HomeMy WebLinkAboutP-2015-2662.MacKinnon.16-09-20 Decision
Public Service
Grievance Board
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Commission des
griefs de la fonction
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Toronto (Ontario) M5G 1Z8
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PSGB#2015-2662
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE OF ONTARIO ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
David MacKinnon Complainant
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The Crown in Right of Ontario
(Ministry of Community Safety and Correctional Services ) Employer
BEFORE Marilyn A. Nairn Vice Chair
FOR THE
COMPLAINANT
David MacKinnon
FOR THE EMPLOYER Stewart McMahon
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING September 9, 2016
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Decision
[1] This application alleges that the complainant, David MacKinnon, was improperly
terminated from his employment because of a disability. The employer raised three
preliminary objections in its Form 2 written response. Those objections went to the issue
of the Board’s jurisdiction to hear the application, and consequently were heard on the
scheduled hearing date of September 9, 2016 prior to the Board entertaining evidence
relating to the merits of the application.
[2] The complainant had been a long-term employee of the Ministry of Community
Safety and Correctional Services (“CSCS” or the “Ministry”). He retired from his
Operational Manager (“OM”) role at Toronto East Detention Centre in December 2012.
[3] There was no dispute that Mr. MacKinnon returned to work as an OM at the
same institution in the summer of 2013. There was also no dispute that, in this capacity,
the complainant was a public servant. Mr. MacKinnon continued to work until July 2014
when he was involved in a motorcycle accident. He did not return to work, apparently
due to his disability, and on September 2, 2015 he was given sixteen weeks notice by
the employer that his employment would end effective December 31, 2015. It is this
employer action that is the subject of the application.
[4] At the hearing, the employer focussed on the first objection raised in its
response. The second objection, it submitted, was subsumed by the first. The employer
withdrew its third objection, a challenge to the timeliness of the application.
[5] The employer asserted that the Board has no jurisdiction over the application as
the complainant, at the time of termination from employment, was working pursuant to a
fixed term contract on an irregular basis. The employer relied on subsection 5. (2) 5. of
Ontario Regulation 378/07, made under the Public Service of Ontario Act, 2006, S.O.
2006, c. 35, Sched. A. That subsection of the Regulation provides:
Eligibility to File a Complaint
Eligibility Generally
5. (2) If any of the following circumstances existed at the material time, a public
servant or other person is not eligible to file a complaint:
…
5. He or she was employed for a fixed term for fewer than 14 hours per week,
employed for a fixed term for fewer than nine full days in four consecutive weeks
or employed for a fixed term on an irregular or on-call basis.
(italics added)
[6] The employer filed copies of four “WIN Employee Action Requests”. Each of
these forms documents employee data, the type of employment transaction triggering
the action, the employee’s status, as well as comments, authorizations, and employee
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statements/signatures. The first form, signed and dated August 12, 2013 by the
institution’s Deputy Superintendent, Operations, identifies the complainant as the
employee and records that the complainant is being hired on a fixed term contract as an
“on call Oper. Manager”. The comments section of the form notes that the fixed term
contract is “up to 40 hours per week – end date January 21, 2014”. It contains a
certification that the complainant is not a regular employee and that, subject to earlier
termination, the contract was effective from July 22, 2013 to January 21, 2014. The
complainant signed that document much later, on May 9, 2014.
[7] The second WIN Employee Action Request form was also signed by the
complainant on May 9, 2014. That document records an extension of the fixed term
contract with a new end date of January 21, 2015. It was signed by the Deputy
Superintendent, Operations on March 26, 2014.
[8] The third WIN Employee Action Request was signed by the Deputy
Superintendent, Operations on January 20, 2015. As noted earlier, the complainant had
been injured in July 2014 and had not returned to work. The employer took the position
that it again extended the complainant’s contract with a new expiry date of January 20,
2016. Although not signed by the complainant, there was no suggestion that he was
unaware of the extension. He was not in attendance at the workplace over the period.
[9] The last WIN Employee Action Request was signed by the Deputy
Superintendent, Operations on December 22, 2015. It records termination from
employment effective December 31, 2015, approximately three weeks earlier than the
stated end date of the contract. The reason for termination is noted as “end of contract”.
[10] The employer also filed copies of the complainant’s monthly schedules for the
seven months preceding his accident, that is, for the period January to July 2014
inclusive. Those schedules show that the complainant worked irregularly, both in terms
of the number of shifts worked over any period and the various shifts offered.
[11] The complainant acknowledged that it was his signature on the WIN records.
Without being able to confirm exact dates, he also agreed that the schedules reflected
his work pattern.
*
[12] The employer relied on the language of Regulation 378/07 as set out above in
support of its position that the Board simply did not have any authority to consider the
application. It argued that, as the complainant was not eligible to file the application, no
jurisdiction could be assumed by the Board over the application.
