HomeMy WebLinkAboutBouvier 04-01-06
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Concerning an arbitration
Between:
Jeanne Sauvé Family Services
and
Ontario Public Service Employees Union
Grievance of Laurianne Bouvier, Dismissal
Arbitrator: Joseph W. Samuels
For the Parties
Union
Will Presley, OPSEU Representative
Maurice Drolet, Local Steward
Laurianne Bouvier, Grievor
Employer
Guy Wainwright, Counsel
Mac Hiltz, Executive Director
Yves Barbeau, Assistant Executive Director
Hearings in North Bay on April 29, and then in Kapuskasing on July 24,
September 17 and 18, December 22 and 23, 2003
1
On January 23,2003, Laurianne Bouvier was dismissed from her
employment as a Casual Residential Worker at Jeanne Sauvé Family Services.
She was still in her probation period. She grieved her dismissal.
Article 5.02 of the collective agreement provides that "An employee
who has not completed his probationary period may be discharged without
just cause and at the sole discretion of the Employer".
The parties agree that Article 5 .02 governs this grievance and that the
Employer is not obligated to show just cause for the dismissal. However, it is
also agreed that, in exercising its sole discretion, the Employer must not act
arbitrarily, or in a discriminatory manner, or in bad faith.
In this .case, the Union alleges that the Employer did act arbitrarily or
in bad faith, because there was no valid reason to dismiss the grievor. From
its opening statement to the end of the hearing, the Union has argued that the
Employer acted arbitrarily and in bad faith by giving different reasons for the
dismissal from time to time and because there was no factual basis for the
reasons which were given.
The Employer says that the grievor was unsuitable for the position and
this is why it decided to terminate the grievor's employment during her
probation period.
Jeanne Sauvé Family Servic,es operates a number of programs and
facilities to assist families in need of assistance. One of the facilities is a
residential unit for young people, called the "Pavillon". This is where
Laurianne Bouvier worked as a Casual Residential Worker.
Ms. Bouvier was hired on a call-in basis on October 28, 2002. At the
time, she resided in North Bay and she moved to Kapuskasing to take up her
position. She expected to get enough work for full-time hours or close to
full-time hours. Within three weeks of coming to Kapuskasing, she applied
successfully for a contract position as a Casual Full-time worker. She would
be replacing Linda Desbiens, who had recently been appointed as an Acting
Supervisor.
2
The decision to dismiss Ms. Bouvier was made by Mac Hiltz, the
Executive Director of Jeanne Sauvé Family Services. The Union agreed that
he based his decision on information and recommendations from managers
(Yves Barbeau, the Assistant Executive Director, and Jean Raymond, the
Supervisor of Residential Programs), who said that the grievor could not do
her job and would not progress. Given this admission, I made a preliminary
decision that Mr. Hiltz did not act arbitrarily or in bad faith. There remains
the issue of whether the information and recommendation~given to Mr. Hiltz
were arbitrary and in bad faith.
Jean Raymond, the Supervisor of Residential Programs, has been
with Jeanne Sauvé Family Services for 15 years, as a Child Protection
Worker, then a Child Protections Supervisor and, for three years, in his
current position. He told us about the structure of the organization, and the
part played by the PavilIon, where the grievor worked. He explained th~
routine that is prescribed for the clients, and the need for the Residential
Workers to ensure consistency within the program. He spoke about the
principles and practices in dealing with the clients. He was involved in hiring
the grievor. He recommended her to Mr. Hiltz. He had little personal
contact with the grievor after her hire, relying on information he received
from the supervisors on shift, Linda Desbiens and Sylvie Boudreault.
Be told us that, as time went on, he heard that there were repeated
concerns about the grievor's performance-she was having power struggles
with the children, she was giving inappropriate supervision, her interventions
were inappropriate, and she came to,the facility once off-shift and once on
shift smelling of alcohol. He testified that he advised the supervisors on how
to deal with the grievor's performance-they should set goals, go over
interventions and explain to the grievor how to deal with a situation more
effectively.
3
Ms. Bouvier told us that she spoke to Jean Raymond on January 20
about a complaint by a client concerning something Ms. Bouvier had done. I
was not told in the testimony precisely what this discussion was about.
Whatever it was about, Ms. Bouvier testified that she told Mr. Raymond that
none of it was true and he said that he would talk to the client, to find out
how the client felt about Ms. Bouvier. They discussed how Ms. Bouvier
should deal with the issue and with the client. It had to be dealt with. You
couldn't just let it go. Ms. Bouvier said Mr. Raymond was very helpful. He
had always been very helpful. She told Mr. Raymond that she would follow
his instructions.
Three days later, Mr. Raymond handed her the dismissal letter and,
when she asked "why?", he replied that there was no need for him to explain
because she was on probation. I have no difficulty whatsoever understanding
the grievor's shock at this decision, coming so soon and with no warning
after her discussion with Mr. Raymond on January 20.
