HomeMy WebLinkAboutHutton 06-05-11
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IN THE MATTER OF AN ARBITRATION
BETWEEN:
CASINO NIAGARA
(the "Employer")
- and -
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
on behalf of its Local 278
(the "Union")
AND IN THE MATTER OF THE GRIEVANCE OF J. HUTTON
OPsEU FILE # 03-278-070
AWARD
Board of Arbitration: Paula Knopf, Chair
Clay Appleton, Employer Nominee
Edward E. Seymour, Union Nominee
. APPEARANCES:
For the Employer D. Brent Labord, Counsel
For the Union David Wright, Counsel
A hearing in this matter was held in Niagara Falls, Ontario, on March 30, 2006,
and written submissions received.
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This is a grievance, based on a claim of estoppel, asserting that
the bargaining unit members are entitled to performance bonuses. In order to
expedite what could have become a very complicated and difficult hearing
involving evidence of bargaining, the parties elected to proceed on the basis of
the Union filing a statement of facts and submissions at the outset. The purpose
of this was to clarify the nature of the claim and receive a ruling on whether the
facts raise a prima facie case for a claim based on estoppel. Upon receipt of
those submissions, the Employer filed a response asserting that the Union's
"best case" fails to establish a prima facie case. The parties have asked this
Board of Arbitration to rule on this issue. After a consideration. of the
submissions, it must be concluded that the Union has failed to establish sufficient
evidence to warrant the matter proceeding to a hearing on the merits. The
reasons for that shall be set forth below.
The facts that the Union relies on to attempt to establish a case of
estoppel are the following:
1. The Union has been the certified bargaining agent for a bargaining
unit of security officers of the Employer since August 1, 2001.
2. No other employees of the Employer are represented by a trade
union.
3. The Union and Employer entered into negotiations for a first
collective agreement which were not completed until the signing of
a Memorandum of Agreement on February 9, 2003. The Union
would have been in a legal strike position commencing at 12 a.m.
on February 10, 2003. A copy of the. Memorandum of Agreement is
Exhibit 3 in these proceedings.
4. The Union's bargaining team was made up of Mr. Robert Field, who
is employed by OPSEU as a negotiator, and five members of the
bargaining unit who are employees of the Casino.
5. The February 9, 2003, Memorandum of Agreement resulted in a
first collective agreement for the bargaining unit covering the period
from August 1, 2001 to March 31, 2006. A copy of the Collective
Agreement is Exhibit 2 to these proceedings.
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6. Prior to certification of the bargaining unit, security officers, and
other employees of the Employer, received annual performance
bonuses. While other employees continued to receive such
bonuses after the certification of the Union, the security officers did
not.
7. The Union filed a complaint to the OLRB respecting this issue and
the complaint was resolved by an agreement of the parties dated
January 22, 2002, on the basis that a bonus for the year 2001
would be paid to security officers and that the matter of bonuses for
the 2002 and later years would be dealt with in collective
bargaining.
8. From the outset of the collective bargaining, the Union tabled a
proposed Arhcle 20.06 which provided that:
"The Employer will maintain the existing 'annual
performance bonus program' which is offered Casino-wide,
and this program will continue to apply to all employees in
the bargaining unit."
9. The Union also tabled a proposal for an Article 29.14, which would
provide a bursary for members of the bargaining unit.
10. During a bargaining session on or about January 27, 2003, the
parties engaged in a discussion about the Union's proposed Article
29.14 and related matters of community service payments and the
performance bonus.
11. During this discussion, the Chief Negotiator for the Employer, Bruce
Caughill, stated that the Employer did not want to put language in
the collective agreement (respecting these matters) as the
Emp~oyer might do away with the programs. He indicated that in the
light of reduced revenues post 9/11, the Employer was not certain
that anyone Would be paid a performance bonus. When the Union's
Chief Negotiator, Mr. Field, suggested that language could be
drafted to deal with this possibility, Mr. Caughill stated that "if we
give it to others, you will get it".
12. The notes of bargaining team member Joanne Sheehan for this
session, [regarding] . . .. the Union's proposed Article 29.14. . .
read:
"Talked about other things of this nature
- community service
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- bonus
Don't want in [sic] just in case they do away with but will still
let us access
Bruce said"
13. The parties did not reach any agreement on the. matter of
performance bonuses at this time.
14. The parties met in a number of bargaining sessions between the
date of this session and February 6,2003.
15. During these sessions, the matter of performance bonuses
remained outstanding, and the Union's proposed Article 20.06
remained on the table.
