HomeMy WebLinkAbout1989-0582.Carson & French.90-08-07 ONTARIO EMPL 0 YEs DE ~A COURONNE
CROWN EMPLOYEES DE L'ONTARIO
GRIEVANCE COMMISSlON DE
SETTLEMENT REGLEMENT
BOARD DES GRIEFS
~180 DUNDAS STREET WEST, TORONTO, ONTARIO. MSG 1Z. 8- SUITE 2100 TELEPHONE/T~cL~'PHONE
180, RUE DUNDAS QUEST, TORONTO, [ONTARIO) MSG I Z$ - ~UREAU 2'IO0 (416) 598-06,88
582/89
IN THE MATTER OF AN AiRBITi~ATION
Under
THE CROWN EMPLOYEES COLLECTIVE Bi--GAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOA_RD
BETWEEN
OPSEU (CARSON/FRENCH)
Grievor
- and -
The Crown in Right of Ontario
(Ministry of Correctional Services)
Employer
- and -
B. Kirkwood Vice-Chairperson ....... ~
E. Seymour Member
!]i!~{!"~ D. Clark Member -~
FOR THE A. Hudgins
GRIEVOR Counsel
Cornish Roland
Barristers & Solicitors
FOR THE P..Thorup
EMPLOYER Counsel
Winkler, Filion & Wakely
Barristers & Solicitors
HEARING: April 18, 1990
Page 2
DECISION
The parties presented an Agreed Statement of Facts
and Issues as follows:
1. In or about June of 1989, the Employer posted a
notice of vacancy and a competition dated June 9, 1989 for
four positions as Correctional Officer II at the Quinte
Detention Centre. The competition closing dated was in or -
about June 20, 1989. The competition number was C!-3533-89.
2. The notice contained a provision restricting the
area of search for the competi5ion to classified and
unclassified staff then employed at the Quinte Detention
Centre in Napanee, Ontario.
3. The Grievors at the time were employed as
Correctional Officers II at the Whitby Jail.
4. The Grievors currently live in Oshawa, and did so
at all times material to t~e'grievance.
5. The Grievors applied for the positions in question.
6. Mr. Meyer, the Superintendent of the Quinte
Detention Centre, acknowledged the Grievors' application in
te'tters dated June 21, 1989 and advised the Grievors that ~he
competition was. restricted to individuals currently employed
within the Quinte Detention CenSre and that their
applications would not be given further consideration because
they were not within the defined area of search.
7. The Grievors were not given interviews.
8. The Grievors, Carson and French, filed separate
grievances dated July 4, 1989, and July t, 1989,
respectively, attached as Schedule "A", alleging they had
been unjustly denied the right to apply for the position of
Correctional. Officer II at Quinte Detention Centre and
requesting placement in that position.
9. The policy of the Ministry of Correctional Services
regarding area of search is attached as Schedule "B". Other
Ministries restrict the area of search in a similar or
identical fashion.
10. The Grievor, Carson, has approximately five years
experience in the classified service as a Correctional
Officer II at Whitby Jail.
1i. The Grievor, FrenCh, has approximately two years
experience in the classified service as a Correctional
Officer II at Whitby Jail.
12. It is further agreed by the parties that before
proceeding to the merits of the case, the Grievance
Settlement Board should decide certain preliminary issues as
follows:
Has the issue raised in these grievances been decided by
~he Grievance Settlement Board such that the grievances
ought to be dismissed?
Alternatively or in addition, does the Grievance
Settlement Board have jurisdiction to review the
Ministry's decision to limit the area of search in
Competition No. Ci-3533-89 to applicants already working
at the Quinte Detention Centre? If so, what is the
appropriate standard of review?
13. If the Employer is successful in i%s preliminary
objection, the grievance must be dismissed.. If the Union is
successful on the preliminary objection, it will be seeking a
further hearing date to' deal with the merits of the case.
Should that occur, the subpoena issued to Gary Meyer shall
bind him for any future hearing date(s), unless released on
agreement of the parties or by leave of the Grievance
Settlement Board.
The position was posted as follows:
STAFFING
PURPOSE: - To attract sufficient numbers of eligible
~. and qualified candidates for a vacancy.