J Mr. Raymond told us that, on January 21 or 2i, he decided that the
grievor: should be terminated and reported this to Mr. Hiltz. On January 23,
he filled out an Employee Performance Appraisal form for Ms. Bouvier.
Under "Limitations" , he wrote:
. Does not take constructive criticism well
. Very confrontational with clients and co-workers
. Poorllimited intervention skills.
On cross-examination, Mr. Raymond was asked his reasons for
recommending Ms. Bouvier's dismissal and he gave the three points
mentioned in the form on January 23, and he added that there had been two
incidents involving alcohol on her breath-one in January involving Linda
Desbiens (which I will review in detail when I look at the evidence of Ms.
Desbiens), and an earlier incident in December, between Christmas and New
Years Day, when a co-worker reported that the grievor had come to work
"seemingly intoxicated" for a 7 AM shift start. The co-worker had not
4
reported this until several weeks later and Mr. Raymond was upset about this
late report. He never raised the incident with the grievor.
Linda Desbiens had been an Acting Supervisor at the PavilIon since
October 16,2002, which is just before the grievor came to the place. Linda
Desbiens had been a Residential Worker there since March 1995. As Acting
Supervisor, Ms. Desbiens remained in the bargaining unit. Ms. Debiens
supervised the grievor for the grievor's whole time with the Employer.
Ms. Desbiens told us that the grievor did very well at the start. The
grievor was told the policies and procedures and was put on a shift with an
experienced worker. Ms. Desbiens said, once the grievor became full-time,
there were concerns. The grievor did not follow some of the routines; she did
not follow through with some "consequences" (which are issued to residents
when they do something wrong); there were complaints that the grievor
screamed at residents; the grievor got into "power struggles" with residents
. .\
("Do it", "No", "Do it", "No"), rather than saying what needed to be said
and walking away. However, Ms. Desbiens did not appear to have any first-
hand knowledge of these concerns and there may have been no factual basis
for them. Indeed, Ms. Desbiens said in examination-in-chief and in cross-
examination that, from her own observation, the grievor was fine in potential
power struggles.
Ms. Desbiens told us about the evening of January 7,2003, when the
Grievor and a co-worker, Renée Seguin, came in while off-shift. Ms. Seguin
had something to do concerning a health and safety inspection (Ms. Seguin
was the health and safety officer for the PavilIon). Ms. Desbiens testified that
she smelled a strong odor of alcohol when she entered the room and found
the grievor and Ms. Seguin. Ms. Desbiens asked the women if they had been
drinkin.g. She said that the grievor's eyes were red; that Ms. Seguin told her
that she herself had wine with supper; and that the grievor said she had
consumed a Mike's Hard Lemonade. Ms. Desbiens was concerned about the
image that all of this would leave with the impressionable residents.
5
At the time of this incident, the grievor was living with Ms. Seguin.
Ms. Seguin testified that she had one glass of wine with supper and that she
did tell this to Ms. Desbiens. She told us that she did not think the grievor
had been drinking that evening. Ms. Seguin had dinner with her three
children at her ex-husband's place and had then returned home to find Ms.
Bouvier napping on a couch. Ms. Seguin needed to get her health and safety
inspection and talk to Ms. Desbiens about it and Ms. Bouvier drove her to the
PavilIon.
The grievor testified concerning this evening. She insisted that she had
consumed no alcoholic beverage and she said that she did not tell Ms.
,Des biens that she had drunk a Mike's Hard Lemonade.
I accept the evidence of Ms. Sequin and Ms. Bouvier. I find that Ms.
Bouvier had not consumed alcohol on the night of January 7.
Ms. Desbiens told us about a conversation she had with Ms. Bouvier
on January 8 concerning the way in which Ms. Bouvier had dealt with a child
,
who used vulgar language, and Ms. Bouvier's responsibility for this child who
was from outside Jeanne Sauvé Family Services. With respect to the vulgar
language, the grievor replied that she did not give "consequences" because,
on an earlier occasion, she had done so and other staff had told her she was
giving too many consequences. With respect to her responsibility for the
outside child, the grievor said that other staff had told her that he wasn't the
responsibility of Jeanne Sauvé staff. Ms. Desbiens was not happy with either
of these responses. In Ms. Desbiens' view, the grievor ought to have given
consequences, and Ms. Desbiens had instructed staff at a meeting that they
were responsible for this child (though she was not sure that the grievor had
been at the meeting). She told us that she had the distinct impression that
Ms. Bouvier could not take constructive criticism and had a "rationalization"
for everything. In my view, Ms. Bouvier's uncontradicted explanations were
the truth and were a good reply to Ms. Desbiens. If experienced staff had
instructed Ms. Bouvier that she was giving too many consequences, then Ms.
Desbiens cannot criticize her for following this advice. Ms. Desbiens
6
corrected the advice and it appears that the grievor was quite willing to follow
Ms. Desbiens' instructions. And I find that the grievor had been told by
other staff that this boy was not the responsibility of Jeanne Sauvé staff.