[13] On behalf of the complainant it was argued that the employer was not concerned
about allowing individuals to work without a contract as evidenced by the failure to have
the WIN documents signed until after work had commenced. The employer, it was
argued, was trying to hold the complainant to a contract when there was none. On
behalf of the complainant it was further argued that it was difficult to believe that a fixed
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term contract employee was not able to make a complaint, asserting that, given the
resources spent by the Ministry in responding to complaints from fixed term employees,
this was an attempt to avoid dealing with the merits of the application.
[14] The employer replied that if there were no contract at the material time there
could be no complaint, as no employment relationship would have been terminated. The
last signed contract ended in January 2015, a year before the action complained of. The
employer conceded that the complainant had continued to be employed by the Ministry,
but on a fixed term, irregular basis. Every time the complainant was offered a shift,
worked the shift, and was paid for it, there was a contract, argued the employer. The
employer agreed that it responded to complaints from fixed term employees. It argued
that it is only non-bargaining unit persons employed on a fixed term contract on an
irregular basis who are not eligible to file a complaint. Whether that limitation is
considered right or fair, argued the employer, the Regulation is clear and the Board
cannot take jurisdiction over an application from an individual who is not eligible to file it.
[15] The complainant reiterated that his case asserted that he was terminated from
employment based on his disability and that he was never offered modified duties, and
that, as a public servant, he still had rights.
*
[16] In determining whether this Board has any authority to consider the application,
one must interpret and apply the language of Regulation 378/07. This Board is a
creature of statute and has no inherent jurisdiction. It cannot go beyond the authority
provided to it. The Board has been continued under Part II of the Public Service of
Ontario Act, 2006. Section 31 of that statute provides for the making of regulations as
follows:
Regulations, Part II
31. (1) The Lieutenant Governor in Council may make regulations,
…
(c) prescribing circumstances in addition to those set out in this Act in which a
public servant may file a grievance with the Public Service Grievance Board;
(d) prescribing matters that cannot be the subject of a grievance before the Public
Service Grievance Board;
(e) prescribing classes of public servants who are not eligible to file a grievance
with the Public Service Grievance Board;
…
[17] Regulation 378/07 has been passed pursuant to this statutory provision and it
both governs and limits the Board’s jurisdiction to entertain applications. Further,
Regulation 378/07 is clear; a straightforward reading of the Regulation confirms that if,
at the material time, the complainant was employed for a fixed term on an irregular or
on-call basis, he is not eligible to file a complaint.
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[18] Although not defined in Regulation 378/07, the “material time” is properly
interpreted as the time when the alleged contractual violation occurred. In this case, the
complainant was advised by letter dated September 2, 2015 that his contract was being
terminated effective December 31, 2015. Whether one considers September 2, 2015 or
December 31, 2015 as the date of the alleged violation, the material time falls within
those parameters.
[19] The only issue is the nature of the complainant’s employment during that period.
[20] I am persuaded that the complainant was employed on a fixed term contract.
Although arguing that there was no ‘last’ contract as none had been signed, it was
acknowledged by the complainant that the signing of fixed term contracts is, in practice,
often delayed. However, more persuasive is the nature of the contracts that were signed
by the complainant. They expressly record his agreement that he was employed
pursuant to a fixed term contract. The specific term is identified on each of the
documents that bear his signature. The second signed contract continued following the
date of the accident and into the period when the complainant was not at work. It is also
the case that the complainant’s Form 1 acknowledges that he was hired on August 8,
2013 as a fixed term employee.
[21] If I were to conclude that no further contract had been entered into because of
the failure to sign the extension, this application would fail in any event, as the
employment relationship would have simply ended on January 21, 2015 at the end of
the term identified by the last signed contract. I accept that the employer renewed the
contract for a further term to end January 20, 2016. There was no suggestion that the
remaining terms of employment were to change in any way.
[22] In addition, I am also persuaded that the complainant was employed on a fixed
term contract on an irregular or on-call basis. Again, the first WIN document expressly
confirms that the position is as an “on call” Operational Manager. The documents
confirm that the complainant was not a “regular” employee. Finally, a review of the
complainant’s schedules confirms that he was both offered work and did work on an
irregular basis throughout the period of his employment on a fixed term contract.
[23] I find therefore that, at the material time, the complainant was employed for a
fixed term on an irregular or on-call basis. By virtue of subsection 5. (2) 5. of Regulation
378/07, he is not eligible to file a complaint to this Board. As such, this Board has no
jurisdiction to entertain the application filed by the complainant. Whether that result is
fair is not the issue. This Board’s jurisdiction is limited to the authority vested to it under
the Public Service of Ontario Act, 2006 and Regulation 378/07 made pursuant to that
statute.
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[24] Having regard to all of the above, this application is hereby dismissed.
Dated at Toronto, Ontario this 20th day of September 2016
Marilyn A. Nairn, Vice Chair