POLICY/
PROCEDURE - The Ajea of Search for Bargaining Unit
and Management ~ecrui~ment up to add including
The manager, in consultation with the regional
person~i administrator, will decide on the
area of search based on his/her knowledge of
available resources and the guidelines
contained in Sect:ion 5, Ontario Manual of
Administration, Volume II.
Page 4
Provided that due consideration is given to
these guidelines and to the requirements to
identify a5 least three candidates, a mana.ger
can select from the following geographical
areas of search:
- local - restricted to employees working
in as specific institution or office
- employees residing within 40 km of work
location
- regional or ministry-wide
- OPS-wide
In addition to defining the geographical area
of.search, a competition may be designated as
falling within one cf the following three
categories:
- 'Open' - such a competition is 'open' to
all members of the general public. As
such, all applications should be
entertained. However, postings of the
competition notice may be re.stricted. '
- Restricted to classified employees.
- Restricted to unclassified and classified
employees of the Ministry of Correctional ..
Services.
Although the notice of application was open to all
classified and unclassified staff at the Quinte Detention
Centre, there were no classified staff employed at the Centre
at the time of the posting and the Ministry filled the
position from the pool of unclassified staff.
The successful candidates were in attendance at the
hearing and had the opportunity to participate.
The preliminary issue before this Board is whether
the Board has jurisdiction to consider the grievance, as
raised in paragraph 12 of the Agreed Statement of Fact and
Issue.
'~-c.. "' Page5
The Ministry bases its preliminary objection on the
application of the concept of issue estoppel. The Ministry's
counsel submitted that as a result of the ~J~algamated T~an~i%
Union (E. Bla~eo et al.} and Toron%o Are~ ~ransit Operating
Authority 1276/87 (Shime) decision, the principles of issue
estoppel are applicable to the Grievance Settlement Board.
The Ministry's counsel submitted that the issue
whether a Board could review and limit the management's area
of search has already been considered and decided by other
.:.- panels of the Grievance Settlement Board in the OPSEU (Robert
..-. Hayford/ and ~j~j stry of CorrectioBal Services G.S.B.
%1119/88 (Dissanayke) case, the OPSEU {T.. Cripps1 and
Ministry of Correctional Services G.S.B. g660/86 (Verity)
case, and the OPSEU (C~ Cal/cchia} and Ministry of
TraDsport~%~on ~d Communications G.S.B. %302/85, 602/85
{Roberts) case, which followed the OPSEU (Yvon Lavign~ and
Min]stry of Trans~ortat~o~ ~nd Communications G.S.B. ~561/81
(Delisle) case and held in the Ministry's favour.
The Union's counsel submitted that the previous
cases cannot be relied upon as there were a number of
fundamental errors in the cases, which create exceptional
circumstances, which then provides a basis for the Board to
depart from the earlier decisions.
She further submitted that a collective agreement
must be interpreted according to %he principles of contract
law, and therefore it must be negotiated in good faith. The
Ministry cannot undermine the collective agreement by
exercising its rights in bad faith to the detriment of the
Union and its employees.
The Union's counsel submitted that the cases which
denied review on the basis of bad faith were fundamentally
flawed.
" Page 6
While the Union's counsel conceded that the ~ayfDrd
(supra) decision dealt with the same parties and the same
issues, she submitted that the Hayford (supra) decision was
not decisive of the issue as it did not consider 5he right to
review management's actions if the actions were based on bad
faith. She submitted that a review"'on the basis of an
allegation of bad faith was still available.
The Union's counsel submitted that the Ministry
acted in bad faith and undermined Article 4 of the collective
agreement by pre-determining the candidates by defining the
area of search. She alleged that limiting the search on the
basis of business efficiency was not applicable when the
Ministry gerrymanders the area to establish a pre'determined
result.
The Ministry .argued that it is common pr.actice for
management to limit the area of search as a measure of
efficiency. It considers the job position on a need basis
and determines the area that would provide a number of
candidates with the breadth of experience necessary for the
job. The Uniqueness of the position determines the scope of
the area of search.
:i
The Ministry submitted that it is common that in
many facilities there are unclassified staff members who hope
to move into classified positions, and competitions such as
these, offer them the opportunity to do so, provided that
they are qualified to do so.