Even Ms. Desbiens acknowledged that there had been an issue about the
responsibility of Jeanne Sauvé staff for this person and that is why she had
clarified it at a meeting, but the grievor wasn't at the meeting and can't be
faulted for having acted on the basis of the advice she had from experienced
staff on this point. After Ms. Desbiens corrected her, the grievor was
perfectly willing to follow Ms. Desbiens' advice.
On January 11, Ms. Desbiens met with the grievor to discuss her
performance and the Notes de Supervision that Ms. Desbiens had prepared
concerning the grievor. Ms. Desbiens wanted the grievor to set out her
personal goal and her means of achieving it, but the grievor was not ready to
do this and never responded to this request before her dismissal. As well, the
grievor appeared unwilling to say a number of things which were on her
mind, p8.rticularly with respect to the changes in staff scheduling which were
proposed and which would have a significant impact on the grievor's
opportunity to visit her daughter in North Bay. Ms. Bouvier later added
written comments on the Notes de Supervision, saying that she needed one or
two months to come to grips with the changed schedule and her feelings
about it.
The Union's cross-examination about these Notes de Supervision and
this meeting between Ms. Desbiens and Ms. Bouvier highlighted why this
matter went to arbitration. Ms. Desbiens acknowledged that, by January 11,
she had concluded that the grievor did not take constructive criticism well,
that she had a confrontational attitude with clients, and that she had poor
intervention skills. But none of this was mentioned in the Notes, nor was it
discussed with the grievor! When asked "why not?", she replied that she did
not intc:nd to re-hash issues, just to address new matters. Ms. Desbiens felt
that the grievor already knew that management had these concerns. And Ms.
Desbiens had no real answer to the next question "Couldn't Ms. Bouvier
7
assume that there was no longer a problem in these areas - that she had taken
advice and had improved?" We know from Ms. Bouvier's testimony that, in
fact, that is precisely what was in her mind. In my view, that would be in the
mind of any employee after this meeting with Ms. Desbiens.
Curiously, Ms. Desbiens testified in examination-in-chief that she was
not satisfied with how the grievor dealt with residents-she screamed at
them, she did not follow through on consequences, she did not give
consequences, she engaged in power struggles. Yet, in cross-examination, she
testified that, in the meeting on January 11, she did the opposite of telling the
grievor she was too confrontational with clients. "I told her she wasn't tough
enough" .
I have no difficulty understanding why the grievor was confused about
what were and were not Ms. Desbiens' concerns.
Later on January 11, Ms. Desbiens received a complaint from a client
who said that Ms. Bouvier had screamed at her and had slammed her
bedroom door, and described a power struggle over a whole evening. She
said that Ms. Bouvier had "freaked out" and was in a bad mood that night
and had screamed at another resident. Ms. Bouvier had doubts about the
client's story and scheduled a meeting with Ms. Bouvier for January 23. But,
before this meeting, another worker came in to tell Ms. Desbiens about that
evening and confirmed the client's story. Furthermore, this worker told Ms.
Desbiens that she was concerned about Ms. Bouvier's professionalism and
her interventions and was very frustrated and wanted a supervisor to deal
with this. Ms. Desbiens says that she had no reason to doubt this worker's
story. Ms. Bouvier was dismissed before Ms. Desbiens had a chance to talk
with her about these allegations.
On January 20, Ms. Desbiens asked Ms. Bouvier for a form concerning
clients. Ms. Bouvier took it out of her bag-the one she used to carry things
to and from home. Ms. Desbiens told the grievor that she was not to take
confidential information home. Ms. Bouvier said that she hadn't known this
and accepted the advice.
8
But the next day, when Ms. Desbiens asked for the "diagnostic
conference report" she had lent to the grievor as a model for one the grievor
was doing, Ms. Bouvier took the document out of her bag. Ms. Desbiens was
bothered. The day before, she had instructed Ms. Bouvier not to take such
material home and Ms. Bouvier had done it again a day later. The grievor
was asked about this in her cross-examination and she was adamant that it
never happened. Indeed, on re-examination, the grievor said she had no idea
what a "diagnostic conference report" was. Both witnesses on this point
were very credible. I am left with finding that there was some serious
misunderstanding in this situation and I make no finding of wrongdoing on
the part of either witness.
By the end of Ms. Desbiens' testimony, it seemed clear to me that her
most serious concerns arose from information she received from clients and
other staff. But these people were not called as witnesses and I have no way
of determining whether there was any factual basis for these problems that
were reported to Ms. Desbiens. In particular, Ms. Desbiens heard from ~thers
that the grievor did not handle power struggles well, but Ms. Desbiens' own
observation was to the contrary. More importantly, Ms. Desbiens was still in
the middle of her investigation of the complaint by a client in January when
the grievor was dismissed. Even in Ms. Desbiens' opinion, it was necessary
for her to complete the investigation before coming to a final conclusion
about the legitimacy of the complaint.
