave evidence about the number of women teaching in the program. However, there was no evidence about how many women applied for positions in the program. 46 [111] Counsel reiterated that this case has always been a case about employment equity and that the union never raised systemic discrimination allegations until the end of the case. He cross-examined Ms. Horodnyk on the distinction between discrimination and employment equity. She recognized the difference. There was no obligation for the college to consider Ms. Horodnyk’s application more favorably because she is a woman. [112] Further, counsel said that Ms. Horodnyk was terminated from her employment. Ms. Horodnyk ceased to be an employee of the college when her contract ended in April 2010. She had no right to a further contract. The parties agreed in the MOS to give the board jurisdiction to hear Ms. Horodnyk’s grievance, when otherwise she had no right to grieve under the collective agreement, since she was not an employee at the time of the competition. [113] Counsel for the college said that the union asked the board to find that Ms. Horodnyk had the equivalent of a post secondary degree. Counsel said that the employer would also like the board to decide this issue. He reiterated that Ms. Horodnyk misled the board and the employer as to her credentials. She does not have a degree and there is no proof that she has the equivalent of a degree. He reminded the board that on cross-examination Ms. Horodnyk said it was the OPG who had assessed her credentials, not a university. [114] In conclusion, counsel urged the board to grant the non-suit motion and dismiss the grievance. 47 Analysis [115] This has been a long and difficult case for the parties. It proceeded by way of MOS and our analysis of the college’s non-suit motion must be guided by that agreement. Ms. Horodnyk’s employment ended with her winter 2010 contract. However, the MOS deemed that the grievor was an employee of the college on September 1, 2010 for the purpose of giving the board jurisdiction to hear her grievance. The MOS specifically authorized us to consider Ms. Horodnyk’s human rights complaints. Ms. Horodnyk agreed to withdraw her human rights complaint at the Ontario Human Rights Tribunal. The parties also agreed that we had the remedial powers of Article 32.03D of the collective agreement. There is an express provision that Ms. Horodnyk was not an internal candidate for the full-time position in the PFP. Finally, the parties agreed in their MOS that Ms. Horodnyk was not entitled to any other rights under the collective agreement. [116] A brief review of arbitral jurisprudence on non-suit motions is helpful at this point in our analysis. The principles applied in non-suit motions at arbitration are well established. In Toronto District School Board, supra, the arbitrator quoted extensively from Ontario v. OPSEU [1990] O.J. No. 365 (Div. Ct.) a decision reviewing an award by the Ontario Crown Employee’s Grievance Settlement Board. The Divisional Court reviewed the necessary elements to be considered by the decision maker in a non-suit motion. The standard of proof on a non-suit is that of a prima facie case, not a case on the balance of probabilities. If a prima facie case has been shown a non-suit must not be granted. It is erroneous to determine a non-suit motion on the basis of the higher onus of the balance of probabilities. A prima facie case is more than a case for the defendant to answer, 48 ‘The term non-suit describes the modern practice of the defendant making an application for judgment at the close of the plaintiff’s case on the ground that the plaintiff has failed to make out a case for the defendant to answer.” Williston and Rolls, “The Conduct of an Action”, p. 45 (Butterworths). ‘A motion for non-suit in modern practice is made by the defendant, contending that the trier of fact should not proceed to evaluate the evidence in the normal way, but should dismiss the action. The defendant must satisfy the trial judge that the evidence is such that no jury, acting judicially, could find in favour of the plaintiff. The decision of the judge in both jury and non-jury actions is a decision on a question of law. Sopinka, “The Trial of an Action”, p. 124 (Butterworths). The “normal way” in a civil action would be on the balance of probabilities. Where a judge is sitting with a jury, the issue is whether there is some evidence to support the claim. If there is, the case goes to the jury. If there is none, it does not. When sitting alone the judge poses the same question. If there is some evidence a motion for a non-suit must be dismissed. If there is none, it must be granted. (para. 25) [117] In City of Toronto, supra, the arbitrator, having cited the history of the non-suit motion in the courts, explained the distinction between “no evidence” and “insufficient evidence” The distinction that has been drawn between “no evidence” and “insufficient evidence” demonstrates the difference between what is and what is not properly a non-suit motion. A non-suit motion is in effect a “no evidence” motion; that is, the moving party asserts that the party which has the onus in the proceeding (or which has the onus with respect to an issue which if decided against it would be dispositive of the proceeding), having had a full and fair opportunity to do so, has failed to make out a prima facie case for the relief it seeks. That is, on its own evidence, there is no reasonable possibility that the party responding to the motion can succeed. (para.17) [118] The arbitrator here went on to address the standard of proof to be applied in considering a motion for non-suit: …the question on a non-suit motion is whether there is any evidence which, if taken at its highest, establishes or gives rise to a reasonable inference in favour of the party responding to the motion. Any doubts in that respect are to be 49 resolved in favour of the responding party (Hall v. Pemberton, (1974) 5 O.R. (2d) 438 (Court of Appeal)). This is consistent with what appeared to be the court’s view of how administrative tribunals should handle such motions (Ontario v. Ontario Public Service Employees Union (1990) 37 O.A.C. 218 (Divisional Court)). This does not mean that the evidence of the party responding to the motion must necessarily be accepted as being true. While a party should be given the benefit of the doubt, taking its evidence at its highest does not require that evidence which is patently untrue or unreliable has to be accepted. Nor does it require that every inference drawn be favourable to the party. If the only reasonable inference to be drawn is a negative one, it is appropriate to do so. The