HomeMy WebLinkAbout1990-1938.Jelinek.93-12-20 ?
- ..~~ ONTARIO EMFLOY~SDEt..A COURONNE
~__ ,.~ CROWN EMPLOYEES DE L'ONTARIO
BOARD DES GRIEFS
150 DUNDAS STREET WEST, SUITE 2?00, TORONTO, Ot~TARIO,
t80, RUE DUNDAS OUEST, BUREAU 2100, TORONTO (ONTARIO]. MSC., 1Z8 FACSIMILE/TELEcORIE : (4 ~.6) 326- t396
1938/90
IN THE MATTER OF AN ARBITRATION
Under ,
THE CROWN EMPLOYEES COLLECTIVE BARGAINING AQT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Jelinek)
Grievor
The Crown in Right Of Ontario
(Ministry of Community & Social Services).
Employer
BEFORE ' J. Emrich Vice-Chairperson
M. Lyons Member
H. Roberts Member
FOR THE J. Paul
GRIEVOR GrieVance Officer
Ontario Public Service Employees Union
FOR THE S. Patterson
EMPLOYER Counsel
Legal Services Branch
Management Board Secretariat
HEARING March 11, 1991
June 24, 25, 1991
July 4, 1991
Dece~ber 11, 1991
February 3, 4, 1992
March 6, 1992
April 27, 1992
May 14, 1992
· June 19, 1992
September 11, 1992
January 14, 1993
March 8, 1993
April 19, 1993
Written submissions dated:
July 23, 1993
~. I. INTRODUCTION
On August 29, 1990, the grievor filed a grievance protesting his termination on
August 22, 1990 from his position as Unit Clinical Coordinator classified as Social
Worker 2 in the Secure Custody Program at Syl Apps Youth Centre in Oakvflle, Ontario.
The grlevor had been hired on November 8, 1989 and it is undisputed that when he was
terminated, the grievor'was a probationary employee. His release was-pursuant to
s.22(5) of the Public Service'Act, which provides:
(5) A deputy minister may release from employment any
public servant during the first year of his employment
for failure to meet the requirements of his position.
R.S.O. 1980, c.418, s.22.
The deputy minister may delegate authority to effect a release in accordance with
the provisions of s.23.
23 (1) With the consent in writing of his minister, a deputy
minister may delegate in writing any of his powers.
under this Act to any public servant or any class
· thereof in his ministry.
(2) With the consent of his. minister, a deputy minister
may delegate any of his duties under this Act to any
public servant or any class thereof in his ministry.
R.S.O. 1980, c.418, s.23.
It was common ground that Ms. Lyrme Bullard, Administrator of Thistletown Regional
Centre, had been delegated authority to effect the release. The letter of release is as
follows:
Community and Services sociaux
Social Services et communautaires
Au~ust 20, [990
Mr, J.M. Jelinek
¢/~ ThLstletown Regional Centre
$¥~ Apps Campus
47~ Iroquois Shore Road
Oakville. Ontario
Dear Mr. 3eline~,
Z have received a recommendation and Z have reviewed the facts
regarding your probationary employment with the Ministry as a
social Worker in the Secure Program section of ThistletownRegional
Centre.
Based on my review, I have concluded, that you have failed to mseC
the requirements of the position,
Accordingly, by the authority delegated to me by the Deputy
Minister, I hereby release you from employment for failure to meet
=he requirements of,the po. lcion 'in accordance.with Section 22(5J
of the l~ublic Service Act. Yo~ release ti effective from Tuosda¥,
Au~lls~ 22, 1990.
Please contact Mr. Rick Martin, Manager, Human Resources at
.1210..extention 308, to arrange a meeting to complete your benefits
documents upon separation.
· ._ .....
Lynn~/~ullard /
Administrator
0~20:01 ~'
2
II. - PROCEDURAL ISSUES
During the course of the hearing two issues arose which we were asked to include
in the award.
A) MArch 5, 1992 - Grievor Contact with Chair
On March 5, 1992, the Chair received a telephone call from the grievor seeking
an adjournment of the hearing day scheduled the next day because he wanted to proceed
~with separate representation. The Chair toldthe grievor that he would have to attend
the next day al the hearing and make his request at that time; when all parties would
be present to address his request. The Cha/r telephoned Mr. Paul to advise him that the
grievor had contacted the Chair and to obtain assurance from Mr. Paul that he would be
in attendance at the hearing the next day.
At the opening of the hearing on March 6, 1992, the board convened in camera
with counsel for the parties. Mr. Paul advised the board .that the grievor was
withdrawing his request for separate representation. The Chair recounted the
conversation which had occurred by telephone the previous day Vfith the grievor and
Mr. Paul. The hearing reconvened with everyone present. The panel addressed the
grievor indicating that they understood that the grievor was withdrawing his request and
the grievor indicated his assent. Counsel for the .Employer indicated that he had no
objection to raise. The hearing then resumed.
B) Rt~llng on Scope of Cross-~srnlnation of Orievor
Counsel for the Employer proceeded to ask the ~rievor questions delving into the
circumstances leading up to a memorandum of settlement between the grievor and his
former employer, The Mental Health Centre,' Penetanguishene. The memorandum of
settlement was admitted into evidence and sets forth the terms under which the grievor
resigned his position as a Clinical Social Worker.
Cross-examination concerning the circumstances behind the settlement proceeded
for a series of twenty-two questions when the Union objected to the relevance of further
questioning concerning matters' behind the settlement. Mr. Paul argued ihat the issue
in the case before th~ panel was whether the release of the grievor from his position at
Syl Apps was bona fide and rationally linked to his failure to meet the requirements of
the position. He added that the grievor's resignation from Oakridge at PenetangUishene
upon agreed terms is not related to the issue before the panel in this case. Mr. Paul
pointed out that no issue concerning his termination from Penetanguishene was raised
in opening statement or. at any time as grounds for substantiating the grievor's release
from Syl Apps.
The line of questioning posed to the grievor prior to the point of objection was to
suggest that his former employer was dissatisfied with the grievor's Work. The evidence
that would be put forth by the grievor's former supervisor, Dr. J. MacDonald, amplifying
On performance issues was put to the grievor. The grievor denied the allegations in this
summary of Dr. McDonald's evidence. Counsel for the Employer turned to questioning
the grievor further on his performance appraisals at O~.kridge; at which point the
objection arose.
4
Mr. Patterson argued that his questioning was relevant and admissible on two
grounds. First, the evidence contradicts the grievor's assertions in diredt examination
'that he had a good employment record, gets along well with people, and that he had
never had a problem with supervision like he encountered at Syl Apps. The evidence was
relevant to show whether the grievor's performance at Syl Apps Was an abberation or
not. Secondly, the evidence is relevant and admissible to discredit the grievor's
Credibility since the grievor had testified in direct examination that he had left of his own
accord. Mr. Patterson indicated that he intended to call evidence to show that the
grievor was being pushed out the door and when he was on the cusp of release, the
grievor retained a lawyer, Mr. Lunnie, to negotiate the termination.
At the hearing, the panel recessed to deliberate upon the parties' submissions,
then reconVened to issue the. following oral ruling, which we now confn'm:
"From the outset, the Employer has based its release (~f the grievor
on concerns that are documented in the performance appraisals filed in
evidence and the viva voce evidence we have received that expand upon the
concerns raised therein.
At no time has it been raised as a reason for release of the grievor
that he supported his employment application with a fraudulent Or
misleading previous record of employment or references. Mr. Nesrallah
testified in cross-examination that he and Ms. Donna Close had sat on the
selection panel, but at no time in these proceedings can the panel members
recall that the Employer's 'witnesses were questioned about the sort of
allegations raised now about the grievor's record of employment at
Oakridge. The evidence does not show that these allegations were relied
upon by the Employer at the time the grievor was released. Thus,' to
advance these matters in cross-examination of the grievor today for the
purpose of establishing the nature of the grievor's previous employment
record or that working relationships at Oakridge are similar to the
problems he encountered at Syl Apps mounts to a change in grounds.
This the panel will not permit. At the very least, these concerns should
have been raised earlier with the Employer's Witnesses in chief as being
relevant to the reasons for release. To raise these at this stage of the
5
proceedings seems a prelude to the Employer splitting its case ahd will not
be countenanced.
The grievor's termination at Oskridge is the subject-matter of a
Memorandum of Settlement. Ordinarily, as a policy to promote the efficacy
and finality of such settlements, it is not permitted to go behind such
settlements to ascertain the truth of the matters that otherwise would have
been determined by litigation, but for the settlement. Thus, the panel is
reluctant' to receive evidence about the quality of the grievor's work and
working relationships at Oakridge for the purpose of making i~mdings of
fact about these matters given that they would be of tangential relevance
to the central issues in this case of the quality of the grievor's work and
working relationships at Syl Apps.
The grievor in chief indicated that he had never before been
terminated or fired. He indicated in explaining his previous employment
history that he had changed jobs frequently to follow better opportunities,
enhance his education and career development. The general tenor of his
evidence has been that his working relationship with Mr. Nesrallah was
eXceptionally difficult. In particular, he defends his plans of care as being
in standard form and generally delivered on time. The Employer seeks to
tender the evidence of Dr. MacDonald from'Oakridge to show that the
grievor was on the brink of being £rred, that his work was unsatisfactory,
being not in the form required or 'timely, and that the grievor was
incapable of dealing with a dual reporting relationship in supervision. We
have already indicated why this evidence will not be admitted for
establishing the truth of those allegations. However, the Employer argues
that it could be tendered for the purpose of testing the grievor's credibility.
In cross~examination the grievor has said he would deny most of those
allegations. The problem with receiving this' evidence for the purpose of
assessing the grievor's credibility, is that at'most we would be invited to
infer that'because the grievor may have prevaricated about the nature of
problems he encountered at Oakridge, he is likely to prevaricate about
problems at Syl Apps. We have a wealth of evidence already before us from
witnesses testifying about the nature of the problems that were
encountered by the grievor and by supervision concerning 'the grievor's
work at Syl Apps. From this sort of evidence we shall have a basis from
which to make £mdings on credibility that are central to this issue before
us, rather than tangential. The'prejudice to the grievor is substantial, and'
the time and expense involved to receive the evidence surrounding the
events at Oakridge are excessive for making findings of credibility.