Sylvie Boudreault started working at Jeanne Sauvé Family Services
in 1993 as a Residential Worker. She became a Shift Supervisor at the
PavilIon three years ago. She was on leave for most of November 2002, so
she did not work much with Ms. Bouvier until about a month after the
grievor started work.
Ms. Boudreault testified that, on December 12, she observed Ms.
Bouvier in a power struggle with a client. She suggested quietly to Ms.
Bouvier that she give the client choices and walk away. Ms. Bouvier
9
accepted this and it worked. Ms. Boudreault was not concerned because Ms.
Bouvier was a new employee. But a few hours later, Ms. Boudreault
observed Ms. Bouvier in another power struggle with the same client. This
time the client was outside at recess and was threatening to run away and Ms.
Boudreault went out to tell Ms. Bouvier that it was best to do some "planned
ignoring" -just leave the client and walk away and he will follow into the
house. The women did this and the client returned as Ms. Boudreault
predicted. Now Ms. Boudreault was concerned about Ms. Bouvier's
performance, because in the morning she had counselled Ms. Bouvier on how
to handle a power struggle with this particular client and Ms. Bouvier let it
happen. again several hours later. The grievor testified in re-examination that
she had no recollection of the first incident about which Ms. Boudreault
testified, and, with respect to the second incident, Ms. Bouvier recalls dealing
with a client who did not want to return to the house, but she says that there
was a co-worker there but there was no supervisor, and she wasn't engaged
. .
in a power struggle with the client. I accept Ms. Boudreault's recollection of
these events.
On December 18, Ms. Boudreault heard from Nathalie Rochon, the
Family Consultant, that the grievor had not handled a situation well when Ms.
Bouvier gave a client privileges in a situation where the client should have
been subjected to greater structure. We will look in a moment at Ms.
Rochon's testimony. Ms. Boudreault spoke to the grievor to ensure that the
grievor understood the need for consistency in the routines. At the same
time, Ms. Boudreault spoke to Ms. Bouvier about filling in the logs properly.
Ms. Bouvier said that she didn't know she had done wrong and Ms.
Boudreault accepted that. But Ms. Boudreault was troubled by the way the
grievor always had an answer-"Ya, I was going to do it" -and Ms.
Boudreault "wondered".
Ms. Boudreault said that over the next month, the problems did not go
away. Ms. Bouvier was still struggling to get the clients to follow her
directions. Ms. Boudreault said that she wondered if this was Ms. Bouvier's
10
field. "Some have it. Some don't." But, in her cross-examination, Ms.
Boudreault testified that she tries to document all her discussions with staff. It
is very curious that there appears to be no entry in her notes after December
18 that refers to any problem involving Ms. Bouvier and her dealings with
clients. I "wonder".
Ms. Boudreault testified that, on January 13, Ms. Bouvier asked for
time off to see her daughter in North Bay. She wanted to switch shifts with
another employee and had talked to the other employee to try to arrange it.
Ms. BoudreauIt did not think the switches were fair to the other employee
who would be coming off a week of" graveyard" shifts and needed time off
to recuperate. Ms. Bouvier was upset and Ms. Boudreault told her that she
ought to do her work as scheduled. In her cross-examination, the grievor
was adamant that this conversation never took place and that she never asked
another employee to switch shifts with her.
Ms. Boudreault recorded the discussion on January 13 in her notes,
I
which went into the grievor's file. I find that the discussion did take place.
However, the final result is recorded somewhat differently in Ms.
Boudreault's notes from her recollection in her testimony. In her notes, she
wrote that she told Ms. Bouvier that she could take time off, but she would
not accept the switches proposed. And the grievor concluded that she would
take time off because her plans were already made.
In cross-examination, Ms. Boudreault acknowledged that it was
common for employees to request a shift-switch, and that in the vast majority
of cases, the request was granted. It appeared that the grievor's request was
not at all out of the ordinary.
The grievor, in her testimony, spoke about her difficulty accepting the
new shift schedule. When she was hired, she worked eight-hour shifts. But
then management decided that the staffing should be based on a 12-hour shift
schedule. When Ms. Bouvier learned about the change at the staff meeting
on January 6, 2003, she became emotional. She had tears in her eyes. It
would now be difficult for her to see her daughter in North Bay as often as
11
she was used to. She spoke out and, though Linda Desbiens and Sylvie
Boudreault said "We understand" , Ms. Bouvier felt "brushed off'.
Apparently Ms. Bouvier was the only staff member to speak against the
changed schedule.
In sum, Ms. Boudreault said that she gave Ms. Bouvier suggestions on
how to do her work when things went wrong, but the same circumstances
recurred. In Ms. Boudreault's opinion, the grievor was not using her
supervisors' suggestions. Ms. Boudreault could see no improvement in the
future.
I don't understand how Ms. Boudreault could come to this conclusion.