test that I consider appropriate to apply is the test applied by the courts and the OLRB in such motions ; that is, whether taking the evidence at its highest, and drawing all the reasonable inferences most favourable to the City, has the City made out a prima facie case for just cause for discipline? (para.21) [emphasis added] [119] The Court of Appeal’s decision in Hall et al v. Pemberton referred to in City of Toronto, supra, also cited in Toronto District Board of Education, supra, provides as follows: The principle which this Court must apply is stated by Lord Penzance in Parfitt v. Lawless (1872), 41 L.J.P. & M. 68 at pp. 71-2 where he said: I conceive, therefore, that in judging whether there is any case evidence for a jury the Judge must weigh the evidence given, must assign what he conceives to be the most favourable meaning which can reasonably be attributed to any ambiguous statements, and determine on the whole what tendency the evidence has to establish the issue. And, From every fact that is provided, legitimate and reasonable inferences may of course be drawn, and all that is fairly deducible from the evidence is as much proved, for the purpose of a prima facie case, as if it had been proved directly. (para. 25) [120] Thus, we must decide whether there is any evidence that allows the board to make reasonable inferences to show a prima facie case that the college denied the full-time position in PFP to Ms. Horodnyk because she is a woman or that she ought to have won the position because she is a woman. The union alleges that the college did not give the grievor a fair chance 50 during the job interview because the Department Head wanted to hire the incumbent. The college discriminated against the grievor and acted in bad faith. We must also consider whether there is any evidence to find that the grievor suffered reprisal for asserting that women should be listed as an equity group. We must consider all of the union’s evidence generously, but we are not obliged to accept evidence that is patently untrue or unreliable. Further, we are required to draw inferences from the evidence that, if believed, are reasonable and legitimate. [121] The college’s non-suit motion is based on the contention that Ms. Horodnyk’s evidence, where not supported by a document is not credible and therefore the board cannot rely on it or make reasonable inferences from it. [122] It is well established that in assessing the credibility of a witness there is no complete list of factors to be applied by the board. In the oft quoted passage from Farnya v. Chorney [1952] 2 D.L.R. 354 (BCCA) noted in Patterson, supra, the court said as follows: Opportunities for knowledge, powers of observation, judgment and memory, ability to describe clearly what he has seen and heard, as well as other factors, combine to produce what is called credibility. The credibility of interested witnesses, particularly in cases of conflict of evidence cannot be gauged solely by the test of whether the personal demeanour of the particular witness carried conviction of the truth. The test must reasonably subject his story to an examination of its consistency with the probabilities that surround the currently existing conditions. In short, the real test of the truth of the story of the witness in such a case must be its harmony with the preponderance of the probabilities which a practical and informed person would readily recognize as reasonable in that place and in those conditions (…) Again, a witness may testify to what he sincerely believes to be true, but he may be quite honestly mistaken. (para. 217)) 51 [123] There are two aspects to credibility. The first is whether the witness has been honest in his/her testimony. The second is whether the evidence is reliable. Poor memory and misperception, inter alia, are likely to lead to a finding that evidence is not reliable. The Grievor’s Credibility [124] The college has argued that Ms. Horodnyk’s evidence is not credible on key issues: her credentials and her claim to have the equivalent of an undergraduate degree; her work on preparation for a course in 2009, her understanding of her efforts to have the job posting changed to include women as an equity group, and her omission of evidence that she worked as a police officer in Lindsay for several months. Counsel for the union argued that none of this evidence should lead the board to find that Ms. Horodnyk is not credible. In support of her position counsel argued that the best predictor of present behaviour is past behaviour. Counsel for the union emphasizes that Ms. Horodnyk, who had a thirty-year blemish-free police career had been highly commended throughout. She noted further that these traits do not change overnight. [125] Counsel for the employer acknowledged that Ms. Horodnyk had a fine record as a police officer. He also submitted that this case had nothing to do with the grievor’s performance in her work for the college. Rather, the employer’s non-suit motion rests on the argument that Ms. Horodnyk’s evidence is not credible and therefore the board cannot rely on it to find that there is any evidence to survive the non-suit. We agree that Ms. Horodnyk’s performance teaching at the college in fall 2009 and winter 2010 is not an issue before us. We also agree that Ms. Horodnyk has a good record as a police officer. We must nevertheless consider the credibility of her evidence. 52 [126] Counsel for the employer argued that Ms. Horodnyk’s evidence on her qualifications is not credible. Ms. Horodnyk testified in examination-in-chief that she had completed six courses in criminology at the University of Toronto. In cross-examination she acknowledged that she had completed four. She testified that she had not realized that she failed one course. She said that this occurred during a difficult time in her life. In re-examination of the grievor the union tried to tender documentary evidence of a history course completed at the University of Toronto. There was an objection that the document was not admissible and a majority of the board agreed. The board is prepared to accept the oral evidence that she did a history course at the University of Toronto. It is also recorded in her resume. However, it is of no help to the grievor on the issue of her credibility on the evidence that she had completed six courses in criminology. The evidence shows that she completed four. [127] We have to conclude that Ms. Horodnyk was either misleading the board, as she had the college, during her interview, or her evidence here is simply not reliable. She did not remember. [128] Ms. Horodnyk testified that she had told the college that her education and