We find that the probatiVe value of this evidence for the purpose of
making findings on credibility to be outweighed by the prejudice, extra
delay, and expense entailed in receiving such evidence~ This is particularly
so when the evidence is about tangential matters and would be
inadmissible to prove the truth of the events.
6
IIi. STANDARD OF ~~
It 'has been argued successfully in other cases that where the statute confers upon
a .designated public servant delegated authority to exercise discretion on a matter, it is
this person who must ensure that all relevant information has been made available and
who must decide whether a recommendation should be accepted. For instance, see G.S.B.
#802/92 OPSEU (Sandman) and The Crown in Right of Ontario (Ministry of Health) and
G.S.B. #577/89 Re OPSEU (Nesbitt) and The Crown in Right of Ontario (Ministry of
Correctional Services). Although the Union raised the .point that Ms. Bullard, the
designated public servant in this'case, did not testify to explain ~he process followed in
reaching the decision to release, the Union did not base its attack of the release on that
ground. Rather, the Union framed i~s case arguing that the decision to release was not
bona fide and that on an objective assessment, the release did not flow log/cally or
rationally from the facts: The parties were agreed that the' appropriate standard of ·
review is stated in G.S.B. #2492/86 Re OPSEU (Sheppard) and The Crown in Right of
Ontario (Ministry of Government Services) (Slone) and followed in G.S.B. 410/88 R_fie
OPSEU (Shaw) and The Crown in Right of Ontario (Ministry of Communitv and Social
Services). After canvassing the Board's earlier jurisprudence in the earlier cases of
Leslie, Fe .rraro, Abdulla andSchiralian, the panel in the Sheppard case summarized the
guidhug pr/nc/pies in the follow/ng way at pp. 14-15:
It can be argued with some logical force that this
Board does not sit as an appeal tribunal from the decision by
a Deputy Minister to release a probationary employee for
failure to meet the requirements of the position. We are not
· entitled to substitute Our assessment of the probationer's job
7
pe~o~.,-mance for that o~ t, he Deputy Minist, er. ~oweYer,
jurisprudence of this Bo~d entitles .us ~ ~view ~a~
ag~s of the ~lease. ~e considerations f~l ~thin t~
somewhat overlapp~g ca~gories:
A. ~ of ~ F~:
If the Employer la~ed g~d faith ~ ~leas~g the
probationa~ employee, then the os~nsible "release" ~1 be
considered actually W have b~n a dismissal, which c~ be
~ieved under Se~ion 18(2)(c) of the Cw~ Employees
Co1~tive B~ga~g Act. Cle~ly the bad faith,'~ fo~d,
must be relatively serious.
B. U~~ble:
~ile this tern is utilized ~ the e~lier d~isions, we
do not t~e it ~ me~ that we ~ review the me,ts of ~he
employ~'s job ~ffom~ce ~d re~s~a~ h~ ~ we fred ~at
the assessment was "~easonable' ~hat the employee had
not meg the ~ob requ~emengs. ~asonablene~s ~ this con~
is a s~cies of g~d faith. ~ereas the phrase. "bad faith"
co~d encompass a release ~pro~rly mo~iva~d or
mEiCiously ~nded, '~easonableness
obj~ive assessment that the release did not flow Io~ly
ra~ionEly ~om the fa~s. If, for exmple, there was s~ply
no evidence ghat a proba~ion~ employ~ had not ~filled or
co~d not ~ffll the job requ~ements, then no mater how
well me~g were the a~ions of his su~dors, the release
wo~d have b~n ~ ~easonable exercise of authority.
C. ~fio~ ~fio~p ~~ ~ Fa~s ~d ~e ~~:
This facgor i~ nearly synonymous' with
"reasonableness." ~ the Employer's assessmen~ ~hat a
ce~a~ set of fa~s justifies release is '~ation~' 0n ~ h~f-
intelligent view of ~he major, then the release becomes a
. ~s~te ~d ~ be reviewed. ~e 'ralionE relationship'
~st shodd not be plaid t~ high. It is easy W br~d as
'~ationE" any thought press or decision ~th whi& one
· d~s not a~. ~e Deputy ~is~r mus~ be free to m~e
decisions, ~thout berg fo~d to have a~d ~a~ion~ly
mealy b~ause a Board of ~bitra~ion might have come W a
d~ferent conclusion.
The Union argued that to support its. decision to release as bona fide and
rationally linked to the facts, the Employer must show that the performance appraisals
which formed the basis for the decision to release were conducted according to the
policies and guidelines set forth in the management manuals for the Ontario Public
Service and for the Ministry. In support of its argument, the Union referred us to the
following cases: Re The Queen in Right of Ontario and Ontario Public Service
Employees' Union et al (1984) 45 O.R. (2d) 361 (Ont. Div. Ct.); G.S.B. #372~84 Re OPSEU
(Ruvert) and The Crown in Right of Ontari(~ (Ministry of Correctional Services~ (G0rsky)i
G.S'.B. #440/82 Re OPSEU (Black) and The Crown in Right. of Ontario (Ministry. of
Revenue) (Joliffe); G.S.B. #0389/88 Re OPSEU ('r]awley_) and The Crown in Right of
Ontario (Ministry of Natural Resources) (Dissanayake); and G.S.B. #729/90 Re OPSEU
(Agboka) and The Crown in Right of Ontario (Ministry of Revenue) (Fisher).
On behalf of the Employer, it was argued that it constitutes an improper change
in grounds and is too late for the grievor to impugn the performance appraisals that led
to.his release. In any event, the Employer argues that even ff there was technical non-
compliance .with guidelines for appraisal, contained in the~ Ontario Manual of
Administration, such non-compliance does not vitiate the decision to release. The
appraisal process met the concerns and objectives of the process, and the grievor was
made aware early on and .throughout his probationary period Of the deficiencies..
management had identified in his work, clinical judgement, and professional conduct.
In support of his argument, Mr. Patterson referred us to the Hawley case at p.18:
9
Counsel for the Employer is correct to the extent that
the Board will not require technical compliance with the
written words. Nevertheless these policies have a rationale
and a purpose. If the Employer can satisfy us that the
rationale and purpose of the written policies were achieved by
some' alternate procedure, the Board is less likely to be
concerned. Nor are we concerned unduly about the use of the
memo format in place of the appraisal forms issued by the
government. What is important is that the process of
appraisal used must be such that the Board can be satisfied
that the concerns and objectives of the written policy have
been met.
Furthermore, counsel for the Employer referred us to G.S.B. 739/91 Re OPSEU
kq?ox) and The Crown in Right 'of Ontario (Ministry of Correctional Services)
(Dissanayake) as authority for the proposition that only deficiencies, in the supervision
process which seriously impede the grievor's performance and ability to meet the job
requirements are relevant. Mr. Patterson argued that the Fox case supported the view
that the Board must take into account the nature of the. position held by the
probationary employee and the education and qualifications brought to the' position by
the probationer when reviewing the evidence. He referred us to pp.19-20 of Fox~ decision:
We observe £trst of all that the role of the board in a
grievance challenging the release of a probationary employee
is not to scrutinize the employer's' conduct to see whether
there were deficiencies in the way the em. ployee was trained,
supervised, and directed. It will be a rare case indeed where
such deficiencies cannot be pointed out. For management
deficiencies to' be relevant, it must be clear that those
seriously impeded the grievor's performance and ability to
meet the job requirements. The grievor pointed out many
shortcomings in the'management practices which are
irrelevant on this basis, For example, the failure to provide
the grievor with a copy of her job description, the failure to
provide formal feedback other than by way of written
comments on her drafts, the failure to perform formal
performance appraisals. We agree that it would have been
10
preferable if those things were done. However, the failure to
do those is of .no significance for purposes of deciding this
case unless it can be shown that they seriously impacted
upon the grievor's' performance.
The second observation we make is that in reviewing
the evidence, the Board must take into account, the nature of
the position held by the probationary employee. This is
particularly so in reviewing the evidence relating to training,
supervision and direction, and feedback. The level of
supervision, direction and feedback that may be deemed as
reasonable must depend on the sophistication of the position.
For example, an incumbent with a minimal education
occupying a clerical position may reasonably expect his
supervisors to provide extensive training, to closely supervise
him, and to give detailed directions and feedback. On the
other hand, where the position by its very nature envisages
a highly qualified and sophisticated incumbent, the Employer
is entitled to. expect the employee to work on his own
initiative and independently, with minimal training,
direction, and feedback.
We adopt the standard of review articulated in the Sheppard and Shaw cases
articulated above, we also agree that deficiencies found in the training, supervision; and
direction of the grievor must be shown to have seriously affected the grievor's ability to
meet the job requirements. We do not find that the fact that the grievor's office was not
in the cottage for a number of months significantly affected the grievor's ability to meet
job requirements. There is a continuous log of activities kept on the cottage. There are
daily issues meetings at the cottage and frequent mini-team meetings and an internal
mail system by which the griev0r could keep apprised of events and incidents.
Furthermore, we do not find that differing philosophies of treatment as identified in Dr.
Keeling's testimony and commented upon in Ms. Parker's testimony played a significant
role or impacted Seriously on the grievor's ability to meet the job requirements. Nor do
11
we find that the grievor was given such inadequate orientation to the position that he
was not aware of the requirements of his role as Unit Clinical Coordinator.
IV. 'REVIEW OF THE BASIS FOR ~E
The panel heard extensive evidence during the course of many days over a period
of two years. On behalf of the Employer, we heard evidence from the grievor's immediate
supervisor on administrative issues, Mr. Douglas Nesrallah, Program Manager, Secure
Custody, and from his immediate supervisor on clinical issues, Ms. Donna Close.~ We
heard as well from Ms. Beverley Parker, Director, Secure Programs at Syl Apps Youth
Centre. On behalf of the grievor, we heard evidence from the grievor, from another Unit
Clinical Coordinator at Syl Apps, Marg Simmons, and from Dr. Kenneth Keeling, Senior
Psychologist at Syl Apps Youth.