In my view, it is entirely unsupported by her evidence. How could she say
she sa~ no improvement when, having counselled the grievor several times in
December about how to do deal with clients (and the grievor ultimately
followed this advice each time), Ms. Boudreault saw no such problems
throughout January? Surely any reasonable person would have concluded
that the grievor håd improved. Ms. Boudreault had no basis for h~r
conclusion that there would be no improvement in the future. Therefore, this
was an arbitrary conclusion.
Nathalie Rochon is the Family Consultant at the PavilIon. She
counsels clients and families. She has been with the Employer for four years.
She has an MA in Psychology. She has an office in the Pavillon that looks
out on the living room in the Pavillon and from which she can hear much of
what is going on in the central areas. She is in the bargaining unit. The
Employer called her as a witness. She testified about a number of situations
involving the grievor. She was not sure when these incidents occurred.
She told us that, about two or three weeks after the grievor arrived,
she heard clients swearing and cursing and Ms. Bouvier was doing nothing to
stop this behaviour. Ms. Rochon testified that this was the only time she
observed Ms. Bouvier allowing such behaviour. Ms. Rochon can't recall if
she reported this incident to Ms. Bouvier's supervisors.
12
She testified about a boy, who had been suspended from the school at
the Pavillon, who was permitted to walk about the place by Ms. Bouvier,
when he was supposed to bring his desk out from his room and place it in the
middle of the living room and do his schoolwork at the desk. Ms. Rochon
told us that the grievor knew what was to be done, and that the classroom
teacher had come out to tell both Ms. Bouvier and Ms. Rochon that the boy
was suspended from class. Ms. Rochon said that Ms. Bouvier was trying to
get the boy to go to his room and then, when Ms. Bouvier mentioned that
she had to go out shopping, the boy said he wanted to come, and Ms.
Rochon overheard Ms. Bouvier say "Can I trust you to come shopping with
me?" Ms. Rochon called Ms. Bouvier into her office to tell Ms. Bouvier not
to do this. Ms. Bouvier said she didn't know the boy had been suspended
from class, but she had been trying to tell the boy that he couldn't go
shopping but must do his work in the living room. Ms. Rochon told us that
she heard it all and Ms. Bouvier had not said this to the boy. Ms. Rochon
told Ms. Bouvier to go shopping and she would mind the boy. When Ms.
Bouvier returned, the boy negotiated with her to play with a Lego set, instead
of doing his homework. Ms. Rochon spoke again with Ms. Bouvier to tell
her that the boy was to do his homework in the living room and was not
supposed to be playing in his room with a Lego set. Ms. Bouvier said that
this was what she had told the boy. Again, Ms. Rochon testified that she had
heard the conversation with the boy and Ms. Bouvier had not told this to the
boy. Ms. Rochon testified that this was the only occasion on which she had
observed the grievor giving an unwarranted privilege. Ms. Rochon could not
recall when this incident occurred, but it appears to be the one that Ms.
Boudreault said had occurred on December 18. Ms. Boudreault told us that,
on that day, Ms. Rochon told her about the incident and Ms. Boudreault
spoke to the grievor to ensure that the grievor understood the need for
consistency in the routines.
Ms. Rochon testified that, after the incident with the boy, in individual
meetings she had with two residents, the residents talked about Ms. Bouvier
13
coming in and screaming at one of the girls. Ms. Rochon agreed that
residents may try to get workers in trouble, but, before she heard it from the
residents, Ms. Rochon had heard about this screaming from a worker who
had said she observed it. Ms. Rochon believed that the screaming had
occurred and reported it to Ms. Bouvier's supervisor (Ms. Rochon could not
recall if it was Linda Desbiens or Sylvie Boudreault). This appears to be the
incident that was the subject of the complaint from a resident that Linda
Desbiens said she received on January 11. And the worker who confirmed
the incident to Nathalie Rochon appears to have been the person who told
Linda Desbiens that it occurred.
Ms,. Rochon told us that one day she answered the phone and it was
Ms. Bouvier seeking the phone number of a former resident with whom Ms.
Bouvie.r wanted to get in touch and whose phone number the grievor had
lost. Ms. Bouvier told Ms. Rochon that she had exchanged personal phone
numbers with the client. Ms. Rochon was very concerned because she had
~
learned in her university courses that it was unethical for a care-worker to
give her personal phone number to a resident, that this created a dependency.
Ms. Rochon also testified about a suicide watch done by the grievor
just before she was dismissed. She had been called upon to take a turn
watching a resident who was threatening to commit suicide in various ways.
Ms. Rochon told us that the grievor did a good job and she confirmed the
grievor's testimony that Ms. Rochon had told her that she had done a good
job.
It is time to say something about the standard of review and onus of
proof in this case.
Arbitrators and courts have not been consistent in their decisions
concerning the right of a probationary employee to grieve dismissal, and, if
the employee has a right to grieve, concerning the standard of review of the
employer's decision to tenninate the employment. A good statement of the
14
scene is to be found in Brown and Beatty, Canadian Labour Arbitration (3rd
Edition), at 7:5020.