experience was equivalent to a university undergraduate degree. She maintained this position after she learned that she had not been the successful candidate in the job competition. In an email to Professor Perino, in response to his reasons for not finding her to be the best candidate, she says, “a University has assessed all of my hands on experience, University and College courses as equivalent to an undergraduate degree.” When cross-examined as to which university, she admitted that OPG had assessed her work history and education. The union made no submission 53 to the board on this evidence, except to argue generally that as a police officer of thirty years, she had an established record of integrity. Ms. Horodnyk provided nothing further to the board that would allow us to conclude that her work history and education were equivalent to an undergraduate degree. The import of this evidence goes primarily to credibility. However, it is also important to the issue of whether Ms. Horodnyk satisfied an essential requirement of the job posting. [129] Two conclusions emerge from this evidence. The first regards Ms. Horodnyk’s credibility. By claiming that a university had assessed her credentials, she clearly misled us, as she misled the college. It is one thing to forget the number of courses completed in a program some years in the past. It is quite a different matter to assert that her credentials had been evaluated by a university as equivalent to an undergraduate degree, when it is simply not true. The second is that Ms. Horodnyk did not provide evidence that she had the equivalent of an undergraduate degree. Therefore she did not meet a threshold requirement of the job posting, which will be addressed again later in our reasons. [130] The college also argued that the grievor’s evidence on her efforts to prepare to teach the “Issues and Diversity” course in the fall of 2009 is not credible. Without repeating the whole of the evidence in this exchange summarized above, the grievor stated that she worked extensively to create the materials for the course, for example, lesson plans and tests. In cross-examination Ms. Horodnyk acknowledged that the Department Head provided materials to her for the course. She also acknowledged that she made almost no changes to the materials. The board accepts the grievor’s evidence that she worked hard to prepare to teach this course. However, in her 54 evidence in examination-in-chief she led us to believe that she had created the materials for the course. She either deliberately misled us or she did not remember what she had actually done, or she had an inflated view of the work she had done to prepare. In any case, we must once again conclude that her evidence is not reliable. [131] Counsel for the college submitted that the email exchange between Ms. Horodnyk and others with regard to the original posting for the full-time position reveals the grievor’s unreliable perceptions of events around her. The grievor testified that when she saw the job posting dated June 28, 2010 she was concerned that women were not included in the list of equity groups encouraged to apply. After some consideration she emailed the Department Head on July 2, 2010 with her concern about women not being listed. The Department Head emailed back on July 5, 2010 at 8:45 am: “You are right the posting does specifically identify women as one of the equity groups encouraged to apply however, since women are underrepresented in the policing profession, women are one of the equity groups. I hope that helps.” The Department Head meant, “Does not specifically identify women…” Given the email was ambiguous, on July 6, 2010 at 10:48 am the grievor emailed back to the Department Head to clarify this and told the chair that she would contact Human Resources to have the omission corrected. She said that she was happy that the Department Head agreed with her and stated as follows: All Police Services in Canada include women as one of the equity groups and the Employment Equity Act of Canada lists women as one of the equity groups. If this situation is not remedied prior to the expiration of the posting, this whole process may be flawed. Please don’t take my objection to the posting as insubordinate, I make this request with the greatest respect of your authority. It is understandable how the equity groups were attached to this posting, being that the same listed equity groups are attached to other faculty programs. From my perspective, I have had to fight an uphill battle for most of my career in Policing and have learned to be proactive as (sic) apposed to reactive. 55 Thank you for your patience and understanding. [132] Within thirty minutes of the receipt of this email, the Department Head replied to the grievor acknowledging that she meant “doesn’t” list women, and copied Human Resources so that they were aware of the grievor’s concerns. The next day Ms. Vidal of Human Resources emailed the Department Head, thanking her for bringing the grievor’s concern to their attention and advising that the college would be amending the posting. Ms. Vidal copied the grievor. Two days later the grievor emailed the Department Head thanking her for contacting Human Resources on her behalf and forwarding her concerns about the omission of women as an equity group from the posting. [133] These email exchanges are very important for a number of reasons. Ms. Horodnyk raised her concerns about the posting. She was not shy about expressing her views, though she testified that it was a dilemma for her, whether to speak up. She got an ambiguous response from the Department Head, in that her email omitted a “not.” However, the rest of the email indicated that the Department Head agreed with the grievor that women should be listed. In a quick response to the grievor’s query about the “doesn’t” the Department Head clarified the ambiguity. She then copied the email chain to Human Resources. The next day Ms. Vidal responded that the posting would be amended to add women. The evidence is clear that the Department Head responded respectfully and agreed with the grievor’s concern. [134] However, this is not how the grievor understood the email exchange. When counsel for the college asked Ms. Horodnyk about the Ms. Vidal’s response, the grievor said, “I was already very suspicious. I did not know why she was thanking [the Department Head] for something I 56 had done.” Counsel for the college argued that to be suspicious of the college made no sense. Ms. Horodnyk’s belief that the Department Head ignored her concerns about the posting contradicts the emails between them. The evidence that the grievor also emailed the college’s equity