HomeMy WebLinkAbout1992-1000.Milks.93-03-11
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)' ONTARIO EMPLOYES DE LA COURONNE
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l1lil1li GRIEVANCE COMMISSION DE
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SETTLEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST SUITE 2100 TORONTO ONTARIO. .MSG lZ8 TELEPHONEITELEPHONE (4/6) 326-/388
180 RUE DUNDAS OUEST BUREAU 2/00 TORONTO (ONTARIO) M5G lZ8 FACSIMILE TELECOPIE (416) 326-1396
1000/92
IN THE HATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Milks)
Grievor
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The Crown in Right of ontario
(Ministry of the Attorney General)
Employer
BEFORE: W. Low Vice-Chairperson
E. Seymour Member
F. Collict Member
FOR THE C. Dassios
mUON Counsel
Gowling, Strathy & Henderson
Barristers & Solicitors
FOR THE M. Migus
EMPLOYER Staff Relations Consultant
Ministry of the Attorney General
HEARING January 7, 1993
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DECISION
The Grievor PatnCla Milks waS employed by the Ministry of the Attorney General
from February 11, 1991, to March .31, 1992 She was employed under Contract No 728724
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effective February 11, 1991, to December 30, 1991, and under Contract No 73306 effective
October 1, 1991, to March 31, 1992 At the end of the second contract, Ms. Milks was not
offered any further contract. She grieves unjust dismissal.
We are asked to rule upon a preliminary objection going to the Board's
jurisdiction to determine the unjust dismissal grievance. It is the posItion of the employer that
the Grievor, being a contract employee whose employment ended wIth the expiry of the term
of her contract, ceased to be a public servant under s 9 of The Public Service Act, and that as
there is no contractual or other obligation on the part of the employer to offer further
employment to the Grievor, the Board has no Junsdlction to determine an unjust dismissal
grievance on the part of the Gnevor
The following facts are not in dispute. that the Grievor's total penod of
employment as a public servant was one year, 17 days, and was pursuant to the two contracts
referred to hereinabove. The contracts covered a new position of cashler/counterclerk (later
known as counter services clerk) classified at the Office AdministratIve Group 5 level. The
counter services clerk position was posted as a full.time classified vacancy in December of 1991
under Competition No 383A/91, a competitIOn to whIch the Grievor apphed The Grievor was
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interviewed on January 21, 1992 She was not successful 10 the competItIon and was so advised
on February 18, 1992 After the competItion results were known, the Grievor was advised that
her contract would not be renewed The candidate selected for the counter services clerk
position started in that position on March 9, 1992, and the Grievor was assigned to other duties
to the end of her contract. She continued to be paid at the Office Administrative Group 5 level
after the re-assignment and to the end of her contract which expired March 31, 1992
It is alleged on behalf of the Umon that there was bad faith on the part of the
employer It is alleged that the acts of bad faith consisted of the following
1 When a support payor told the Grievor that he did not wish to deal with
her because she was a woman, the Gnevor's supervisor, Mr Belanger,
agreed and told the Gnevor that he was to be summoned when this
particular payor came in,
2 When another payor wrote a letter to the Mimstry praising the Grievor's
manner in the conduct of her dutIes, the orig1Oal of the letter was not
given back to the Gnevor, notwithstanding her request for It;
3 In another'incident, Mr Belanger dropped an Affidavit on the Grievor's
desk and told her to "find all the errors", which Grievor did,
notwithstand1Og that she did not draft the AffidaVit;
4 Shortly after she was informed that she was not successful in the
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competition, the Grievor was confronted by her supervisor Mr Belanger
with a list of allegations regardmg her conduct, including allegations that
she had been dating payors and providing confidential information to
persons not entitled to same, and when later the Grievor denied the
allegations, the particulars were given to her in a two page memo which
was also put on her file detailing the allegations. It is alleged that there
was a real risk that these allegations had an impact on the result of the
competi tion,
5 Although the contract had not yet run its course, the Grievor was re-
assIgned to do relatively menial tasks once the competition was concluded
and the successful candidate mstalled, and the Gnevor received no
alternate training and no support;
6. When the Grievor's contract ran out, the Employer did not look for new
work for her
We did not receive evidence on the Issue of the allegatIOns of bad faith The
parties have agreed that on the preliminary issue, if this Board is of the view that bad faith is
irrelevant for purposes of determimng whether there is Junsdicticm in this Board to determine
the grievance, that would be an end to the matter It is of course the position of the Employer
that the presence or absence of bad faith is irrelevant in determining whether or not this Board
has jurisdiction, and it is submitted on behalf of the Union that the presence of bad faith is a
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relevant factor
One of the addItional facts raIsed by the Employer and which is not disputed by
the Union is that the position which the Grievor had been hired to fill was a positIon existing
pending posting and competItIon The permanent position was posted and a classified position
was created The functioQ that the Grievor had been origmally contracted to fulfil on a
temporary basis therefore came to be performed by a permanent classIfied employee, thus
obviating the contract pOSItIon It is also not seriously dIsputed that there was no contractual
or other obligation on the part of the Employer to seek other work or to offer another contract
to the Grievor Finally, It was indicated to us that at least some of the incidents which are
alleged to be acts of bad faith on the part of the Employer were the subject matter of earlier
grievances by the Grievor, but that the gnevances were WIthdrawn
Counsel have referred us to thIS Board's deCISIons m Healey 0485/88 (Fisher),
Shipley 0223/86 (Samuels), Corey 377/86 (Gandz), Humemuk 614/84 (Springate) and a decision
of Mr Shime in Re InternatIonal Nickel Co. of Canada ,Ltd. v United Steelworkers. Local
6500, 14 L.A C 2nd, 13 (1977)
In Corey, the Board held that a non-renewal of a contract which has run its term
cannot be viewed as a dismIssal and accepts a conclusIon reacheq in the earlIer case of
Cascagnette 1246/85 that the Board has no jUrIsdiction to reVIeW the circumstances under which
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a fixed term contract was not renewed The employment relatIonshIp created by a fixed term
contract is severed by operation of s. 9 of The Public ServIce Act and the terms of the contract
itself In Shipley, Arbitrator Samuels came to the same conclusion notIng that the Board cannot
create a contract where none exists and cannot fashion remedies to deal with the failure to enter
into a contract. In the Shipley case, the Grievor alleged that he was beIng discriminated against
contrary to the Human Rights Code and the result of such discriminatIon was the non-renewal
of his contract. The Board held that even assuming the Employer's policy on hIring relatives
was contrary to the Code (being the grounds for the allegation of discrimination), the Board
nevertheless had no jurisdIction to deal with the grievance that the contract was not renewed
Vice-Chairman Samuels noted at page 8 of the deCIsion
"An unclassified employee has no contractual right to renewal of his contract.