In my view the preferable approach in the case of a provision like
Article 5.02 of this collective agreement (which provides "An employee who
has not completed his probationary period may be discharged without just
cause and at the sole discretion of the Employer") is the one adopted by sole
arbitrator J. P. Sanderson in Re McRae Waste Management and
International Union of Operating Engineers, Localll5 (1998), 71 LAC
(4th) 197. This was one of the cases on which the Union relied here. In
McRae, Mr. Sanderson was dealing with the dismissal of a probationary
employee under a collective agreement which said in Article 11.I(a) "A
probationary employee may be dismissed at....the Employer's discretion"-a
provision which is essentially the same as the one I am dealing with. After an
extensive review of the jurisprudence, Mr. Sanderson quoted at length from a
previous award and said (at page 211) "In my view, these words provide a
thoughtful outline of the appropriate factors to bel considered in judging
whether an employer was acting arbitrarily when exercising its discretion in
terminating an employee during his probationary period". The previous
award referred to by Mr. Sanderson happened to be a decision I made in
1995 in Air Ontario Inc. and CUPE Airline Division (Carter Grievance),
[1995] CLAD No. 731 (QL). I have not changed my view of the proper
way to deal with this type of case. Mr. Sanderson quoted the following
passage from Air Ontario (at page 4 and following):
In my view, the best conclusion and
summary of authorities is to be found in an older
decision of Arbitrator Brandt, in which he dealt
with a collective agreement almost identical to the
one before me-Re Air Canada and Canadian
Airline Employees' Association (1979),23 LAC
(2d) 241. In particular, Article 9.04 of the Air
Canada contract was virtually identical to Article
13.02 of the Air Ontario agreement here, reserving
to the Company the "sole right to make decisions
15
regarding the termination, retention.... of an
employee at any time during the probationary
period". The learned arbitrator said (at pages 245
to 246):
The more widely-held view is that during a
probationary period an employer has a right to
examine "the suitability of employees on the
broadest grounds": see Re U.E.W., Local 514, and
Westinghouse Canada Ltd., supra. (referring to
(1972),24 LAC 74 (Palmer)) The types of factors
that may be taken into consideration include the
employee's character, his ability to work in
harmony with others, his potentiality for
advancement and his general suitability as an
employee: see Re United Rubber Workers, Local
561, and Rosedale Plastics Int'l (1960),11 L.A.C.
71 (Anderson).
As to the proper role of an arbitration board
reviewing the decision of a company terminating
the employment of a probationary employee the
I general trend in the cases is to indicate that role
should be a limited one in which, broadly speaking,
it is recognized that the employer is exercising a
discretion which ought not, except in certain limited
and exceptional cases, to be interfered with: see for
example Re U A.W., Local 195 and Chrysler
Corp. of Canada Ltd. (1949),1 loA.C. 387 (Lang);
Re Board of Education for City of Windsor and
Ontario Secondary School Teachers' Federation
(1975), 10 LA.C. (2d) 165 (Kruger); Re Town of
Mississauga and C.U.P E., Local 66 (1972), 1
LA.C. (2d) 270 (Hinnegan).
One of the best and most recent reviews of
the law with respect to the standard against which
an employer's decision to terminate a probationary
employee's employment is to be measured is found
in the case of Re Cassiar Asbestos Corp. Ltd. and
U.S.W., Local 6536 (1975), 10 L.A.C. (2d) 1,
[1975] 1 Can. loR.B.R. 212 (Murphy). In that case
the board makes disapproving reference to the
Frontenac Floor & Wall Tile Ltd. case, supra
(referring to (1957), 8 LAC 105 (Little)), and
adopts instead the criteria accepted in another case,
16
Re V.S.W., Local 5046 and Construction
Aggregates Corp. (1958),9 L.A.C. 187 (Robinson).
In that case the board attempted to set out the
various principles applicable to the situation of the
termination for a non-disciplinary reason of a
probationary employee and the case of discharge of
a probationary employee. It is appropriate to set
those principles out [po 191]:
(a) by providing for a probationary period the
parties to the collective agreement have themselves
agreed to a distinction between two types of
employees, namely, probationary employee and
regular employee
(b) once the probationary period is over the
employee changes his status and acquires seniority
rights with considerably more job security than the
probationary employee
(c) during the probationary period the employee
is, in effect, on trial to determine whether or not he
possesses satisfactory qualifications and suitability
for regular employment
(d) in this respect during the probationary period
the employee is required to meet the standards laid
down by the company
(e) these standards are not necessarily confined
to those relating to quality or quantity of
production but may include consideration of the
employee's character, ability to work in harmony
with others, potentiality for advancement and
general suitability as an employee of the company
concerned
(f) unless otherwise provided in the agreement,
the employment of a probationary employee may
be terminated by the company at any time during
the probationary period, if in the judgment of the
company the probationary employee has failed to
meet the standards set by the company and is
considered to be not satisfactory
(g) however such decision by the company must
have been made after giving the employee a bona
fide trial during his probationary period and the
termination of the services of the probationary
employee must have been for a reason which was,
in the view of the company, an adequate one and
which was related to the failure by the probationary
employee to meet the standards required by the
company.