office is irrelevant. We have evidence in an email from Ms. Vidal that shows that, upon receipt of the Department Head’s email, she consulted with Mr. Yves Deschenes, the Associate Vice-President, Human Resources and Organizational Development about changing the posting. Ms. Vidal noted that the equity office “had been contacted” regarding the posting. Mr. Deschenes agreed within ten minutes. His email said, “Can you please update the list of equity groups to include women for the posting…” This evidence shows that the college, including the Department Head, took the grievor’s concerns seriously and took the necessary steps to change the posting. [135] Given Ms. Horodnyk’s perceptions of the email exchanges, counsel argued that the board could not rely on her perceptions of what happened during the interview for the job or on the September 1, 2010 meeting with the Dean and others. We accept the college’s argument that it makes no sense for the grievor to be suspicious of an oversight in the posting or wonder why the Human Resources thanked the Department Head for forwarding the grievor’s concerns to them. It does lead us to conclude that Ms. Horodnyk’s perceptions of events here are not credible. [136] Counsel for the college argued that the grievor was willing to testify to anything under oath to make out her case. She was also willing to omit part of her work history that might not have reflected well on her record. Without the grievor’s response on cross-examination to why she omitted this work history, we would not conclude that this was a deliberate omission. 57 However, when cross-examined on her employment in Lindsay, the grievor said, “I did not know that you knew about that”. In the context of the detailed evidence on her work history, it is not likely that she merely forgot to include it. Therefore, we conclude that the omission was calculated. This evidence further undermines the grievor’s credibility. [137] In sum, it is not necessary for us to find that Ms. Horodnyk has been generally dishonest in her evidence, but from all of the above we must conclude that her evidence is not consistently reliable. She exaggerated her credentials and her work on the fall course and misperceived an inadvertent omission on the job posting as something deliberate and suspicious. She certainly did not remember the number of courses she took in criminology. Ms. Horodnyk’s evidence that she had the equivalent of an undergraduate degree as assessed by a university is clearly false. Thus, we must be careful in assessing the grievor’s evidence in this case. Should Ms. Horodnyk have won the position because she is a woman or was she denied the position because she was a woman? [138] The union conceded that the college never designated the full-time position as an equity- hire. Nevertheless, the union maintained that the college ought to have considered its obligations under its employment equity policies and the Letter of Understanding to assess Ms. Horodnyk’s application and that she ought to have won the position because she is a woman. With all due respect, we are persuaded that in this case the college was entitled to choose whomever it considered the best candidate, given Article 6.01 (ii) which provides that the college may hire employees “subject to the right to lodge a grievance in the manner and to the extent provided in this Agreement.” Thus, there was no obligation under the collective agreement or under the college policies to hire a woman. There is no evidence to support the union’s allegation that the 58 college acted in bad faith by not considering equity policies. Moreover, there is no obligation to hire women under the Code. [139] Ms. Horodnyk believed that the college should have hired her because she is a woman. In her view, women are underrepresented in the department. She also testified that she believed that there were systemic barriers to women being hired. Counsel for the college objected to the union arguing in its reply to the non-suit that the grievor did not get the job because of systemic discrimination in PFP. Counsel argued that this was the first time the union raised systemic discrimination as a ground in the grievance. He argued that it would be prejudicial to the college for the board to entertain the argument. He also argued that the union had not put in evidence to support a claim of systemic discrimination. Counsel for the union disagreed and pointed to the grievor’s testimony where she had said she did not get the job because of systemic barriers to women. She also argued that Ms. Horodnyk meant systemic discrimination when she used the term employment equity. We will not repeat the union’s whole argument on this issue, which is found under the subheading, Systemic Discrimination above. [140] We do not need to address the issue of when the union first advanced systemic discrimination, because we are satisfied that there is no evidence to support a prima facie case that there are barriers to women being successful. To advance a case of systemic discrimination there would have to be some evidence of practices, policies or rules that may appear benign, but have an adverse effect on a protected group, in this case women. It is not enough to assert that the program is male-dominated without also providing evidence of how many women applied for full-time positions over some time. Ms. Horodnyk’s opinion that she was unsuccessful in the job competition because of systemic barriers is not helpful. Further, we are not persuaded that the 59 Department Head’s answers to the grievor’s questions at the end of her job interview prove systemic discrimination. Nor can we infer that Professor Perino’s view that the grievor lacked administrative experience was further evidence of systemic discrimination. He seems to have relied upon the fact that the grievor’s highest rank as a police officer was acting sergeant. One final point is that several partial load male professors were discouraged from applying, if they did not have the credentials. Ms. Horodnyk was never told not to apply. [141] The union rightly argued the hiring process must be consistent with the collective agreement, which incorporates the Code. Therefore, the next question before us is whether there is any evidence to support a prima facie case that the college denied the job to Ms. Horodnyk because she is a woman. [142] The union’s position in this case is that the grievor ought to have won the full-time position because she is a woman and is qualified for it. The college did not give her a fair chance during the hiring process; the union argued that the college discriminated against her. Initially it contended that