16. At the bargaining session of February 6,2006, the Employer tabled
a proposal for wages and pension, which included a proposal for
the payment of a bonus for the year ending March 31,2002, and for
a one-time lump sum bonus on date of ratification. While this
proposal provided for the payment of bonuses, no numbers were
set out in the proposal. The Employer referred to its proposed
bonus asa "signing bonus" not a "performance bonus". A copy of
this proposal is attached as Appendix 1.
17. The Union rejected this proposal.
18. After the bargaining session between the full bargaining teams on
February 6, 2003, a meeting was held between Mr. Field and Ms.
Sheehan for the Union, and Mr. Caughill and Simon Mortimer,
counsel to the Employer. At that meeting, the Union tabled a new
proposal for performance bonuses. Instead of language which
simply. provided for the continuation of the annual. performance
bonus plan, the Union tabled a proposal that performance bonuses
would be paid as follows:
$1060 - retroactive
$1000 - 2003
$2000 - 2004
$2000 - 2005
19. Mr. Caughill responded by saying that the parties were so far apart
that he could not respond. In further discussion at that meeting, he
then reiterated, with respect to a performance bonus, that "if we
give it to them (other employees), we will give it to you".
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20. The next day there was a discussion between the employee
members of the bargaining team, at which Mr. Field was not
present. Ms. ,Sheehan advised the other employee members of the
team of the comment made by Mr. Caughìfl with respect to
performance bonuses the night before (as set out in paragraph 17).
21. The employee members of the bargaining team, including Ms.
Sheehan, interpreted and understood this comment to mean that
they could reach an agreement on signing bonuses to be paid
retroactively and at the date of ratification, as proposed by the
Employer in Appendix 1, and that members of the bargaining unit
would still be eligible for and be. paid annual performance bonuses
if such bonuses were paid to other employees in the future.
22. in reliance on Mr. Caughm's comment, which confirmed his
comment made in discussions respecting the proposed Article
29.14 regarding bursaries (as set out in paragraph 11 above), the
employee members of the team agreed that they could accept
language respecting bonus on the model proposed by the
Employer on February 6, providing agreement could be reached as
to the amount of the signing bonus.
23. Negotiations continued between the parties and all further
discussions about bonuses related to the amount of the signing
bonuses that would be paid under the model proposed by the
Employer on February 6.
24. Ultimately, on February 9, a full agreement was reached, as set out
in Exhibit 3, which included payment ofa bonus of $1060
retroactively, a lump sum payment on ratification of $750 and an
additional lump sum payment for benefit adjustment of $150.
25. The employee members of the bargaining team would not have
agreed to these amounts if they had not accepted the
representations of Mr. Caughill that they would be eligible for future
performance bonuses if such performance bonuses were paid to
other employees.
26. After the Union learned that in fact other employees had been paid
a performance bonus in May 2003, this grievance was filed.
The Union asserts that the facts set out above establish a prima
facie case of estoppel. In support of this, the Union relies on the authorities of Re
Hallmark Containers Ltd. and Canadian Paperworkers Union, Local 303 (1983) 8
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LA C. (3d) 117 (Burkett), at p. 124; Re The Sf. Catharines Standard and St.
Catharines Typographical Union,. Communications Workers of America, Local
416 (1998) 72 LAC. (4h) 332 (Rose), at 341-2; and Consumers Glass v. United
Steelworkers of America, Local 260G (July 7, 1998) unreported (Briggs), at pp.
13-14. Counsel for the Union asserts that representations were made to the
Union on two occasions to the effect that if performance bonuses were paid to
employees outside the bargaining unit in the future, this bargaining unit would
receive the same bonuses. It is also alleged that the Union relied on those
representations as the basis for their agreement to the language on bonuses
initially tabled. by the Employer on February 9, 2003. It is asserted that this
reliance was to the detriment of the Union, as performance bonuses were in fact
paid to other employees after February 9, 2003, but were not paid to members of
thi~ bargaining unit. Accordingly, the Union submitted that the evidence it intends
to rely upon establish a prima facie case of estoppel. Accordingly, it was said that
the Board of Arbitration should proceed to a hearing of the merits of the case.
In response to the Union's submissions, the Employer asserts that
the alleged facts are not evidence of an independent promise to continue the
performance bonus plan. Further, it is asserted that the Union's facts do not
assert that it treated these discussions as representations that were relied upon
to its detriment. It was stressed that the Union made different and subsequent
proposals in relation to performance bonuses on and after February 6, 2003.