Thus, in my view, the Company's decision to
dismiss the grievor is a decision "which ought not,
except in certain limited and exceptional cases, to
be interfered with". And, as said at the end of the
passage quoted from Mr. Brandt's award, "such
decision by the company must have been made
after giving the employee a bona fide trial during
his probationary period and the termination of the
services of the probationary employee must have
been for a reason which was, in the view of the
company, an adequate one and which was related
to the failure by the probationary employee to meet
the standards required by the company". j
This last paragraph captures the standard of review in Ms. Bouvier's
case.
In my view, the Employer did not give Ms. Bouvier a bona fide trial. I
say this for a number of reasons.
Firstly, the Employer deliberately did not raise with her major concerns
about her performance and did not make any reasonable effort to ascertain if
some of these concerns were based on real facts. There are a number of
serious examples of this-
. Mr. Raymond, who w~s the effective decision-maker with respect to
her dismissal, said in cross-examination that one of the reasons he
dismissed her was because he thought she had come to work under the
influence of alcohol in late December 2002. He heard this from an
employee several weeks after it is alleged that it occurred. Mr.
Raymond never asked the grievor about this. He assumed the
17
18
employee's report was correct. In my view, this failure to make any
proper investigation into such a serious allegation against the grievor
was totally unreasonable. When Mr. Raymond used this allegation as a
basis for deciding that Ms. Bouvier's performance was unsuitable, he
was acting in an arbitrary manner.
. Mr. Raymond appears to have taken into account an allegation by a
client that Ms. Bouvier acted inappropriately one evening. Linda
Desbiens was to meet with Ms. Bouvier on January 23 to get Ms.
Bouvier's side of the story. But Mr. Raymond dismissed her without
even giving her an opportunity to tell her story. This was arbitrary
conduct.
. Ms. Desbiens, the grievor's closest supervisor, met with the grievor on
January 11 in a formal discussion about Ms. Bouvier's performance.
At the time, Ms. Desbiens had three serious concerns about the
grievor's suitability as an employee-Ms. Desbiens felt that the grievor
~ j
did not take constructive criticism well, that she had a confrontational
attitude with clients, and that she had poor intervention skills. But
none of this was discussed. The grievor had every reason on January
11 to take from the meeting that there were no such problems. She
was given no opportunity to discuss these serious concerns with Ms.
Desbiens, and, more importantly, she was given no idea at all that the
Employer expected better of her in these areas. She was given no help
whatsoever to improve, if in fact there was some deficiency (as we will
see in a moment, I have serious doubts about whether in fact there was
a deficiency by that time).
. On January 20, the grievor met with Mr. Raymond to discuss a
possible complaint by a client. Mr. Raymond was all helpfulness about
this particular matter. Yet again, Mr. Raymond had an opportunity to
let the grievor know of the deficiencies he thought she had, and to
discuss with her the Employer's standards, and to suggest ways in
19
which she could improve. But he remained dead silent about all this.
And then he handed her a dismissal letter three days later!
1. find in all this a high-handed and arbitrary treatment of Ms. Bouvier.
An employer can't leave an employee in the dark about serious concerns the
employer has, and then dismiss the employee when the employee fails to live
up to the unknown standards. In his testimony, Mr. Raymond said that he
asked his supervisors what they had done to help the grievor set goals,
improve her interventions, and learn how to deal with situations more
effectively. But these things weren't done. I heard about several incidents in
December and earlier, when the employer says that the grievor handled
interventions with clients improperly, but for the whole of January, the
supervisors either saw no problems involving interventions or dealing with
situations, or the supervisors deliberately avoided discussing them in detail
with the grievor (except for the complaint from the client which was never
fully investigated). Again, in my view, it is critical that, on January 11, when
Ms. De"sbiens met with the grievor, Ms. Desbiens had serious concerns (which
mayor may not have been valid), but she consciously stayed away from
discussing them with the grievor. This is exactly the opposite of what is
necessary to give a probationary employee a bona fide trial period. If an
employee walks out of a discussion like that with no idea that the employer
thinks there are serious problems, then the supervisor is simply not doing the
job properly. In particular, the supervisor is not following the scheme that
Mr. Raymond told us he wanted-help the grievor set goals, improve her
interventions, and learn how to deal with situations more effectively.