the Department Head contrived to award the position to the incumbent for personal reasons. In argument against the non-suit motion, union counsel conceded that there was no evidence before the board to support the allegation that the Department Head had a personal interest in the incumbent’s success. [143] Much of the evidence tendered by the union was the grievor’s belief that the college treated her badly and the incumbent was the favoured candidate. We heard from Ms. Horodnyk that she was of the view that the college gave the incumbent a teaching assignment that would give him an advantage to compete for the position. The union made a substantial argument that 60 the college permitted the incumbent to compete for the full-time position, even though he was not an internal candidate. The college also permitted the grievor to compete, even though she was not an internal candidate. The college treated them the same way. Thus, we are not persuaded that the college gave any advantage to the incumbent. They were the only candidates for the full-time position and the college allowed both to compete. [144] The grievor testified that in her view the college tailored the job posting to the incumbent’s qualifications. She thought that the Department Head had written the posting. However, there is no direct evidence to support her supposition. The Department Head told the grievor that she had nothing to do with the job posting. She said that PAC drafted it. The union tendered a document from PAC that was incomplete and stated it had no documentation on the job competition. From this evidence, the union asked us to infer that the Department Head lied. We cannot rely on an incomplete hearsay document to make such an inference. We prefer the evidence, which the grievor told us herself, that the Department Head did not draft the posting. [145] The posting required a degree or equivalent qualification. The incumbent has a Bachelor of Applied Arts in Justice Studies and at least on review of his resume would seem to qualify in all the requirements of the posting. Ms. Horodnyk does not have a degree, but as she claimed that she had the equivalent of an undergraduate degree, the college allowed her to compete. [146] The union argued that the omission of women as an equity group in the posting was also part of a concerted effort to hire the incumbent. Further, the union claimed that it was because the grievor raised the job posting issue that the Department Head was angry with her and treated her badly in the job interview. The union asked the panel to infer that the Department Head 61 scored the grievor with low marks because she was angry with Ms. Horodnyk and wanted to ensure that the incumbent was the successful candidate. [147] The union also argued that we should infer that Professor Perino was angry at the grievor for raising the omission of women in the posting during the interview. However, subsequently the union acknowledged that there was no evidence that Professor Perino had any knowledge of the grievor’s concerns about the posting at the time of the interview. There is no evidence that anyone in the college was angry with Ms. Horodnyk for raising her concerns. Ms. Horodnyk may have believed this to be true, but it would be unreasonable for us to infer this on Ms. Horodnyk’s belief alone. As we noted earlier the Department Head’s response to the grievor’s email was respectful and supportive of the change in the posting. [148] We are left with Ms. Horodnyk’s belief that the college treated her badly during the interview because she raised equity concerns about the job posting and because the Department Head wanted the incumbent to get the position. Ms. Horodnyk blamed the panelists for her poor performance in the interview. She complained that the panelists did not give her a chance to explain that she had an equivalent credential. She testified that she understood that she did not have to provide proof of her credentials until she was offered the job. However, there is no direct evidence that the college treated her badly during the job interview. Even if Professor Perino was skeptical about the grievor’s credentials or the Department Head was cold in response to her answers to the competition questions, we are not able to infer this was because she is a woman and the college wanted to hire a man. Given her low scores, we might, conclude that Ms. 62 Horodnyk did not answer the questions very well. She acknowledged as much. She said that she did not do a good job in the interview. [149] We must conclude that given her misperception of the email exchange with the Department Head regarding the change of the posting, her evidence on the interview is not reliable. Further, the claim that the incumbent got special treatment, even if such an inference was reasonable, does not provide any evidence that the grievor suffered discrimination contrary to the Code. To be precise, there is no evidence that the incumbent received special treatment because he is male. [150] The union argued that Ms. Horodnyk was clearly qualified for the full-time position. The grievor testified that she met or exceeded the job requirements. The union invited us to address the issue of whether Ms. Horodnyk had the equivalent of a university degree and argued that it had provided ample evidence through the grievor’s testimony that Ms. Horodnyk was qualified for the full-time position. The employer agreed that we should address the issue. [151] With respect, there is no evidence to conclude that Ms. Horodnyk met or exceeded the job requirements for the full-time position. An undergraduate degree or equivalent was a required qualification for the job. The only evidence before us is the grievor’s opinion that she had attained the equivalent of an undergraduate degree. We cannot simply accept her opinion. It is not reliable. Furthermore, she is not in a position to assess her own credentials. [152] Ms. Horodnyk’s evidence that a university assessed her experience and course work as equivalent to an undergraduate degree was false. There was nothing adduced to show that her credentials were equivalent to an undergraduate degree. There was no certificate or record of 63 assessment from a university as could be expected if she had one. The board has no expertise to assess Ms. Horodnyk’s education and experience. This was the first essential element in the union’s case and there is no evidence for us to find that she met this requirement of the job posting. Even if Ms. Horodnyk met every other requirement in the job posting, this was enough to disqualify her from getting the job. [153] Further, we get some insight from Professor Perino’s email to