Ms. Bullard did not testify. The basis upon' which management acted was
provided by testimony from Ms. Beverley Parker and from Mr. Nesrallah. By
memorandum, dated July 31, 1990, Ms. Parker indicated to Ms. Bullard her support for
Mr. Nesrallah's recommendation for termination of the grievor.
12
-memorandum '®
To: Lynne BuLt~r~ O~e: ~u17 3~, 1990
Director. Thistletown ~e~an~ Centre
Copy: ~ck M~
F~m: Beverley J. P~ker ~ug Nesr~ah
D, rec~or ~ Secu~
~yl Apps C~pus
._ Re:. Jay Je~ek Perform~ce A~pr~s~_
! enclose copie~ of Performance Appraisals '(three) as well as memoratldu~
summarizing appraisal issues regarding Jay Jelinek.
I .have met with Mr. Jelinek, Doug Nesrallah and Rober~a Roberts, as~
s~nior soc~al'wor~ consultant, to go over these issues, and I support
Doug Nesrai!ah's recommendation for terminat/on.
The matter has been d/scussecl with Human Rcsources and has 3tick, ~arth3's
approval. Because the matter has been dealt w~th just prior to .the begitlning
of your vacation, there Will be some urgency to this upon your ~eturn;a~
Mr, JeLinek knows the meoommenclat~on has been made.
Beverley. J. Ps~.qa~
BJP:JC
In her testimony surrounding this step in the process, Ms. parker indicated that
the first three performance appraisals were forwarded to Ms. Butlard, but not the fourth
and i%al appraisal. At Ms. Parker's request, Mr. Nesrallah prepared a memorandum
summarizing the performance issues that had been identified in respect to the grievor's
work.
13
memorandum
To: Beverley J. Parker Date: July 26. 1990
Director, Secure Programs
From: Douglas O. Nesrallah
Program Manager
Re: Supervision issues Regagding Jay Jelinek
Covering the Period December 1, 1989 to Jul3f 24, 1990. Inclusive
~lnce the time of Mr. Jelinek's employment here at Syl App$ Campus
(Nevember 8, 1989, date of commencement), there have been numerous
and consistent .supervision issues, A brief summary of these issues
follow s:
o Difficulties with Unit Supervisor, Flora Lamont (his Unit
Supervisor at that time). Concerns identified having to do
with Jay's difficulty in focusing on the issues and respon(ling.
directly to issues, or questions presented to him; and his
-difficulty in hearing residents and staff when they addressed ..
him; and the general question of his unfocused style. Three
meetings were held in all.
o December 14, 1~$9: Concerns regarding JaY's style - he
digresses, his style is florid, he provides extraneous information.
Note from Flora in my Supervision Log that Jay is. "running
around like a crazy person" and driving her crazy.
o January 4, 1990: I identified f~r Jay that. Plans of Care and
the way they are written would become the topic of Supervision
for the two of us. Further discussion - .Jay overworks issues
generally, and changing meetings when previously advised not
to change meeting dates ~.ucl times.
o January'2~, 2990: ! met with Jay regarding my concern that
Jay was developing a,habit of pointing out how we were not
following through on Policy, versus actually doing the clinical
work I was hoping he wou~d get at (for example, during Incident
Reviews.
~ebruary 2, 1990': 'There was a huge confusion over a.discharge
conference that should have been a review conference for a
resident, and Jay had come to me about re-scheduling the meeting.
February 12, 1990: ~ray still raised issues with regard to FIora'
and I referred him back to he~. I identified performance issues
during this meeting that we would be looking at on a regular
basis over the next several months as part of the performance
appraisal process. I expressed concern how his evolving
relationship with Flora would directly impact on the quality of
care the kicis in Cottage 3 were receiving.
14
Beverley 3. Parker
July 28, 1990
Page 2
o February 27, 1990: Jay..advised that he was dissatisfied with
his fi~r. st performance appraisal.
February 21 & 22, 1990: Regarding two of Jay's conferences
around residents. Both notes have to do with vague presentations,
generally weak presentations, and Jay's overall poor delivery.
o March 15, 1990:' I helped Jay formulate goals for treatment plan.
) Jay seemed unable to comprehend or grasp the direction we were
going, in with these treatment goals.
,~o March 19, 1990: Discussion with Jay on the matter of priori{izing
his time in order to get the Plans of Care done in a reasonable
'time frame.
.o March 21, 1990: I noted ongoing issues with regards to Plans Of
C are.
· ' ~ April 3, 1990: Difficult supervision session. My question during'
this meeting was:' Could Jay demonstrate that he could Carry out ..
his role as Unit Clinical Coordinator as outlined in the program
description.- ss contrasted previously? Jay disagreed with me
that he has not been carrying out his role - and he felt he was
carrying out his role effectively.
ApriI 19, 1990: I expressed serious concerns regarding the
clinical input around' discharge planning for a resident.
Jay disagreed. -'
May 7, 1990: I reviewed reports with' Jay and went over goals.
for each of them. These involved five different residents.
o June 15, 1990: Discussion with J.ay took place regarding how a
Treatment Plan should be written. We discussed style and length.
During this meeting, I spoke with 3aY around his credibility
on the team. He indicated to me that I needed to be more specific .
when I had such concerns.
o July 12, 1990: I discussed issues with Jay regarding an Incident
Review and Plan of Care with a resident. Jay disagreed with my ·
'position. Also discussed was the fact that Jay went home sick
· on the afternoon we were having supervision, and left me a note
saying he would be off the following day for vacation.
July 12, 1990: Last note that Jay was telephoning Beverley
Parker to advise her of his health status, rather than calling me.
Douglas O. Nesrallah
DON:JC
15
· The grievor prepared written addenda to respond to the criticisms of his work
contained in the first three performance appraisals.. Ms. Parker testified that she had
forwarded the grievor's addenda to Ms. Bullard, but her evidence was not unqualified.
In cross-examination, she stated that she assumed that they had been attached to the
grievor's first three performance evaluations. The suggestion wa~ put to her that the
addenda were not attached to the performance appraisals in the grievors' personnel
She responded that was possible, but she did not know why the addenda would not be
fried with the performance appraisals. There was no evidence from personnel in Human
Resources having custody of the grievor's personnel file to clarify this point, nor evidence
from Ms. Bullard to clarify what material had been received and considered-by her in
reaching the decision to release the grievor.
Ms. Parker indicated, that following the grievor's third performance appraisal,
dated May 24, 1990, the grievor spoke to Ms. Parker requesting a meeting to address his
response to Mr. Nesrallah's supervision issues and to have' an objective impartial social
work professional in attendance. The grievor's request was dated June 15, 1990 and was
fQed in evidence: memorandum ®
~'.~,. o~, ....
TO: Beverley J. Parker oate: June [5, 1990
Director, Secure Programs.
I received your memo this afternoon,
My objective or goal'was to have an impartial review of all relevant
circumstances as they concern my employment.
..
The reason for my suggestion is my belief that my previous comments
and reflections'put me in jeopardy and produced treatment of my person
I consider unacceptable.
To accomplish the objective [ suggested an impartial external profes-
sional person. An example of such a person was Mr. Sheehan with whom
I have not dealt personally. There was an alternate sug~estion'made
by you.
I am prepared to provide additional oral and written comments on
all aspects of'the situation.
M. Jay Jeiinek
16
A meeting was held on July 4, 1990 at which the grievor, Ms. Parker,
Mr. Nesrailah, and Dr. Roberta Roberts were present. Dr. Roberta Roberts was the
senior social work consultant at Thistletown. She attended at the~ invitation of
Ms. Parker. Ms. Parker had suggested Dr. Roberts as a suitable external professional.
In his evidence, the grievor indicated that he had wanted Donna Close, his clinical
supervisor, to be in attendance. His memorandum of June 15, 1990 does not make such
a suggestion. Furthermore, Ms. Parker recalled clearly that the grievor was requesting
an uninvolved professional to be'in attendance. By this time, Donna Close had not b~en
providing much supervision to the grievor, but had allowed Mr. Nesrallah to fulfill that
function. The grlevor had tried several times unsuccessfully to reach Donna Close for
supervision after the early Spring of 1990 and had become frustrated with her
preoccupation with other work. We prefer the evidence of Ms. Parker on this point, that
the grieVor did not request Donna Close to attend the July 4th meeting. In any event,
she did not attend.
Ms. Parker agreed, in cross-examination, that the grievor's addenda to his
performance appraisals raised serious allegations in respect to the working relationship
between the grievor and the Unit Supervisor, Ms. Lamont, regarding inadequate clinical
supervision he had received from Ms. Close, and concerning the supervision style and
hostile attitude Of Mr. Nesrallah.
Ms. Parker stated in chief, and in cross-examination, that the reason for the July
4th meeting· was to address the concerns raised in the grievor's addenda and to speak
about the supervision process. The meeting was not held to discuss thel· grievor's'
termination. Prior to and at the meeting, Ms. Parker advised the grievor that everyone
17
had reviewed his addenda, yet the grievor spent nearly the entire hour .reading his
addenda to those present. A few questions in clarification were posed .to the grievor and
the meeting ended. Ms. Parker testified that she took no action to address the grievor's
concerns and she agreed that the grievor's concerns went unresolved. She stated that
she did not perceive the grievor's Problems to be specifically related to Mr. Nesrallah,
Ms.' Close, or Ms. Lamont; rather, the deficiencies identified with respect to the grievor's
suitability had.to do with his ability ~o function as a Unit Clinical Coordinator and his
ability to grasp plans of care. Throughout the supervision process and up to the point
that she wrote to Ms. Bullard supporting Mr. Nesrallah's' recommendation to release the
grievor, Ms. Parker did not deal directly with the grievor.. She was content to. advise
Mr. Nesrallah concerning the depth and focus of his supervision of the grievor and she
referred Mr. Nesrallah to the Human Resources Department once she became aware in
May that Mr. Nesrallah was considering the possibility of release. She admitted in cross-
.examination that she did not know that Mr. Nesrallah had not reviewed the performance
appraisals and the grievor's addenda with the grievor. She further admitted that she
was not aware that Mr. Nesrallah had not discussed with the grievor the impending
decision to release following the July 4, 1990 meeting. Mr. Nesrallah's recommendation
concerning release was contained in the fourth' performance appraisal. She further
acknowledged in cross-examination that she did not know upon what information
Ms. Bullard acted in reaching the decision'to release the grievor, other than the material
which Ms. Parker forwarded to her with her 'memorandum of July 31~ 1990. Other than
acknowledging that at some point she may have suggested that the grievor speak to
Dr. Roberta Roberts about a transfer, Ms. Parker took no steps to investigate the facts
further or to consider options other than release, follo ~wing the meeting of July 4, 1990.