The first question which is raised in the Agreed
Statement of Fact and Issue arises as a consequence of the
Blake (supra) decision in which the Board held that the
Grievance Settlement Board acts as one board and does not act
as different panels. Mr. Shime, held, on behalf of the
Page ?
Board, that the various panels of the Grievance Settlement
Board are bound by prior decisions of the Grievance
Settlement Board, unless there are exceptional circumstances
which warrant a departure from the earlier decisions.
The concepts set forth in the Blake (supra)
decision have been reviewed by the Divisional Court in the
unreported decision of Her MajeSty ~h~ Queen in Eight of
Ontario a~ R~esented by the Ministry of Correctional
Services and Ontario Public E~plQy'ee'~ U~iQn (Daniel Dupuis)
and the Gri~eVance Sett%ement Board, Reid J. May 9, 1990. Mr.
Justice Reid found that the decision in Blake when reviewed
in its entirety rested on the acceptance of ~he principle
that the earlier decisions must be relied upon unless they
are manifestly wrong. In obiter dicta, the Divisional Court
expressed a concern about the application of the test of
"exceptional circumstances", but did not find th'at it was
manifestly wrong. Therefore, although the role of the
Divisional Court in judicial review is to determine if the
interpretation of the Board is patently reasonable or not,
and is not to confirm the decision of the Board, the
reasonableness of the Dlake decision has been upheld and the
test set out in the D~ decision is still applicable.
Therefore, we must consider if there are 'other
decisions which decide the same issue as before this board,
and' if so, we must follow the principles 'previously
established unless the earlier decisions are manifestly wrong
or unless there are exceptional Circumstances which provide a
basis for not following the earlier decisions.
The issue which is the'basis of the grievance is
whether the Board has the jurisdiction to review management's
decision to limit the area of search in a job competition.
Page 8
This issue has been- considered by the Grievance
Settlement board on many occasions. It involves the
consideration of article 18 (1) of the Crown Enlp!oyees'
Collective RargD~sin~ Act R.S.O. 1980, c.108 as amended, and
articles 4.03 of the collective agreement. It also involves
article 4.5 of the collective agreement which has been added
since the l.avigne (supra) decision.
Section 18(1) of the Crown r.~loyees' Col!ectj.va
Dargaini~g Act states:
18.--(1) Every collective agreement shall be
deemed to provide that it is the excl'usive
function of the employer to manage, which
function, without limiting the generality of
the foregoing, includes the .right to
determine,
(a)emptoyment,appointment, complement,
organization,assignment,discipline, dismis
sal, suspension, work methods and
procedures, kinds and locations of
equipment and classification of
positions; and
(b) merit systems, training and
development, appraisal and
superannuation, the governing principles
of which are subject to review by the
employer with the bargaining agent,
and such .matters will not be the subject of
collective bargaining nor come within the
jurisdiction of a board.
Article 4.03 of the cotlectiv~ agreement states:
4.03 In filling a vacancy, the Employer shall give
primary consideration to qualifications and
ability to perform the required duties. Where
qualifications and ability are relatively
equal, length of continuous service shall be a
consideration.
Article 4.5 of the collective agreement states:
I ' -,- Page 9
4.5 Relocation expenses shall, be paid in
accordance with the provisions of the
Employer's policy.
The l.av4, gne (supra) case is the first decision that
considered this issue. It dealt with section 18(1) of the
Crown Employee's Collective Bargai~4ng Ac~, and article 4.03
of the collective agreement. The Union claimed that the
right of the Ministry to limit a job search to a geographical
area was in contravention of Article 4.03 of the Cdllective
Agreement. The Ministry however, maintained that management
had an unrestricted right to select the area of search and
relied further on the staffing policy noted in the Ministry's
Personnel Policy and Procedure Manual. The Board held that
management had the unrestricted right to select the area of
search in the absence of other provisions in the collective
agreement to the contrary. Article 4.3 was not found to be a
restriction on management rights. Professor Delisle
recognized the Ministry's responsibility to take business
efficiencies into account when managing public funds.
Professor Delisle stated at page 6
· We are satisfied here that the employer,
given the task of managing public funds,
promotes business efficiency by limiting the
'-' area of search and we see nothing in the
Collective Agreement that in 'any way limits
that right. Counsel for the grievor suggested
that the ability in the employer to limit the
search held the seeds for possibility of abuse
in that the employer might, prior to posting,
regard those who are eligible and then limit
the area of search to insure awarding the job
to its preselected candidate. The short
answer to that possibility resides in the
thought that then the employer would be
subject then to attack on the grounds of bad
faith; In this case no allegation'of bad
faith was made nor evidence of the same led.