Ms. Horodnyk in response to her outrage at not being hired. He listed three reasons for her not being successful in the job. In addition to not having a degree or equivalent, she did not achieve the benchmark scores required in the competition questions. He also said that she lacked administrative experience. Ms. Horodnyk reached the rank of Acting Sergeant. [154] As in Sosoo, supra, the grievor here has made broad and sweeping allegations that the college discriminated against her because she is a woman. However, she has not provided any evidence to show the nexus between her gender and the alleged mistreatment. In Sosoo, the Human Rights Tribunal commented on the threshold for meeting a prima facie case of discrimination as follows: It has been said that the threshold for making out a prima facie case of discrimination is not a high one. However, in my respectful view, nor is it so low that merely establishing that one has been mistreated and that one identifies with one or more prohibited grounds under the Code will suffice to make out a prima facie case. If that were the case, then every single employee who experienced any kind of mistreatment would have a prima facie case of discrimination under the Code, since everyone identifies with one or more Code grounds just by virtue of her humanity. In order to make out a prima facie case of discrimination, the applicant’s evidence must establish a foundation upon which the Tribunal could find not only that the applicant was mistreated, but that he was mistreated on the basis of a prohibited ground under the Code. This is consistent with the Supreme Court of Canada’s decision in 64 Andrews v Law Society of British Columbia, [1989] 1 S.C.R. 143, in which the court defines discrimination thus: Discrimination is a distinction, which, whether intentional or not but based on grounds relating to personal characteristics of the individual or group, has an effect which imposes disadvantages not imposed upon others or which withholds or limits access to advantages available to other members of society. (para. 71) We agree with this analysis. The union’s evidence does not provide a foundation upon which we can find that she lost the competition because of her gender. The only evidence we have is that she is a woman and did not get the position. Having carefully reviewed all of the evidence and the submissions of the parties, we have concluded that there is no evidence to support a prima facie case that the grievor was denied the full-time position because she is a woman or should have been successful in winning the competition because she is a woman. Reprisal [155] The next issue to consider is whether there is any evidence to show a prima facie case of reprisal under the Code for the grievor’s complaint. The union argued that the employer was liable for two reprisals. The first occurred when Ms. Horodnyk’s teaching load was reduced from a partial load to part-time. The second occurred when the college did not renew her contract in the fall of 2010. In Noble, supra, the Human Rights Tribunal explains why the protection against reprisal is an important provision in the Code. The prohibition against reprisal is an important provision in the Code. Its purpose is to ensure that individuals may “claim and enforce” the fundamental rights embodied in the Code without fear or intimidation. It protects the integrity of the process before the Tribunal, as well as in other complaint procedures that may be established under human rights policies. An individual need not prove that their rights have in fact been infringed to claim protection of section 8. As the Court has said, 65 “Without a strict prohibition against reprisals, the purposes and effectiveness of the statute would be significantly diluted.” (para 30) [156] The tribunal goes on to articulate the test for reprisal as follows: In order to prove reprisal, a complainant –now an applicant- must establish that the respondent engaged in an action, or threat, which was intended as a retaliation for the claiming or enforcement of a right under the Code. Unlike an allegation of discrimination, where intention is not a necessary element to prove a violation, where a reprisal is alleged, the complainant must establish that the action was action with an intent to punish or retaliate. [cites omitted] (para 31) [157] The tribunal summed up its analysis with a list of the elements that must be proved to establish reprisal: a. An action taken against, or threat made to, the complainant; b. The alleged action or threat is related to the complainant having claimed, or attempted to enforce a right under the Code; and c. An intention on the part of the respondent to retaliate for the claim or attempt to enforce the right. Thus, we must first review the evidence to assess whether the union has provided any evidence to prove a prima facie case that the college deliberately reduced Ms. Horodnyk’s hours to part- time because she made or tried to make a complaint under the Code. Then the union must have adduced evidence that the college intended to punish the grievor for claiming that her human rights had been violated. The union rightly argued that even if the grievor was wrong about alleging a breach of her human rights, the college might still be liable for reprisal under section 8 of the Code. [158] There was a substantial submission before us as to whether Ms. Horodnyk was alleging discrimination before her contract was not renewed in September 2010. The college argued that 66 Ms. Horodnyk did not raise a beach of the Code until at the very earliest September 1, 2010. Union counsel argued that while the grievor complained about the college’s failure to meet what she considered its obligations under employment equity, she really meant that she had suffered systemic discrimination. Whether she meant this or not, she did not make a complaint that her human rights had been violated until the September 1, 2010 meeting with the Dean and others. Before this date, she consistently voiced her complaint on employment equity. She believed that she ought to get the job because she is a woman and in her view, women were under represented. Asserting a right to employment equity is not the same as alleging systemic discrimination. . Therefore, there is no evidence that the grievor claimed a right under the Code, against which a reprisal could be committed. [159] Moreover, the evidence before us is that Professor Perino emailed partial load and part- time professors in the program in the spring of 2010 to tell them that their hours for the fall were not clear, given someone was returning from a maternity leave and the full-time hire. He did