We find this inaCtion on the part of Ms. Parker remarkable given that she
admitted in cross-examination that the tone and content of the performance appraisals
were not in accordance with policies and guidelines for ~ppraisals of probationary
employees. Ms. Parker acknowledged in cross-examination that' she would not have
adopted the format used. The content of the grievo'r's addenda made it clear that the
grievor and Mr. Nesrallah had become embroiled in a deleterious and emotionally
charged relationship.. Ms. Parker seemed to be aware that Donna Close had ceased
providing much active clinical supervision of the grievor since early Spring 1990, yet she
agreed in cross-examination that it would not be usual for clinical supervision to cease
because Mr. Nesrallah was providing supervision on administrative-matters.
Furthermore, she perceived that weaknesses identified in the grievor's performance were
related to clinical issues. Ms. parker admitted in cross-examination that the first three
months of supervision should have been formal with goals and objective parameters set
as performance standards for the grievor. Yet the evidence of Mr. Nesrallah was that
such a process was not followed in the initial months following the grievor's hire; rather,
the grievor's supervision was informal in that time frame.
We find that the omission Of Donna Close 5o Provide continuing clinical
supervision to the grievor throughout his probationary period, the omission of
Mr. Nesrallah to set up objective performance goals in consultation with the griev0r at
the outset, and the omission of Ms. Parker to take steps to defuse the escalating conflict
between the grievor and Mr. 'Nesrallah had a significant impact on the grievor's ability
to meet the requirements of his position.
Ms. Parker admitted in cross-examination that Mr. Nesrallah's recommendation
carried great weight in the process to release the grievor~ Furthermore, the evidence
revealed that Ms. Builard, who was charged with authority to make the decision to
release the grievor, lacked relevant information at the time of making her decisionl
Finally, the witnesses who testified indicated that they'were not aware of any
investigation or review of the facts conducted by Ms. Bullard. Furthermore, none of the
witnesses knew the basis upon which Ms. Bullard acted, other than the material
fox-warded to her with Ms. Parker's memorandum of July 31, 1990. Indeed, counsel for
the Employer characterized Ms. Bullard's action as "rubber-stamping" the decisions of
Mr. Nesrallah and Ms. Parker.
The role of the Unit Clinical Coordinator is set forth in a document entitled Secure
Custody/Detention Program DesCription, Thistletown Regional Centre, Syl ApPs Campus,
dated March 8, 1989 at pp. 14-15: ·
Hole of the Unit Clinical Coor~instor
The Unit Clinical' Coordinator's role is to facilitate the
identification of clinical needs of residents and response to .
those needs while in the program. The assessment process,
begins at the point of admission and continues throughout
the duration of the resident's stay. The provision of service
will, where appropriate, .be ex~nded to family members,
guardians or significant others~ inasmuch as the well-being
of each resident is seen to be contingent upon the well-being
of the family Or system of reference for the resident.
The Unit Clinical Coordinator will also work in dose
collaboration with the Unit Supervisor to ensure the smooth
delivery of all clinical and operational aspects of the Secure
program.
2O
The Unit Clinical Coordinator will also be responsible
for: .,
1. Develops~ coordinates and im~olements individualized
treatment/intervention plans (Plans of Care)
· Ongoing consultation with cottage staff regarding
clinical issues pertinent to residents in program.
· To encourage relevant community agencies to
participate and give input to regular conferences as
well as follbw-up on treatment plans decided upon.
· Working closely with Prime Workers and cottage
staff in developing, monitoring, and amending
individual programs for residents on ongoing basis
between conferences.
· Liaising with (and begin to make contact with)
and/or referrals to community based agencies,
where applicable.
· Involving/consultingwithresident, family/guardian,
significant others, Probation Officer, etc. with a
view to planning, obtaining input re appropriate .
post-secure placement.
2. Does individual, family, and grouv counselling
· Involvement through counselling with individual
clients and their families when warranted.
· Leading residents' group meetings.
3. Acts as a clinical resource for the unit orogram team
and the facility
· . Ensuring .that relevant Clinical information is
· shared with all staff members in order to respond
better to residents' needs while in Secure
Detention/Custody.
· Participate in staff training and development in
clinical· areas.
4. Contributes to the design, implementation, and
maintenance of the therapeutic environment
· Participation in any meetings which pertain to
planning for residents during their stay in Secure
Detention/Custody.
· . Participate in Clinical Management meetings.
21
Both Mr. Nesrallah and Ms. Parker identified this'description as aCCurately
describing the job and Ms. Parker indicated that it was more accurate than the position
specification. This document was provided to the grievor at orientation.
The evidence revealed that Ms..Close abdicated her role in providing clinical
supervision to the grievor certainly by March 1990, if not sooner. On the grievor's
~stimony, she bowed' out of meaningful contact with the grievor as of January or
February 1990, apart from a joint supervisory session in March or April 1990 in respect
towr/ting plans of care and plan of care review reports. Ms. Close testified that she was
involved With the grievor up to March or April 1990.because she was able to recall her
participation in a joint supervisory session of the grievor with Mr. Nesrallah around that
time. The evidence of Marg Simmons, another Unit Clinical Coordinator, emphasized
that a close supervisory relationship with Ms. Close was of invaluable assistance in
carrying out the role of Unit Clinical Coordinator.' We reiterate our conclusion that the
abdiCation by Ms. Close of her supervisory function in respect to the grievor seriously
impaired his ability to perform and meet the job requirements.
It is clear that the opinion formed of the grievor by Mr. Nesrallah played the
pivotal role in the process leading to the gr/evor's rele~se. We heard extensive evidence
surrounding the supervisory sessions held by Mr. Nesrallah with the grievor. 'We heard
extensive evidence from Mr. Nesrallah and the grievor concerning the content of the
supervisory notes, the performance .appraisals and addenda, and the incidents referred
to as examples in those documents.
Counsel for the Employer character/zed the problems w/th the grievor's
performance which emerged from the evidence as falling within four areas: 1) 'the
inability or refusal of the grievor to take ownership 'of issues .coming within his
responsibility; 2) the apparent inability of th~ grievor to identify, synthesize and
communicate Clearly, to provide focus upon important clinical issues at meetings and to
members of the multi-disciplinary team; 3) the difficulties the grievor manifested in
writing reports' such as the plan of care ~and plan of care review; and 4) problematic
· aspects of the grievorts clinical judgement and professional condUct. It would take a tome
to detail each instance touched upon in evidence as examples of these problems, but we
shall highlight examples in order to illustrate our conclusions in respect to the four areas
in turn.
1) Own p
In his testimony and in the performance appraisals and supervision notes fried,
Mr. Nesrallah criticized the grievor for a propensity to avoid responsibility for resolving
problems with co-workers such as Flora Lamont, the Unit Supervisor, and Joan Barton,
the Programme Secretary. It was clearly a source of irritation and frustration for
Mr. Nesrallah that Mr. Jelinek would raise complaints about the quality and timeliness
of Joan Barton's work without raising those concerns directly with her. Mr. Nesrallah's
response to the grievor's complaints was to refer the grievor back to the secretary
directly. The evidence indicated, as does the memorandum of Ms. Parker dated
November 14, 1989, that Joan Barton had been temporarily assigned as secretary to the
Secure Custody Programme in November 1989, around the same time that Mr. Jelinek
began work at Syl Apps. Ms. Marg Simmons, 'a Unit Clinical Coordinator who was hired
in March 1990 to work in Cottage 2, testified that she had encountered continuing
23
problems with the quality and timeliness of Ms. Barton's secretarial service and she
could recall mentioning this to Mr. Nesrallah on one occasion. The problems that
Mr. Nesrallah noted in respect to Joan Barton and the grievor are not mentioned after
the first performance appraisal. It was part of Ms. Barton's responsibility to schedule
meetings and it was the evidence of both Ms. Simmons and the grievor that she did not
take 'direction from them readily concerning scheduling of meetings or the quality 'and
tfrneliness of her work. Unit Clinical Coordinators have no line supervision responsibility
-over the programme secretary, but the programme manager does. We find that it was
neither fair nor realistic for Mr. Nesrallah to expect any continuing problem with the
quality of Ms. Barton's secretarial work to be dealt with by the grievor alone without
intervention or direction from Mr. Nesrallah to the programme secretary. Indeed,
Mr. Nesrallah in cross-examination denied that there were any problems with
Ms. Barton's work, despite complaints from the grievor and Marg Simmons. We' fred that
Mr. Nesrallah abdicated his supervisory role in respect to Ms. Barton and blamed the
grievor for the problems encountered. However, we fred that'the problems with
Ms. Barton are not mentioned after the first performance appraisal and are not
mentioned in Mr. Nesrallah's memo of July 26, 1990 to Ms. Parker. We therefore fmd
.that this deficiency in handling the situation by Mr. Nesrallah did not significantly
impact upon the grievor.