We are confirmed in our view of the
unrestricted right in management to select the
area of search in absence of provisions in the
collective agreement to the contrary by the
Page 10
presence in the collective agreement in
Article 24 -' Job Security~ limitations on the
assignation of employees designated as surplus
to vacancies within a set geographical area.
The grievor also relied on the decision of re
Canadian P~c~f~¢ [,im~ted, 19 L.A.C. (2nd) 202
(Schiff), 1978, for the proposition that
geographical limitation on the applicants
candidacy was discriminatory. We are
satisfied however that the result in that
awa'rd was dictated by the particular
provisions of the Collective Agreement. They
are under review and accordingly, has no
application to the instant grievance.
This decision was judicially reviewed by the
Divisional Court and was upheld.
The Union's counsel submitted that it would be
wrong for the Board to rely on the Lavjg~e (supra) decision
as the Board in the L~v. igne case did not consider the
decision of 'Re Canadian Pacific t,imit%d 19 L.A.C. (2d) 202
(Sqhiff) . In the gADadian Pacific 7,imited (supra) case,
Professor Schiff found that as the collective agreement
included a clause providing relocation expenses that the
grievor was being discriminated against, by being excluded
from the competition, by the t6cation of his residence. She
submitted that the language in the Cana~ian.P~cific I~imited
(supra) case which provided for location expenses was similar
to the.language in article 4.5, which has since been included
in the collective agreement between the parties to this
grievance, and submitted that therefore, the Board ought to
consider follow the Canadian.Pacific I,imited (supra) case.
Although a similar provision was considered in the
Canad]~D Pacific 1,4m4ted (supra) case;, in the Cripps (supra)
decision, the Grievance Settlement Board considered the same
issue as between these parties, article 4 which included
article 4.5 as presently drafted, and the decision of the
Divisional Court in l,avigne (supra). It held that the right
Page 11
to limit the area geographically arises from management
rights in s. 18(1) of 5he Crown Employees' Collective
Bargaining Act, and" no provision in article 4 limited
managemen~'s rights to determine the area of search at page
!0 of the decision, Arbitrator Verity stated:
The novel is'sue said to arise in .this case is
the standard or scope of review of the
management right conferred by statute.
Res%ricting the area of search geographically
in a competition is the type of management
activity which the Ontario Divisional Court
appears to agree is within the exclusive
function of the Employer as provided in
section 18 (1) of the Crown Employees'
Collective Bargaining Act. Section 18 of the
Act 'makes it clear that those matters within
the exclusive function of the Employer shall
not be the subject of Collective Bargaining
and in particular, "nor come within the
· jurisdiction of a board" Accordingly, it
would be unreasonable and indeed improper, we
think for a Board' to hinder or in any way
interfere with management rights' in those
areas of exclusive jurisdiction. For the above
reasons, this grievance must be dismissed.
The Divisional Court upheld the Board's decision.
We are not persuaded that there was a manifest
error in the Cripps (suprA) decision· Article 4.5 merely
works in conjunction with management rights in article 18.01.
Management has the right to manage its business, which
includes establishing the criteria for the competition. As
in the I.avigne (supra) decision, the area of search is not a
qualification and subject to this Board's review under
article 4.3 of the collective .agreement. If a person is
chosen and is eligible for relocation expenses pursuant to
article 4.5 of the col~ective agreement, that applicant will
receive the relocation expenses.
Pagcl2
To suggest tha~ the presence of relocation expenses
creates an entitlement to anyone to apply for the job no
matter where that person lives, would create an undefinable
area of search and there would be no limits on the expenses
that may be incurred. It would contrary to the inherent
responsibility of the Ministry to take business efficiencies
and expenses into account when handling public funds.
Nor can we accept Union's counsel submission that
we could not rely on the Crigps (supra) decision as the
~anadian Pacific l, imited (supra) case had no% been brought to
the Board's attention.