Further, it is alleged that the discussions on February 6, 2003, and thereafter
focused on the Employer's proposal for wage increases and a payment of fixed
bonuses in lieu of the performance bonuses. It is asserted that to interpret the
proposal otherwise would lead to the conclusion that the Employer was offering
economic items not. requested by the Union and voluntarily proposing terms and
conditions which exceeded that which was provided to the larger non-Union
group. It is asserted that the facts alleged by the Union indicate simply that the
Employer was offering a fixed bonus instead of annual performance bonuses. It
is also asserted that the facts indicate that the Union's counterproposal as of
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February 6, 2003, shows that the parties began to discuss fixed amounts in lieu
of the continuation of performance bonuses. It was submitted that the facts which
the Union relies upon are more consistent with the conclusion that the Company
intended to provide either a fixed bonus or a performance bonus continuation,
but not both. It is asserted that such evidence is not clear.and cogent evidence of
a representation that the Company was agreeing to provide the performance
bonus outside of whatever else the Union was able to negotiate by way of a fixed
bonus. The Employer recognizes that the chief negotiator for the Union may have
understood or believed that the performance bonuses may continue outside the
Collective Agreement. However, it was asserted that the facts the Union intends
to rely upon do not give rise to a clear and cogent representation that the
Employer would continue to perform its bonus plan outside of the Collective
Agreement. Further, it was said thatthe chronology and context of the proposals
and counterproposals, even as alleged by. the Union, are as consistent, if not
more consistent, with the Employer negotiating on the. basis of either
performance bonus or fixed bonus, but not both. The Employer also stressed that
the Union does not assert that the Employer stated that the Union would r~ceive
both the fixed bonus it proposed plus the performance bonus continuation. In
support of its submissions, the Employer relies upon Re Strait Crossing Joint
Venture and International Union of Operating Engineers/Iron Workers (1997) 64
LAC. (4th) 229 (Christie); and Re Sudbury District Roman Catholic Separate
School Board and. Ontario English Catholic Teachers' Association (1984) 15
LAC. (3d) 284 (Adams).
THE DECISION
This is a claim based on estoppel. The Employer has asked that
the grievance be dismissed at the preliminary stage without a consideration of
the merits of the case on the basis that the facts that the Union intends to rely
upon do not establish a prima facie case. Therefore, the issue at this stage is not
whether clear and cogent evidence exists to found the claim. The question is
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simply whether the Union's alleged facts raise a prima facie case that could
support the claim.
Estoppel is established where one party to a collective agreement
makes a representation to the other as to how it will administer the collective
agreement, and where the second party relies on that representation to its
detriment. Representations made at the bargaining table can support an
estoppel. See Hallmark Containers Ltd., supra; and St. Catharines Standard,
supra. However, what the Union is seeking here is a significant monetary benefit
which one usually expects to see within the wording of the collective agreement
itself. In order for the Union to succeed in this case, at this stage, it must show
alleged facts that would form the basis for a conclusion that a significant
monetary benefit was being promised to the bargaining unit outside of the
Collective Agreement.
The facts the Union wishes to rely upon do indicate that in the early
stages of negotiations there may have been discussions about the continuance
of the performance bonus outside of the contract. However, the facts also
indicate that the question of bonuses remained unresolved up to February 6,
2003. At that time, the Union tabled a proposal regarding performance bonuses
which the Employer clearly did not accept. The following day, the Union engaged
in discussions regarding the Employer's proposal respecting a "bonus model"
that did not include a performance bonus. Indeed, the facts the Union relies upon
reveal no discussions between the parties regarding the "performance bonus"
once the parties focused on the Employer's different "bonus" model. Thereafter,
there is no allegation that the Company promised to provide a performance
bonus in addition to the fixed bonus that the parties were then discussing.
Hearings that reopen the history of negotiations and that pit
peoples' understandings and assumptions during bargaining can be very
complex and divisive. Counsel and the parties are to be commended for the
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decision to expedite what could have been a very difficult and costly case by
choosing to make written submissions and set forth the facts they intend to rely
upon in order to seek directions from this Board of Arbitration. The Board has
considered the outline of the factual basis of the Union's case. The facts reveal
that the Union was able to secure significant monetary benefits for the members
of this bargaining unit. Even if all the facts set forth by the Union are proven, it
must be said that those facts do not establish the legal basis that is necessary for
the claim for additional benefits to succeed. The Union has the legal and the
evidentiary onus in a case of estoppel. The facts the Union is relying upon cannot
meet that onus. Accordingly, no purpose can be served by conducting any further
hearing into this matter. Therefore, on the basis of the written submissions
received, the grievance is dismissed.
DATED at TORONTO this 11th day of May, 2006.
"Clay Appleton" - I concur
Clay Appleton, Employer Nominee
"Edward E. Seymour" - I concur
Edward E. Seymour, Union Nominee
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