say there would be opportunities for all. Ms. Horodnyk claimed that she had no idea that her hours could be reduced, but she did receive the email. It is also important to note again that Ms. Horodnyk’s contract ended in April 2010. She was not an employee of the college and therefore had no entitlement to any hours. [160] The next question is whether the college did not renew Ms. Horodnyk’s contract because she raised equity issues and filed a grievance. As noted above, there is no evidence before us that Ms. Horodnyk claimed a right under the Code until possibly the September 1, 2010 meeting with the Dean and others, when at the end of the meeting in her words she “served” the college 67 with her grievance. The meeting was originally set up for feedback on the job competition. The evidence of this meeting is important to our analysis of the union’s claim of reprisal. [161] Ms. Horodnyk copied the Dean and other senior staff on the August 23, 2010 email to Professor Perino. This email was highly critical of the Department Head. At the September 1, 2010 meeting, she learned that the Dean had investigated her allegations that the competition was not fair and particularly the comments that the incumbent was given special treatment. The Dean told Ms. Horodnyk that there was no support for her defamatory allegations against the Department Head. [162] The Dean had also received a copy of an email from the Maytree Foundation that Ms. Horodnyk had sent the foundation on August 16, 2010. In it the grievor complained to the organization about not getting the job. She also claimed that the college was ignoring equity obligations in hiring. In the email, the grievor complained specifically about the Department Head. The Dean asked Ms. Horodnyk if she had spoken to anyone outside of the college about her complaint. Ms. Horodnyk testified that she understood that the Dean was referring to her email to Maytree. The Dean told her that she had a problem with that. Ms. Horodnyk said that she understood why the Dean was upset. She also told us that she had no intention of anyone in the college seeing the email. The Dean concluded the meeting by telling Ms. Horodnyk she would have to consider what action to take if any given all the circumstances. [163] The grievor testified that she was “ambushed” at this meeting. Counsel for the college urged us not to believe this, given Ms. Horodnyk had a prepared grievance with her and delivered it at the end of the meeting. We tend to agree. The meeting was originally set up for 68 feedback on the job competition. The nature of the meeting changed to an inquiry into Ms. Horodnyk’s complaints, including the one made to Maytree. Given, the evidence on Ms. Horodnyk’s view of what happened in the job interview, which we found not to be reliable, we are not convinced that the college attacked her in any way in this meeting. By her own testimony, she continued to criticize the Department Head and the competition process. Again, she was not shy in advancing her views. [164] The next day the college informed Ms. Horodnyk that they would not be renewing her contract. The union argued that this was the ultimate reprisal for raising her equity concerns with the college. The college argued that the grievor sent outrageous emails both internally and externally and acknowledged in cross-examination that her communication was inappropriate. Given her behaviour and considering that she was not an employee, there can be no inference that the college’s refusal to renew her was reprisal. Counsel for the college also emphasized the grievor’s email to Maytree on September 9, 2010 that said in part, “I was just fired from Centennial College for the following reason: ‘The way your complaint was put out there, the fact that you sent an email about your complaint to outsiders.’” He argued that Ms. Horodnyk recognized that the reason for her nonrenewal was because she had contacted Maytree. [165] It is not clear that the college realized that Ms. Horodnyk was raising any human rights complaint in her grievance, because her complaints at the September 1, 2010 meeting and the emails centered on a claim that the college failed to consider employment equity and the unfairness of the competition, as she saw it. However, even if we found that there was some evidence to satisfy a prima facie case that the grievor made a complaint alleging that her human rights had been violated, we find there is no evidence that the nonrenewal was an intentional 69 retaliation for her complaint. The statements in the August 20 and 23 and Maytree emails are highly disrespectful to the Department Head and the college. In her strident email on August 20, 2010 cited above in full, she attacked the Department Head: I sincerely hope this is not disguised punishment because I took exception to the noncompliance of this hiring process in terms of employment equity. I felt when I requested that women be included as an equity group in the posting, you were hostile towards me. In fact I had to go above the hiring manager and prove that females were underrepresented as professors in the Police Foundations Program. (There are now 5 full-time male professors and 0 female professors.) Likewise, the tone of the August 23, 2010 email is angry and entitled: it contains bolding and underlining. Ms. Horodnyk was outraged that she did not get the job that she was sure should be hers. When asked by counsel in cross-examination whether she thought bolding and underlining was professional and appropriate, she said it was. She also suggested an outside review by Stockwell Day’s office, before the college had even had an opportunity to investigate her concerns. In cross-examination, she admitted that this was flippant and sarcastic. She copied many senior staff of the college on both emails. [166] Further, Ms. Horodnyk’s email to Maytree on September 9, 2010 contradicts any opinion advanced at the hearing that the college did not renew her contract because she raised equity issues with the job competition. She recognized that the college did not renew her contract because she sent her complaint to an outsider. We are satisfied that given her behaviour and considering that she was not an employee, there can be no inference that the college’s refusal to renew her was reprisal. 