Firstly, we cannot determine by the decision
whether the decisions were considered. Secondly, even if it
had, in light of the Blake (supra) decision, when there is a
prior decision of the Grievance Settlement Board on the
interpretation of the same article of the collective
agreement between the same parties, as before the present
panel, the 'decision of the earlier panel of the Grievance
Settlement Board must be applied. The decision of an outside
panel may only be of assistance as a guideline indicating one
interpretation' by an arbitration board on a similar
situation. It does not set a precedent for the'Grievance
Settlement Board.
We also cannot accept the Union's Submission that
we cannot rely on the Cr~9ps (supra) decision as the Board
had not referred to the ~l]~chia and Da Costa decisions.
She had submitted that by not referring to the decisions,' the
Board did not say that they should not be followed.
We do not find tha~ even if the Ealicchia and Da
CQSta decisions were considered that it would advance the
Union's case. The Ca] icchla (supra) case supports the
principles held in the Lavigne (supra) case, but on the
Page 13
facts, the Board did not find that there was any bad faith on
the part of the Ministry or ~hat the Ministry gerrymandered
the area of search to predetermine candidates and therefore
the right to review the decision on ~he basis of bad faith
was not reviewed.
No allegation of bad faith ~was raised in the
qrievance nor was it even raised in the opening statement of
the 'Union. It arose only as a result of the quaere for
clarification raised by the Board
The Union's counsel argued that the allegation of
bad faith was included in the reference in the grievance
form, that the grievor was "unjustly" denied the opportunity
to apply for the position. We find to Che contrary, "unjust"
is not broad enough to ihclude bad faith. An allegation of
bad faith is a serious allegation and goes to the Tvery basis
and veracity .of 'an agreement be%ween the parties and to the
modus operandi of the parties. If bad faith is found, it can
void the transaction or agreement. Unjustly, however, does
not mean that the transaction is void, but that it is
"unfair", which at most, may find that the transaction i's
voidable.
· Whenever a party becomes aware that there are facts
that support an allegation of bad faith, that party must
present that position to the other side as soon as possible
upon. becoming aware of the facts in order that the other
party can meet the issue. Although there .are no pleadings,
as there is in civil litigation, the grievance form presents
the. foundation of the case tO be met. Furthermore the
purpose of the grievance procedure is to discuss %he various
positions .to maximize the chance for settlement. If a party
has facts which suggest that the actions may be void, it
cannot sit and attempt to surprise the other side once the
. other party has put in its case, as it did in this case.
Page 14 _
Such an allegation cannot be used frivolously nor as a basis
for a fishing expedition into the process which the Ministry
followed.
In addition, if there is an allega%io~ made of bad
faith, that allegation must be supported by facts. Although
· 'no viva voce evidence was heard at the hearing, if the union
were seriou~i~'pursuing thf~.aliegation a statement of the
evidence upon which the union was relying should have been
brought to the Board's attention at the commencement of the
hearing. This is not the situation'wher~ facts come to light
in the course of the hearing and one party is given an
adjournment in order to meet a key issue.
If the Union .had thought that the procedure which
the Ministry had followed was improper, it could have raised
the issue by means of a policy grievance when the job was
posted.
Therefore, in summary, we find that the Grievance
Settlement Board and the Divisional Court have considered the
issue that is before this Board and has found that the
Ministry has an unrestricted right to limit the area of
search for a job.competition.
When considering the cases preceding t~is decision,
the submissions of counsel and the Agreed Statement of Fact
and Issue, we find that there are no contradictions in the
earlier cases, nor do we find that there are exceptional
circumstances, nor even any manifest errors in the preceding
cases which would persuade us that these cases' were not
appliCable.
Accordingly, we find that the designation of an
area of search for a job competition is a management right
flowing from Section 18(1) of the Act. .The grievor has been
Page 15
unable to point to 'anythinq in the Collective Agreement that
fetters the exercise of that right, other than article 4,5,
which as we have stated, does not restrict the Ministry's
rights.
We do not find that ~here is any suggestion of any
facts that would lead the Board to concluded that a
possibility of bad faith occurred.
Therefore, the Board is withoUt jurisdiction to
deal with the merits of this grievance and the same is hereby
dismissed.
Dated at Toronto, this 7th day of August 1990.
B.~. K~'~rkwoo~,' Vicecha~rperson
E. Seymour, Union Member
D. Clark, Employer Member