There were continuing problems noted in the supervision notes and in the first two
performance appraisals with the working relationship between the grievor and the acting
Unit Supervisor, Flora Lamont. Prior to the grievor's hire on November 8, 1'989,
Ms. Lamont had been carry/ng out her responsibilities for her acting appointment as well
24
as some of the responsibilities of Unit Clinical Coordinator for the residents in Cottage
3 due to a critical shortage of staff. She was an unsuccessful candidate in the
competition for a permanent position as Unit Supervisor and left Syl ApPs around March
1990. The grievor found that Ms. Lamont was not cooperative or commUnicative with
him concerning clinical issues for residents whom she had been handling prior to
Mr. Jelinek's appointment. The role conflict is noted in Mr. Nesrallah's supervision notes
on January 29, 1990, and he notes that the grievor agreed to approach Ms. Lamont to
set up regular meetings or sessions to review and update the grievor on cases as a means
to minimize the communication gap. In the performance appraisal of March 23, 1990,
Mr. Nesrallah noted that the role conflict problem had subsided and in his supervision
notes for January 29, 1990, and in his testimony he noted that Jay and Flora had
reported to him that they were resolving issues between them. In any event, by ~he time
Mike Brown is appointed as Unit Supervisor, the problem of role conflict is not pursued
in the performance appraisals and the evidence indicates that there was a satisfactory
working relationship between the grievor and the new Unig Supervisor. We'fmd that it
was neither fair nor realistic to saddle the grievor with' all the blame for the role conflict
with Ms. Lamont. Once Mr. Nesrallah had instructed~both the grievor and Ms. Lamont
unequivocally to work Out their problems with each other, without his intervention, the
problems seemed to subside. The evidence did not indicate that there was a Continuing
problem of role conflict between the grievor and the Unit Supervisor through to the point
that the grievor Was released. However, the role conflict with Ms. Lamont is relied upon
by Mr. Nesrallah in his July 26th memorandum to justify the grievor's release. We fred
that Mr. Nesrallah's criticism of the grievor on this issue had a. significant adverse
25
impact upon the grievor. Mr. Nesral~ah did not act in an objective or even-handed
manner. He clearly was irritated by the grievorts conduct and empathized with
Ms. Lamont. On an objective assessment, both the grievor and Ms. Lamont participated
in role conflict. Mr. Nesrallah did not appear to credit the grievor for achieving a
satisfactory working relationship with Mr. Brown.
The major example offered of the grievor failing to assume responsibility for his
mistakes occurred when Flora Lamont assigned to one of the.prime workers in Cotgage
3, Rob Lister, the task of preparing a behaviourial summary, on 'a resident.
Mr. Nesrallah explained that the residentts probation officer, .Mr. Beauchamp, had
requested Ms. Lamont to have the report prepared in time for a court appearance ~he
following week. Ms. Lamont was absent on the Thursday and Friday of the week the
report was assigned, so Rob Lister approached the grievor to review the draf~ report he
had prepared. The grievor, on reviewing'the draft, judged that tl~e clinical contex~ and
issues needed to be developed to a greater extent. The grievor offered ~o assist in the
writing of the report. In the result, the report was not ready 'at the time arranged and
Ms. Lamont became furious with the grievor. She berated the grievor directly; and
complained to Mr. Nesrallah about the grievor's interference. For his part, the gi*ievor
felt that he had been by-passed by Flora Lamont concerning the probation officer's
request for a clinical report on a resident in his Cottage. In his supervision notes of
January 29, 1990, Mr. Nesrallah faulted the grievor ~for not checking back with
Ms. Lamont concerning what sor~ of repor~ was required and when. In his testimony,
Mr. Nesrallah acknowledged that he became angry with the grievor about this issue and
empathized with' Ms. Lamont's irritation. He testified that he told ihe grievor ghat since
26
only a behaviourial summary had been requested and the probation officer was fully
apprised of the clinical issues with respect to the resident, it was appropriate for the
request to have been channelled to' Ms. Lamont. Furthermore, he told the grievor that
he should ha~e referred the prime worker back to Ms. Lamont for further direction or in
her absence, checked with Mr. Nesrallah. From his response in the addendum to the
£~rst performance appraisal and from his testimony, it is apparent that the grievor
understood this incident as a role conflict with Ms. Lam°nt and that he had been
.unfairly criticized for offering assistance to a prime worker, a duty contained in his role
description. We fred that it was a reasonable expectation on the part of Mr. Nesrallal~
that the grievor should have ascertained the nature of the report required and whether
there was a deadline to be met. The grievor's testimony and written response show that
he did not accept responsibility for any error on his part in this matter. In the next
section we shall review the evidence pertaining to the ability of the grievor to identify,
synthesize, and communicate clearly clinical issues in respect to residents. The
"ownership" issue overlaps into this area as well.
2) Identification, Synthesis, and Clear Communication of Cliaical Issues - Focus
As early as December 14, 1989, Mr. Nesrallah began to note that the grievor had
a propensity to digress, provide extraneous information, and use a florid style when
communicating clinical issues in respect to residents. By JanUary, Mr. Nesrallah
observed that the grievor's problems stemmed from his approach to identifying clinical
issues, .as well as from' the manner in which the grievor communicated such issues.
Mr. Nesrallah' made notes to this effect on January 17, 1990, and on February 21, 1990
27
with respect to the grievor's presentation, at a plan of care meeting in respect to resident
T.N.; on February. 22, 1990 concerning a plan of care meeting for resident S.G., at which
a probat, ion officer was noted' to ask the grievor what point the grievor was trying to
make. On February 28, 1990, Mr. Nesrallah noted a comment made by the grievor at
'a meeting concerning the admission of resident H.B. suggesting a'behaviourist approach
to treatment ·that would train the resident like mice. On March 21, 1990, at a plan of
care meeting in respect to K.G., Mr. Nesrallah noted that the grievor had undermined:
his own'clinical approach by supporting the behaviourist approach suggested by the
youth workers concerning refusal of writing materials ix) the resident at bedtime when
she was .most anxious. Earlier, on March 12, 1990, Mr. Nesrallah criticized the grievor
for requesting that the same resident, K.G., refrain from sexual intercourse during the
term of"her stay. Mr.. Nesrallah characterized the grievor's requirement as a sexist
contract., that ignored the underlying clinical issues for the resident whose past history
of abus~ was conducive to sexual 'acting-out. On March 23, 1990, Mr. Nesrallah noted
that at a team meeting concerning resident S.G., the grievor was asked by a team
'membe~ to explain what he meant by the phrase that the resident "used sex as a
transitional object." Mr. Nesrallah noted that the grievor became flustered and
embarrdssed and was unable to provide a dear, concise response understandable to both
~clinicians and lay-person members' of the team. In respect to resident S.G.,
Mr. Neskallah noted that the grievor handled inappropriately the resident's request for
a temporary release, which request was supported by the resident's probation officer.
The plan of care for this resident had stipulated that he obtain a psychiatric assessment
and be assessed for substance abuse because at the time of admission he had manifested
28
psychotic episodes. The plan of care had recommended ·that there be no temporary
releases sUpported until after the appropriate assessments had been conducted. The
grievor took the position at the meeting and in discussion with Mr. Nesrallah that the
temporary release should be supported. At the hearing;. ~he grievor reiterated his view
that as a matter of law, the resident was entitled to apply for a temporaryrelease. We
fred that the griev°r at tl~e time and at the hearing seems to have missed the point.
Regardless of whether the resident was entitled'in law to apply for the temporary
release, the Crucial clinical decision was whether the clinicians at Syl Apps would
officially support or recommend denial of the request to the Provincial Director.
Furthermore, Mr. Nesrallah noted that the gri-evor at the trine attributed the problem
to an omission by management to make the temporary release policy clear to him at an
earlier point in time. Yet, at another point in his testimony, the grievor suggested that
he had been surprised that the release was granted by the Provincial Director.
On April 11 and 19, 1990, Mr. Nesrallah noted concerns with the
inappropriateness of the discharge planning conducted by the grievor in respect to
resident J.L. The plan supported by the grievor and the resident's case manager was to
discharge the resident to live with his mother in six weeks' time. The resident had not
lived with his mother for approximately two years. He had a violent history and had'
attempted to strangle a case worker at ~a group home, which had led to his admission to
'Syl Apps for six months. The grievor had not ensured that there was representation or
reports from the resident's school or from his play .therapist. In Mr. Nesrallah's view,
given that the resident's mother lived in a batchelor apartment, on social assistance, and
29
given the treatment goals in the plan of care, discharge to a therapeutic ~etting would
have been more appropriate and consistent.
On April 19,' 1990, Mr. Nesral]ah noted a meeting with the grievor relating to
resident C.S., a pyromaniac with sexual identity problems. Mr. Nesrallah was critical
of the way in which the grievor had identified and communicated the clinical issues for
this resident. In direct examination, Mr. Nesrallah explained that.the grievor had failed
to prepare the resident and failed to communicate at the plan of care conference that the
pyromania related to sexual dysfunction. Another relevant issue to the question Of
sexual dysfunction and gender identity was whether the resident's involvement with a
known homosexual as his caseworker was appropriate in the circumstances, in direct
examination, Mr. Nesrallah characterized the grievor's presentation of the case as "an
'overly conscientious boy, with a single mother, With poor parenting skills, and who
happened to be a fire-setter." In cross-examination, Mr. Nesrallah recalled that this
supervisory session was very difficult and that he had yelled at the grievor.
Mr. Nesrallah also acknowledged that he had had a difficult supervisory session w/th the
grievor on ApriI 3, 1990 and yelled at him then too. The grievor recalled the April 19th
meeting as being difficult and that Mr. Nesrallah yelled at him, although the grievor
understood that Mr. Nesrallah was mad at h'im simply because he had relayed the
concerns of the cottage staff concerning whether C.S. should have a case manager who
was effeminate. In chief, the grievor's evidence suggested that he did not express any
personal opinion about the propriety of the assignment. In cross-examination, the
grievor retorted that even if he disagreed with the propriety of tl~e assignment,
Mr. Nesrallah ought not to have abused his authority by behaving the way he did ~ i.e.,
yelling at the grievor.