70 [167] Finally, we would like to thank both college and union counsel for their able argument after a lengthy hearing. [168] For the reasons noted above, we hereby grant the college’s non-suit motion and dismiss the grievance. Dated at Kingston, this 10th day of October, 2014 _ ________________________ Deborah Leighton, Chair _________________________ Ann Burke, College Nominee, concurring __________________________ Sherril Murray, Union Nominee, dissenting in part Deborah Leighton "Ann Burke" "Sherril Murray" 1 Dissent (in part) Although there are a number of issues with which I agree with this Board, using t heir discretion to eliminate the name of the Chair of the Community Services Department (Department Head), Ms. Rita McGillivray while including the name of the grievor is unfair. The parties had not sought an order to omit names and when a Board uses its discretion to eliminate names (a practice I support) I believe it to be an obligation to be exercised for all concerned. To do otherwise is in fact an action against the grievor. With reference to the claims about the preparation work she did before her first assignments, Ms. Horodnyk used the term” course outlines” to describe the work she was doing to learn the materials and create lesson plans. A mistake in terminology is not a fabrication or exaggeration. In terms of the grievor’s resume omitting a few months of employment with a police force over twenty years ago is irrelevant. Yes, she did that and admitted to a minor fender bender during that brief employment. I agree that the grievor did herself no favour by exaggerating her credentials, but I also believe she held a genuine belief that the 30 years of police work, 7 years of Acting Sergeant, her success in the classroom, the 47 or more courses associated with the ranks of police personnel, her courses at University and her self-assessment using the OPG assessment tool gave her the equivalency. By contrast, there was no consideration given by the hiring committee into establishing any type of equivalency. Similarly, with the issue of women in the Department. Absolutely no effort was made to further delve into the question raised by the grievor about why the entire full time faculty of Police Foundations were men. Although the Chair (Department Head) was a female, there was no evidence to suggest she had any police training at all. Although the college revised the posting to include women, it was a hollow gesture without meaningful analyses let alone any course of action. Certainly there is no evidence that the college at any point turned their mind to gender issues nor that an entire program had only male full time faculty. While there was no explanation provided by the college as to why or how it happened, there was also no dispute that the category “women” should have been included on the posting. While the majority may be correct in that the evidence did not support the allegations, the fact remains there were a number of indicators that Ms. McGillivray favoured a certain male candidate. That person was accommodated to the point he taught 9 hours in one day. In this member’s experience in dealing with more than 7,000 college grievances I have never seen such a workload as had neither of the faculty witnesses. 2 To those unfamiliar with this Collective Agreement, teaching “9 hours” classifies the individual as Partial Load, a status which entitles one to be interviewed as an internal candidate. There is sufficient evidence to conclude that the Department Head was at least seeking a new full time position for the program although she may not have known conclusively it was to be approved . Although eventually both candidates were treated as “internal”, it is more likely because the grievor had raised her concerns about the omission of women as an equity group in the posting. However I also believe the grievor that the interview itself was disingenuous. The exhibits show marks from the interview awarded the grievor were extremely low considering the answers she provided and written comments about her answers non - complimentary. The unrefuted evidence that the Department Head also dissuaded two other candidates from applying for the position also gives rise to further concerns. The college asserts (without evidence) that was done because the candidates did not have a University degree. Then why ask for equivalency in the first place? Up until a significant number of days into the hearing, the grievor had not known that this particular posting had not been designated an equity hiring as had the previous posting in the department. Thus her pursuit in the direction of equity matters and systemic discrimination. After dealing with the employer to rectify the posting and include “women”, she brought to the attention of the college the positive efforts of police forces to encourage female applicants in a tremendously male dominated sector. She asked for any information the college could muster on what inquiries had been made into this issue. The only response from her Department Head was “There are already enough women working in the college.” With respect, that does nothing to address the issue with Police Foundations. Turning to the posting itself. It is heavily skewed in a direction which encompasses the incumbent’s qualifications as evidenced in exhibit 54, Ms. McGillivary’s “Request to Recruit Form” and exhibit 58, the incumbent’s resume. No doubt the incumbent’s experience is useful to the department. However, other partial loaders and part timers including the grievor may in fact have possessed superior experience and demonstrated skill. The posting was so narrowly construed paired with the Department Head’s active campaign to dissuade other candidates, we will never know. The grievor testified that she had asked Ms. McGillivary about the creation of the posting and Ms McGillivary said the PAC had created the criteria. A request for information revealed they had not. It is most unfortunate that the grievor’s quest for assistance from Maytree was revealed to the grievor’s employer. More unfortunate is the employer’s defensive and punitive reaction. The grievor had asked for a meeting post interview to review her performance at the interview to seek advice from the employer as to what she needed to do to become the successful 3 applicant for a full time position. Instead she received the news of what she views as her “termination”. She had already been told that she would be teaching two courses and had prepared the materials for two courses. The college chose to withdraw that offer, or more precisely did not commit to place in writing those contracts of employment. I can draw no other conclusion than the employer was offended by the grievor’s persistence at addressing the issues of gender and systemic discrimination and decided to sever the relationship. However I believe a large part of that “offended” also meets the level of reprisal and terminated the grievor contrary to the code. All of which is respectfully submitted, Sherril Murray Union Nominee.