Why would it matter if the failure to renew was "tainted by bad faith" (whatever
that would mean in the circumstances)? This Board- simply has no jurisdiction
over non-contractual problems, except for the three matters mentioned In section
18(2) of the Crown Employees Collective Bargaining Act."
In the Healey case, the union argued that the Board has the jurisdiction to enquire
into the decision-making process of the employer in deciding not to renew a contract to see if
the decision was made in good faith It was also argued that If not, the Board had junsdiction
to apply the appropnate remedy Vice-Chairman Fisher accepted the reasoning in Shipley as
binding on this Board in accordance with the Blake deciSIon and held that the Board simply has
no jurisdictIon in the case of a simple non-renewal of a contract where the employee was paid
to the end of his term
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The earlier decisIon of H u mem uk 614/84, a decIsIon of Vice-Chairman Spnngate,
appears to be the progenitor of the argument that the establishment of bad faIth on the part of
the employer in not renewing a contract might open the door to an enqUIry by this Board where
the operation of s. 9 of The Pubhc Service Act and the operatlOn of the contract would prima
facie preclude this Board's Junsdiction on a gnevance as to non-renewal In the Humeniuk case,
the ratio of the decision appears to be in the following
"There is nothmg in the collective agreement or in the applIcable statutes which
guarantees contract employees the right to be reappointed, or which in any way
restricts management when it makes a decision as to which contract employees
are not to be renewed Accordingly, the non-renewal of the gnevor's contract,
which was not ta1I1ted by bad faIth on the part of the employer, did not involve
a breach of either the collectlve agreement or a relevant status "
It IS the phrase "whIch was not tainted by bad faIth on the part of the employer"
which has fed numerous arguments that the presence of bad faith may create jurisdiction where
none otherwise would exist. On our view of the Humemuk decision, the comment as to tainting
by bad faith is at best obIter,and does not, in our view constitute an authority for the
propositIon that the presence of bad faith would, in a non-renewal of contract sItuation, give
jurisdiction to this Board to renew the contract or to impose a new contract upon the parties. As
for the International Nickel decision to which we were referred, although we agree with
Arbitrator Shime's comments as to good faith, we find the deciSIon not applIcable in this
statutory setting In any event, we are of the view that decIsions In Corey, Shipley and Healey
were correctly deCIded, and whether the Blake deCIsion permits thIS Board to depart from earlier
jurisprudence of the Board only in cases where there are exceptlOnal circumstances or in cases
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where an earlier decision is seen to be manifestly wrong, we are of the view that the line of
reasoning set out in Shipley is correct and accordingly would adopt it.
For the foregoing reasons, the grievance is therefore dismissed.
DATED this l1thday of March, 1993
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WlLOW - Vice-Chairperson
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E. SEYMOUR - Hember
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G S B FILE 1000/92 - 0 P S.E.U (Milks)
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THE CROWN IN RIGHT OF ONTARIO
(Ministry of the Attorney General)
ADDENDUM
Edward E Seymour, Union Nominee
I concur with the Decision, however, the allegations made by the
Union, if true, are disturbing Management acted shabbily towards
the griever and, for whatever reason, it appears they gave her
little support
In these times when women are struggling in the workplace against
some who refuse to regard them as equals, it seems that Management,
in this instance, were only too willing to perpetuate this sexism
by acceding to the wishes of a "support player," who did not want
to deal with the griev~r simply because she was a woman
This panel was unable to fully explore the details of this allega-
tion, but if true, Management's behaviour with respect to the issue
is nothing short of atrocious The alleged actions of Mr Belanger,
particularly with regard to the above, and other unsubstantiated
allegations, appear to be those of an individual seriously
deficient in managerial skills
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While I agree that there was no obligation for the Ministry to
renew the griever's contract, an employee is deserving of respect,
and the right to work in an environment devoid of the petty actions
of a Manager who seems more interested in exercising power than
managing the workplace in a manner which is fair to everyone
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Edward E Seymour, Union Nominee
opeiu 343
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