In June, Mr. Nesrallah met with the grievor and Mike Brown, the Unit
Supervisor, to discuss issues the cottage staff had raised concerning the grievor's style
and delivery which wei, e affecting his credibility with the team. Mr. Nesrallah suggested
that the grievor meet with the cottage staff to confront them' about such allegations at
a subsequent team meeting, However, Mr. Nesrallah acknowledged that this step would
be difficult and he was not surprised that the grievor chose not to'do so.. On June 20,
1'990, Mr. Nesrallah nOted that the grievor's presentation at Plan of care conferences for
residents S.B. and RN. did not clearly identify or communicate the underlying clinical
issues.
On July 5, 1990, .during a plan of care review for resident K.G., Mr. Nesratlah
noted that the style of the grievor's presentation was not conducive ~ .discussion of
clinical issues. He noted that the grievor raised the concept of rewarding her
misbehaviour. Mr. Nesrallah took issue with the grievor's approach as being opposed to
the programme's philosophy. By this time~ the meeting with Beverley Parker had taken
place and the relationship between the grievor and Mr. Nesrallah was so strained that
little meaningful communication occurred between them directly.
The grievor, in his evidence, denied that the supervision he received from
Mr. Nesrallah amounted to coaching, a~sistance, or training. He indicated that
Mr. Nesrallah's attitude toward him changed remarkably after the conflict with
Ms. Lamont at the end of January 1990 over the grievor's offer to help the prime worker,
Rob Lister, prepare a report on a resident. He supported his view in' chief by asserting
· - 31
that at the July 4th meeting. "Mr. Nesrallah didn't Object to the suggest.ion that his
attitude had changed" after the Rob Lister case report problem with Flora Lamont. In
cross-examination and from the other evidence, we f'md that although Mr. Nesrallah may
have clarified some aspects covered in the grievor's addenda, the JUly 4th meeting did.
not lead to much discussion: Mr. Nesrallah, as did other members of supervision, chose
to remain silent, even if they disagreed With the content of the addenda. Apparently'the
grievor interpreted Mr. Nesrallah's silence on this point as tacit assent.
For the first three months following his hire in November, the grievor
characterized his supervision as informal, .with no criticisms of his report writing, or of
other aspects of his performance. The grievor, after repeated questioning, eventually
acknowledged that there was a meeting with Mr. Nesrallah in February when
Mr. Nesrallah reviewed some matters of concern prior t~ receipt of his first performance
appraisal. He acknowledged that he had received some orientation, although he
disagreed with Mr. Nesral]ah as its extent.' .He acknowledged that he had requested a
copy of the policies and procedures manual and received it to review prior to December.
He acknowledged that he received a copy of guidelines for clinical report writing from
Donna Close before January and from Mr. Nesrallah in March or April. He
acknowledged that he had regular supervision from Ms. Close each week on Friday up
to January during which they discussed clinical issues and aspects of his role: We f'md
that given the grievor's lengthy clinical experience and academic qualifications, the
extent of orientation and the guidelines and policies provided were adequate.
Mr. Jelinek took the view that from January on, Mr. Nesrallah's attitude and
supervision was hostile, adversarial, and negative. He could not accept the perfo~rmance
32
appraisals as legitimate because he viewed them as not embodying performance
standards that were objective, measurable, reasonable, or attainable. Rather, he
perceived .the performance appraisals as containing many out of context remarks
calculated to be disparaging of the grievor. When 'pressed repeatedly in cross-
examination as to whether he felt he needed to improve or change his performance in
response to the performance appraisals, the grievor responded by questioning the validity
of the appraisal process. In re-examination, he asserted that he tried to meet the
expectations as he understood them either from the goals or from the manual.
We reviewed carefully the evidence of the grievor in response to the criticisms of
the grievor's clinical approach and case presentation style. In general, the grievor did
not accept that the criticisms of his performance were valid. He defended his
performance by ascribing blame to others. In some instances, he blamed Mr. Nesrallah
for being unable to accept or tolerate a difference in professional clinical judgement. For
instance, Mr. Jelinek referred to a divergence in clinical approach between Mr. Nesrallah
and himself concerning resident K.G. in reference to the supervisory note made on July
5, 1990. Mr. Jelinek took the stance that it was inappropriate that her misbehaviour be
rewarded by being taken to the snack bar by her worker; usually, residents were taken
to the snack bar as a reward for good behaviour. In another example, Mr. Jelinek
defended his stance on the temporary release for' S.G. mentioned in supervisory notes in
March 1990. In brief, the grievor testified that the resident was legally entitled to apply
for a temporary release and since the case manager supported it, he should not oppose
the application. Mr. Jelinek opined that the plan of care, if it did not contempla~ a
temporary release at that point in time, was unrealistic and not in conformity with
33
clinical opinion favouring family reintegration. Later in his testimony he indicated that
he was surprised that the temporary release was granted. We find the grievor missed
the point that the role of the Unit Clinical Coordinato~ was to offer advice based on the
treatment goals in the plan of care which, in this case, would postpone a temporary
release of the resident unt//assessments were conducted.
In response to the "mice" comment, as a reference to the grievor advocating a
behaviour modification approach to handling resident HE., Mr. Jelinek explained that
the clinical approach taken previously with this same resident on a prior admission had
been unsuccessful. Mr. Jelinek ~ok the opportunity to explain to cottage staff a different
approach, the behaviour modification approach, as an alternative that might be
considered. He defended this as appropriate to a case conference which includes an
element of in-service clinical training.
In other instancesl Mr. Jelinek ascribed blame to his role conflict with Flora
Lamont and to Mr. Nesrallah's favouritism of Ms. Lamont, which, in the grievor's view,
led to Mr. Nesrallah to take a critical view of his work and clinical judgement. For
instance, the grievor's evidence indicated that he had been blamed ,mfairly for trying to
assist Rob Lister to prepare the report requested by' the probation officer, Rick
Beauchamp; that Ms. Lamont was mistaken about the due date; and that Mr. Nesrallah
was mistaken that the report was required for a court appearance. We have already
indicated that it would have been responsible and reasonable for the gr/evor to seek
clarification as to what sort of report was required and the due date.
In other instances, the grievor ascribed blame to conflicts between Mr. Nesrallah
and Ms. Close as to how clinical issues are to be identified and goals to be formulated in.
34
plans of care. The grievor adopted this as an explanation to defend his work in drafting
plans of care for residents R.V. and S.B. In the latter case, the grievor also ascribed
blame to the difficulty in coordinating reports in a timely fashion from various members
of the multi-disciplinary team. In this instance, the grievor acknowledged that he had
pointed out that Dr. Chamberlain had been difficult to contact so as to clarify whether
he would have continuing involvement as the primary therapist. ·
On the whole, we fred that the supervision notes and the testimony surrounding
the events noted reveal that there was some basis supporting Mr. Nesrallah's critical
assessment of the grievor's ability to identify, synthesize, and communicate clearly
clinical issues of residents. However, the evidence also reveals that Mr. Nesrallah had
little respect for differences in clinical approach taken by the grievor. Mr. Nesrallah
chose to treat Such differences as a personal attack upon his authority and upon his
ability to maintain a cohesive clinical approach by care givers. The evidence of
Ms. Close, Nits. Parker and Ms. Simmons indicated that differences in clinical judgement
and approach are aired in team meetings. It is the duty of the Programme Manager as
Chair to forge a consensus upon an integrated clinical approach to each resident. It is
the role of the Unit Clinical' Coordinator to support the Programme Manager in that
task.
Unfortunately, by April 1990, ffnot sooner, Mr. Nesrallah manifested an inability
t° handle supervision issues with the grievor in an objective, constructive fashion - he
descended to yelling at the grievor and keeping a paper trail which portrayed the grievor
in an invariably disparaging way. We recognize that Mr. Nesrallah was frustrated
because the grievor's academic credentials and previous clinical experience reasonably
35
would lead to the expectation that the grievor would not havre difficulty in identifying,
synthesizing, and articulating clinical issues. Nonetheless, we fred that the grievor was
entitled to'a more objective, constructive approach in supervision.' The dynamic which
emerged from Mr. Nesrallah's disparaging and hostile approach was that the grievor
became inured to his criticism because he perceived Mr. Nesrallah to be biased. We
conclude that the pernicious quality of this supervisory relationship significantly and
adversely affected the. ability of the grievor to meet the requirements of his position,
particularly in the absence of assistance from Ms. Close after March and in the absence
of intervention by Mrs. Parker. '
3. Dit~_culties in Clinical Recording - i.e. Pi.-. of Care and Plan of Care Review
Reports
In her testimony, Ms. Close indicated that she had detected problems with the
organization and clarity of plans of care drafted by the grievor. To illustrate, Ms. Close
recalled having a joint supervisory session with the grievor and Mr. Nesrallah in March
1990 to review the grievor's draft plan of care for resident R.V. At this juncture the
grievor was provided guidelines for clinical recording by Mr. Nesrallah. Later she was
asked by Mr. Nesrallah to attend and chair a plan of care review conference on June 20,
1990 for the same resident R.V., as Mr. Nesrallah was unable to attend. She nbted that
a consensus emerged at the meeting that the central clinical issue for this resident was
to address feelings of loss, grief, and mourning. However, when she reviewed the
grievor's draft plan of care review, the grievor had identified the chief goal for therapy
36
as assisting the resident to develop positive transference with persons in authority. She
edited the draft and added the .clinical issue concerning loss and mourning.
Ms. CIose explained that her supervision fell off after March because
Mr. Nesraliah was increasing his supervision of the grievor concerning goal formulation
and identification of clinical issue in plans of care. She felt it would be redundant for her
to do the same. She added that the grievor's problems arose at the most basic level of
report writing, whereas her expertise was sought by Unit Clinical'Coordinators usually
in respect to. more complex issues of clinical management, She disputed the grievor's
evider~ce that her supervision dropped off in January; she placed the turning point in
March.