In Re Abex Industries Ltd. and United Food and Commercial
Workers' Union, Local 173W (1995),48 LAC (4th) 353 (H. D. Brown), the
arbitrator dealt with the discharge of a probationary employee under a
collective agreement with a more restrictive provision than the one in our
case. In Abex, Article 11.01(a) provided that "During the probationary
period, an employee may be discharged by the Employer without the
20
employee or Union having any recourse to the Grievance or Arbitration
procedure". In spite of this prohibition of any recourse, the Employer
accepted that the arbitrator did have jurisdiction under the Labour Relations
Act, and that the test of the company's action was whether it acted arbitrarily
or with bad faith. The arbitrator adopted the definition of "arbitrary" in
Black's Law Dictionary-"In an unreasonable manner, as fixed or done
capriciòusly or at pleasure.... not done according to reason or judgment;
depending on will...". He then went on to say (at page 365):
".... The company has an obligation... to assess the
probationary employee on an objective standard
and to fairly set out, in clear terms, what the
company expects of that employee in that period to
successfully complete his probation and become all
employee with seniority..A probationary
employee.... is entitled to know what will be
expected of him in the job and on what measures
he will be assessed."
Ms. Bouvier was not told the standards in clear terms. Instead, Ms.
Debiens deliberately did not even raise her concerns on January 11. And Mr.
Raymond said nothing on January 20. And then, to compound it all, after
Ms. Bouvier was dismissed, and she asked Mr. Raymond "Why?", he told
her she didn't have to be told. She was judged against hidden standards.
And, once judged inadequate, she wasn't even told what she had done
wrong!
Secondly, a bona fide trial involves judging the employee after a
reasonable effort to ascertain the real facts. Even though the decision is left
"at the sole discretion" of the employer, the employer must exercise this
discretion properly. It is arbitrary to simply accept as fact incidents or
reported conduct. The employer must base its decision on the facts it finds
after a reasonable investigation. Mr. Raymond's conclusions about the
grievor were arbitrary. He wrote in her Employee Performance Appraisal on
January 23,2003, that she was "very confrontational with clients and co-
21
workers" and that she had "poor/limited intervention skills". In fact, there
appears to have been no evidence whatsoever on which he could base a
conclusion that she was confrontational with co-workers. And, with respect
to "confrontational with clients" and "poor/limited intervention skills", I
heard evidence to suggest there were some problems in the first month or so
of Ms. Bouvier's employment (Ms. Desbiens told us of reports she had of
power struggles, but they were unconfirmed), and in December (Ms.
Boudreault concerning December 12 and 18), but nothing thereafter, except
the complaint by a client which had not yet been fully investigated when the
employer dismissed the grievor. Mr. Raymond told us that he met with the
grievor's supervisors every week and every week there were problems
reported to him, but there was no evidence to support this statement. Indeed,
the evidence strongly suggested otherwise! Ms. Desbiens and Ms. Boudreault
were being quite careful through January to document any problems with the
gri~vor in their notes kept in the grievor's file. I wa~ asked by the parties to
read these notes. I did. Ms. Debiens wrote about the complaint she had
received from a client-the one that was still under investigation when the
grievor was dismissed. In all of January Ms. Boudreault had nothing to write
about problems with the grievor's intervention skills or confrontations with
clients. The Employer relied in part on Nathalie Rochon's observations of the
grievor's performance. As we have seen above, Ms. Rochon's office was
well situated for Ms. Rochon to know what the grievor was doing a lot of the
time. From Ms. Rochon's testimony, we know that she didn't observe any
problems with Ms. Bouvier's intervention skills or dealings with clients in the
house in all of January.
Mr. Raymond was asked in cross-examination when did the alarm go
off in his head about Ms. Bouvier? He answered that there was no alarm, but
there was an ember that got brighter and brighter. He had to avoid an
"inferno". But there was no evidence on which he could base his view that
the ember was getting brighter and brighter.
22
Mr. Raymond also wrote in his Performance Appraisal of January 23
that the grievor "does not take constructive criticism well". This appears to
be based on several remarks by Ms. Desbiens and Ms. Boudreault that, when
told she was doing wrong or needed to try another approach, the grievor
gave some "excuse" or "explanation" for what she had done. But there is
not onè shred of evidence anywhere to suggest that, when told what to do,
the grievor didn't do it! Some of her explanations were legitimate-for
example, on January 8, when Linda Desbiens was upset that the grievor had
not given a consequence to an outside boy who used vulgar language (I
explained the situation and my reasoning above, in the review of the
testimony of Ms. Desbiens).
In conclusion, I find that the Employer acted arbitrarily in dismissing
Ms. Bouvier.
The remedy in this situation is not easy to find. In my view, it would
i (
be very uncomfortable for Ms. Bouvier to return to the workplace pursuant
to an Arbitrator's Order. She may not want to return to Kapuskasing, now
that she has moved back to North Bay. The Employer may not want her
back and her treatment in the workplace may not be appropriate. If she is to
return, it should be by agreement of the parties, with suitable arrangements
worked out by them.
At this point, I will confine my Order to this - the grievor must be
returned to the financial position she would have been in had she not been
dismissed arbitrarily. This means a consideration of her losses since her
dismissal, and a consideration of what her future would have been had the
Employer not violated the collective agreement.
23
I will leave it to the parties to fashion a suitable remedy in light of these
considerations. I will retain my jurisdiction to put flesh on these bones, if the
parties are unable to come to agreement on the remedy.
Done at London, Ontario, this 6th day of January, 2004