When asked in cross-examination whether she recalled indicating to the grievor
that Mr. Nesrallah had said to her that Mr. Jelinek would be gone in six months, she
responded "No." When asked whether she recalled that Mr. Nesrallah had consulted
with Human Resources to discuss performance appraisal, she responded "Yes." She could
not specify the time frame when Mr. Nesrallah had consulted with human resources, but
she indicated in her evidence that Mr. Nesrallah was advised by Human ResoUrces
personnel to go through performance appraisal, but not for the purpose of termination.
She also indicated that she became aware by January or February 1990 that there were
supervision issues with respect to the grievor's writing of plans of care. She gleaned this
impression from regular supervision sessions she had with the grievor in the initial three
months following the grievor's hire and from editing his draft plans of care and plan of
care review reports. We fred that the supervision and guidance provided by Ms. Close
continued to March 1990, and' was adequate to that point. Given that the grievor was
37
still experiencing problems with identifying and articulating clinical issues, in her view,
we find that~ it was inappropriate for her to cease her supervision of the grievor
thereafter, particularly in the context of 'the difficult supervisory relationship with
Mr. Nesrallah.
The evidence shows that both Mr. Nesrallah and Ms. Close had identified
problems in this aspect of the grievor's work by January.' It was one of the reasons that
Mr. Nesrallah sough~ advice from Human Resources on how to address this with the
grievor. We can only characterize the grievor~s testimony in this area as evasive,
· guarded, and defensive. In direct examination, the final version of several plans of care
and plan of care reviews which had been assigned to the grievor were put to him for
comment. He insisted that his reports were ail eventually approved by Mr. Nesrallah.
We £md that the grievor'S answers were calculated to mislead the Board as to the extent
of revision that had been required. When the draft versions Were put to him in cross-
examination, the grievor refused to accept the editing as a form of assistance or that the
extent of editing reflected a problem in his ability to organize and articulate the clinical
issues in a clear, coherent, logical format, but ascribed blame to differences between
Mr. Nesrallah and Ms. Close in goal formulation and writing format.
t
We conclude that the evidence of Ms. Close and Mr~ Nesrallah is to be preferred
on this issue. We £md that the evidence shows that there were significant problems with
the grievor accepting and conforming to expectations and standards for clinical recording,
despite considerable assistance in the form of editing and discussion provided by
Ms. Close in the early stages of his employment and subsequently by Mr. Nesrallah.
38
Furthermore, we fred that by mid-January, Mr. Nesrallah had concluded that he
had a performance problem with Mr. Jelinek. We also find that Mr. Nesrallah had a
personality conflict with the grievor such that he became readily exasperated with ti~e .
grievor and became increasingly unable to provide assistance in a Ixelpful manner;
supervisory sessions by April became so difficult that Mr. Nesraltah was reduced to
yelling criticism at the grievor. We have already articulated our conclusions about the
knpac~ that the approach taken by Mr. Nesrallah had upon the grievor's opportunity to
demonstrate that he could meet performance expectations.
4. Clinical Judgement and Professional Conduct
Much of the illustrative evidence pertaining to the problems identified in this area
has been reviewed above. For instance, the support for the early,temporary release for
S.G,; the discourse on a 'behaviour modification approach for resident H.B.; the
disagreement concerning what would be suitable punishments or rewards for and
suitable conduct by K.G. in light of the clinical issues arising from a history of abuse; the
apparent difficulty the grievor had in articulating to cottage staff what was meant by the
term "uses sex as a transitional object" used by Dr. Meen in respec{ to resident S.G.; the
stance taken by the grievor, concerning the assignment of a e0mmunity worker who was
a known homosexual to resident C.S., whose clinical issues included pyromania linked
to sexual dysfunction and problems with gender identity; and the problems with
discharge planning for resident J.L. We f'md that the whole of evidence supports a
conclusion that there was some problem with the grievor's clinical judgement. However,
we also Fred that the grievor was denied sufficient assistance from Ms. Close to assist
39
him to develop his clinical judgement and tn articulate clinical issues in a manner that
was consistent with the predominant clinical ideology at Syi Al{ps, which appears ~o be
the psycho-social model. We t'md that Mr. Nesrallah had concluded certainly .by May'
1990, and perhaps even by March, that the grievor was headed for termination and that
· he would document a consistent paper trail in that direction. In this context, given the
' difficult working relationship that. had arisen between the grievor and Mr. Nesrallah, the
omission by Ms~ Close to continue to provide clinical assistance to the grievor, inCreased
the severity of the impact upon.the grieVor's attitude and performance. Furthermore,
· senior management took no conCrete steps to alleviate the conflict between the grievor
and Mr. Nesrallah, despite the content of the addenda, which should have induced some
reaction. The offer of a transfer to the grievor by Mr. Nesrallah in January or early
February occurred before the supervisory relationship had become so difficult. The query
by Ms. Parker as to whether the grievor could work elsewhere on July 4th was half-
heart~d, resulting only in a referral to a person that even Ms. Parker admitted in her
evidence had no authority to provide a job to the grievor. Mr. Nesrallah's ·supervision
was problematic for the reasons outlined, as well as the further reasons that in the
initial stage of the grievor's employment following his hire, Mr Nesrallah provided little
SUpervisory feedback to the grievor to put the grievor on notice that his performance was
not meeting expectations. Furthermore, in this time frame and up until March or April,
the grievor was contending with a problem with his hearing that was not resolved until
after the second performance appraisal. Thus, from his hire in November until early
spring, the grievor's compromised ability to hear what was said at team and mini-team
meetings could have affected his ability to summarize accurately what transpired at
'these meetings, yet he was responsible for taking minutes and for providing an accurate
~reflection of treatment goals and progress in clinical recording. We are of the view that
the employer was under a duty to accommodate the grievor in respect to his hearing
problem. While the employer did assist the grievor to have this problem addressed,' the
supervisory response did not seem to link 'these issues to problems that were noted in
clinical recording in the early stages. ·
CONCLUSION
We conclude that the evidence supports a finding that there were performance
problems which underpinned management's decision to effect the grievor's release.
However, the probationary employee is also entitled to have supervision which is fair.and
affords an adequate opportunity to demonstrate that performance standards can be met.
Furthermore, the performance standards set should be objective, measurable, reasonably
related to the worl~ and responsibilities. We fred that Mr.. Nesrallah failed to providb
adequate supervision to the grievor in the initial stages of his employment from
November to February. We £md that Ms. Close provided inadequate supervision to the
grievor from March to August. We fred that Mr. Nesrallah failed to proyide fair,
objective supervision after March and allowed his judgement of the ~,rievor's performance'
· to be clouded by a personality clash with the griever. We f'md that these deficiencies in
the supervision accorded to the grievor seriously impacted his ability to meet the
performance standards expected. We find th: :~ i~rformance standards expected were
41
that the grievor be able to provide sound clinical judgement and be able to identify,
synthesize and communicate clinical issues in a dear, logical and coherent fashion that
is consistent with' the psycho-social clinical model predominant at Syl Apps. These
performance standards are reasonable and relevant to the duties and responsibilities of
the position. The problem lay in the assistance accorded to the grievor to realize those
performance standards. 'That is not to say that the grievor's thirty years' previous
clinical experience and academic qualifications are not relevant. The grievor's
background and qualifications would form a rational justification for' management's
assumption that the grievor ought to. have been able to meet the performance standards
more qUickly and with less supervision than would be required for a recent graduate
without dirdcal experience. However, when the whole of the evidence is considered, we
conclude that the grievor, even with his considerable knowledge and experience, was
entitled to a fair, objective assessment of his performance and to ~ve an adequa~,~
opportunity to demonstrate that he could meet the performance s~ndo_rds. As mentioned
earlier, the decision of management to release the grievor pivoted upon Mr. Nesrallah's
supervisory process and opinion. We have found deficiencies in'the rational basis for that
opinion and in the process followed.
We cannot dose ws'thout adverting to the manner in which the grievor was advised
of his termination. Although he knew from his fourth performance appraisal and from
Mr. Nesrallahs' deportment generally that Mr. Nesrallah was recommending release, the
grievor was not aware that the recommendation had been approved officially until
8:30 a.m. on the morning of August 22, 1990 when Mr. Nesral]ah handed him his letter
of discharge. Mr. Nesrallah switched versions in his evidence as to whether he invited
42
the grievor to his office to explain the letter or whether he simply handed him the letter
near the security doors in the lobby. Either way, the method was in.considerate. The
grievor was offered no opportunity to collect his personal effects and notes from his office.
Ms. Parker denied that she gave any such direction, although Mr. Nesrallah testified
that Ms. Parker had ordered that he not be allowed to go'io his office. The termination
was effected in a brutal, uncivil manner, which even Mr. Nesrallah conceded in cross-
examination. If.anything, the manner in which Mr. Nesrallah effected delivery of the
release letter confn'ms our view that he harboured ill will toward the griev0r, and had
done so for some time.
REMEDY
In short, the grievance is allowed in part. 'While the Union has not established
that the grrievor is able to meet the performance requirements of the position, the Union
has established that there were significant flaws in the good faith and rational bas'is
supporting the decision to release which adversely affected the grievor's ability to
demonstrate that he can meet the position requirements. We therefore order that .he be
reinstated to his position as a Unit Clinical Coordinator at Syl Apps subject to completion
of his probationary period. In view of the length of time that has ~elapsed since his
termination on August 22, 1990, we would urge the Employer to provide the grievor upon.
his reinstatement a refresher orientation to assist him in reintegrating to the curreht
treatment team.
'43
We are not convinced that the grie¥or can meet the position requirements. In the
case G.S.B. #729/90 Re OpsEu (Agboka) and The Crown in Right of Ontario (Ministry
of Revenue), cited by the Union in this case, the panel commented upon the propriety of
awarding compensation in cases where release of a probationer is not upheld. In the
Agboka case, the Union conceded in dosing argument that the grievor was not able to
perform the job in question. By 'way of remedy, the Union was not seeking reinstatement
to the grievor's former position but reinstatement to a different position. At pp.18-I9,
the panel articulated the reasons why it would not order reinstatement to a different
position. At pp.16-17, the panel articulated its reasoning concerning the remedy of
compensation to a probationary employee upon reinstatement to his former position
where a release has not been upheld and where the evidence indicates that the grievor
may not be able to meet the position 'requirements:
First of all, it is clear that any re-instatement would be
to a probationary position with the balance of the
probationary period to run. This has been .the procedure
followed in a number of probationary re-instatement cases
[Walker 1272/88 (Fisher), Sheppard 2492/86 (Sloane) and
Nicholson 1294/88 (Ratushny)].~
Secondly in terms of compensation,'although a number
of awards have automatically given compensation, upon re-
instatement [Walker 1272/88 (Fisher)] some awards have not
iManiate 56/77 (Swan)].
If one applies the basic principles of contract damages
to these cases, the rule is that the Grievor should be put in
the same position he would have been had the contract not
been breached. If the contract had not been br~ached,~the
grievor would have been in the position that at any time up
to the end of his probationary period he could have been
released due to his failure to meet the requirements of the
job. He-would only .achieve the coveted prize of permanent
status once he had successfully completed hi~ probationary'.
period. It follows then *_.hat we do not know at *_,his point
whether or not the grievor will pass his prebation_~_ry period
44
ff he is reinstated. In fact he could be reinsta~ to his
probationary status and fail to pass probation. If ~h,~t is so,
why reward him now with over 2.5 years of back pay?
Instead ~_h_e compensation award should be made conditional
upon his succe__zsful completion of ~_he reinsured probationary
period. Th~_, srrsngement would provide hi,. with t~he full
compensation to which he ',may be entitled while at the same,
Thus, if the grievor were to be reinstated, this Board
would not provide for automatic compensation, rather we
would make it a condition that his compensation award be
contingent upon the successful completion of his probationary
(emphasis added)
While these reasons were obiter in the Agboka case, we agree with the principles
articulated and fred them applicable to the instant case. We therefore order that ·
compensation to the grievor be conditional upon his successful completion of the
probationary period and.subject to a duty to mitigate his losses since he was released in
August 1990.
In the result the grievance is allowed in part. At the part/es' request we remain
seised to deal with problems arising in the' implementation of this. award which the
parties are unable to resolve 'themselves.
Dated at Kingston, Ontario, on this 2oth day of December, 1993.
Jane h Vice-Cha irper son
"I dissent" - partial dissent to follow
Michael Lyons Member
"I concur with addendum"
Harry Roberts Member
46
Addendum
1938/90 OPSEU (Jelinek) and the Crown in Right of Ontario (Ministry~
of Community & Social Services)
After carefully reading the analysis of the evidence
presented in the above case, leading to the decision set out in the
final award, I am persuaded to concede, with some r~luctance, that
the remedy'proposed is not unreasonable under the circumstances.
JI am completely in agreement with ad share the belief that,
as noted at the top of page 44 "we are ·not Convinced that the
grievor can meet the position requirements."
I strongly support the ruling that compensation, if any,
which might be paid to. the grievor, be conditional, upon his
successfully completing the revised probationary period, and not
otherwise.
H.- Roberts, Member
PARTIAL DISSENT
G.S.B. 1938/90
OPSEU (~elinek)
and
THE CROWN IN RIGHT OF ONTARIO
(Ministry of Community and Social Services)
This was a difficult and complex case. It required 17 hearing days
over more than two years to complete the evidence and arguement. I
cc~pliment the Chair for the excellent job she did in sun~m~rizing the
facts and arguements. For the most part I agree with the conclusions
reached in the award; unfortunately, I must partially dissent,
primarily because of the remedy which the Board orders.
Essentially, there are three parts to the remedy: 1 - that the Grievor be. reinstated;
2 - that the Grievor be required to ccmplete the remaining
portion of his probationary period;
3 - that compensation to the Grievor be conditional upon his
his successful completion of his probationary period;
It is the third aspect of the remedy with which I disagree.
The Board's usual practice is to award full retroactive compensation
when a grievance challenging a probationary release is allowed.' It
see~s clear frcm the award, that'the reason that the majority decided
not to award ccmpensation until the Grievor completed his probation
was because "the Union has not established that the Grievor is able to
meet the performance requirements-of the position" and therefore "we
are not convinced that the Grievor can meet the position
requirements". However, with respect, it is not up to the Board to
determine whether or not the Grievor can meet the position
requirements', nor dOes the Union bear the burden of .establishing that
he can.
It was agreed that the appropriate standard of review of a
probationary release is stated in Sheppard, G.S.B. 2492/86 (Slone).
That award says in part at page 14:
"It can be argued with some logical force that this
Board does not sit as an appeal tribunal from the decision by
a Deputy Minister to release a probationary employee, for
failure to meet the requirements of the position. We are not
entitled to substitute our assessment of the probationer's job
performance for that of the Deputy Minister."
Sections 22(5) and 23 of the Public Servi~e Act gives the Deputy
Minister or his/her delegate the sole authority to determine whether
or not a probationary employee has met the reqirements of the
position. Accordingly, the Board, in my view, lacks the jurisdiction
to step into the shoes of the Deputy Minister and to make this
determination. If the board ~re to undertake 'this task, it w~uld
amount to second guessing the decision of the Deputy Minister. This
Board does not have that authority.
On the· issue of onus, in Mitchell, G.S.B. 1610/89 (Emrich),the Board
· clearly found that the Employer had the onus of proving that the
release of a probationary employee was reasonable and in good faith.
It is inconsistent to claim that in this case the Union bears the onus
of showing that the Grievor could meet the requirements of the
position. In Sheppard, supra, the Board outlines the aspects that must
be considered when reviewing a probationary, release. (These are
quoted on page 8 of this decision. ) None· of these factors require the
Union to establish that the Grievor is able to perform the job
requirements; rather, they all deal with whether or not the Employer
met its responsibilities. In this case, the Union clearly showed that
the Employer did not. In fact, the lack of good faith by the
Employer, along with the poor supervision and inadequate evaluations
given to the Grievor, made it highly improbable that the Grievor would
be able to meet his job requirements..
During an employee's probation period, both the employee and the
employer, have a responsibility to to take steps that will help the
employee to successfully cc~plete his/her probation. In this case,
the BOard found that the Employer failed to meet its responsibility;
yet, unless the Grievor successfully completes the remaining portion
of his probation, there will be no consequences for the Employer.
· This should not be so. Since the Board'found that the Employer was
at fault in this matter, the Grievor ought to be ~compensated,
regardless of whether or not he successfully completes his probation.
Remember also, that the Board recognized that the liklihood that the
Grievor will successfully cc~plete his probation has been reduced
because, given the length of time that has elapsed since his release
(3% years), his skills are likely rusty.
By deciding to return the Grievor to his position but not to award
cc~pensation, until he has cc~pleted the remaining portion of his
probationary period, the Board is departing frc~ the traditional
remedy that has been overwhelmingly followed by Arbitrators in similar
cases. This is also a departure from the well established principles
'in_Blake, G.S.B. 1276/87, (Shime).
In light of the above, ~ would have ordered that the Grievor be
returned to his position (subject to completion of his probationary
peri~d) with full ccmpensation.
Dated at Toronto this 4th day of January, 1994.
Re: G.S~B. #19~ O~.S-~,.U. (Jelinek) and The Crown in P~ht of Ontario
fMi-~tr~ of Co~m,-~ty and S~_ '~! Serdces)
ADDENDUM
There is no question that in a case of the release of a probationer, the burden of
proof rests upon the Employer to establish that the release was bona fide and reasonable.
Indeed, our conclusion on the merits was that the release was neither bona fide nor
reasonable.
However, when we turned to the issue of the appropriate C°mpensa~ion which
should be awarded to the grievor consequent upon this finding on the merits and our
order that the grievor be re/nstated, we needed to consider what would be an appropriate
measure of the grievor's loss, given all the circumstances of the case.
At. p.43, we concluded that "While the Union has not established that the grievor
is able to meet the performance requirements of the position, the Union has established
that there were significant flaws in the good faith and rational basis supporting the
decision to release which adversely affected the grievor's ability to demonstrate that he
can meet the-position requirements." In phrasing our conclusion in this manner, we do
not intend to reverse the burden of proof which rests upon the Employer throughout to
defend its 'decision to release as bona fide and reasonable. At the same time, however,
this was a case in which we found at p.26 that "both the grievor and Ms. Lamont
participated in role conflict." At p.27 we found that the grievor refused to accept
responsibility for any error on his part in respect to a report deadline, when it would
have been reasonable to do so. At p.33, we noted that the grie),or did not accept any
1
criticisms of his performance as valid and he customarily would ascribe blame to others.
In respect to the issues around clinical recording, our review of the evidence resulted in
the following findings at p.38:. "We can only characterize the grievor's testimony in this
area as evasive, guarded, and defensive .... We irmd that the grievor~s answers were
calculated to mislead the Board as to the extent of revision that had been required." ...
"We trmd that the evidence shows that there were significant problems with the grievor
accepting and conforming to expeci~ti0ns and standards for clinical recording, despite
considerable assistance in the form of editing and discussion provided by Ms. Close in the
early stages of his employment and subsequently by Mr. Nesrallah." Furthermore, at
p.39, we stated our conclusion on the evidence that "We £md that the whole of the
evidence supports a conclusion that there was some problena with the gr~evor's clinical
judgement." In measuring the extent of the loss suffered by the grievor in consequence
of his release, some account must be taken of his contribution to that loss and of his lack
of candour. Thus, at p.44 we expressed the view that we were not convinced that the
grievor can meet the position requirements. His incumbency in the position is contingent
upon the successful completion of the proba~onary period. M~klug the award of
compensation conditional upon successful completion of the probationary period properly
balanced the concern arising from deficiencies noted in the grievor's performance and
demeanour with the deficiencies in the supervision process. The deficiencies in the
supervision process COmpelled our decision on the merits, but deficiencies in the grievor's
performance and demeanour as a witness led us to conclude that recovery of
compensation for his loss Should hinge upon successful completion of the probationary
period.
2