HomeMy WebLinkAbout1992-3085.Ally.94-12-14
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~ <: EMPLOYES DE LA COURONNE
r. - ONTARIO
CROWN EMPLOYEES DE L'ONTARIO
1111 GRIEVANCE COMMISSION DE
.
SETTLEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST SUITE 2100, TORONTO, ONTARIO M5G IZ8 TELEPHONE/TELEPHONE (416) 326-1388
180, RUE DUNDAS OUEST BUREAU 2100 TORONTO (ONTARIO) M5G IZ8 FACSIMILE /TELECOPIE (416) 326-1396
3085/92
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Ally)
Grievor
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The Crown in Right of ontario
(Ministry of Transportation)
Employer
BEFORE: A Barrett Vice-Chairperson
E Seymour Member
M Milich Member
FOR THE N Roland
UNION Counsel
Barristers & Solicitors
FOR THE A Rae
EMPLOYER Counsel
winkler Filion & Wakely
Barristers & Solicitors
HEARING January 19, 1994
April 28, 1994
May 27, 1994
June 2, 1994
July 8, 1994
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The grievor was dismissed from employment with the Ministry
on October 7 , 1991, for the reasons set out In his discharge
letter, as follows
"CERTIFIED LETTER AND DELIVERED BY PUROLATOR
October 7, 1991
Mr Kamar Ally
c/o N Xynnis, Esq
Heller & Rubel
111 Richmond Street West
Toronto, Ontario
M5H 2G4
Dear Mr Ally I
I have been advised that you have been sentenced to a
jail term of twelve months as a result of your conviction II
on the indictable offence of arson
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You profited from your criminal conduct through the Short !
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Term Sickness Plan and LTIP and with the Ministry as the
Short Term Sick Plan carrier subsidizing ail your other
benefits In accordance with Section 22(3) of the Public
Service Act, R S 0 1980, Chapter 418, the Ministry
hereby dismisses you from the Public Service effective I
immediately
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At this time, I should make you aware that you have the I
right to grieve this action pursuant to Article 27 8 2
of the Collective Agreement with respect to working
conditions and Employee Benefits 1
Pat Jacobsen
Deputy Minister"
We find as a fact on all of the evidence that on August 24,
1988, the grievor committed arson at a meat store owned by himself
and his wife, for which he was later convicted and jailed, and that
he sustained severe burns to his hands during the commission of the
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offence The grievor told the employer, the insurance company, the
police and his doctors that the burns were caused by the explosion
of a car battery when he was giving someone a boost some two days
before the arson He remained off work, first of all on short-term
sickness benefits, then for two years on long-term income
protection through Confederation Life The employer discovered the
truth in September, 1991, when somebody read a newspaper report
about Mr Ally's arson conviction The employer ordered a
transcript of the reasons for decision and reasons for sentencing
of the trial judge and learned that Mr Ally had relied at trial
on the same exploding car battery explanation for his injuries
That explanation was not accepted by the trial judge and Mr Ally
was convicted of arson and sentenced to one year in jail
We admitted in evidence the transcripts, the Confederation
Life medical and other records and the evidence of Mr Barnes, for
the employer, as prima facie proof of the fact that Mr Ally
obtained his burns in the commission of arson and not some two days
earlier by means of an exploding car battery as alleged by Mr Ally
in all of his dealings with the employer, the insurance company,
his doctors and the police Mr Ally did not testify at our
hearing, and we find the employer s evidence to be conclusive of
the facts since not rebutted in any respect by Mr Ally
At issue is whether or not the employer had just cause to
terminate Mr Ally for "profiting from his criminal conduct" The
collective agreement provisions governing entitlement to sick
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benefits must be studied carefully to determine if a person is I
disentitled to benefits if they arise as a result of criminal
conduct It is not disputed by the employer that Mr Ally was in
fact seriously injured and unable to work during the full period
of time that he collected both short-term and long-term sickness
benefits
The short-term sickness plan is set out in Article 52 of the
collective agreement, the relevant portions of which read as
follows
"ARTICLE 52 - SHORT TERM SICKNESS PLAN
52 1 An employee who is unable to attend to his
duties due to sickness or injury is entitled
to leave-of-absence with pay as follows
( i ) with regular salary for the first six (6)
working days of absence,
(ii) with seventy-five percent (75%) of regular
salary for an additional one hundred and
twenty-four (124) working days of absence,
in each calendar year "
The long-term income protection plan 1.S set out in Article
42, the relevant portions of which are reproduced below
"ARTICLE 42 - LONG TERM INCOME PROTECTION
42 1 The Employer shall pay eighty-five percent
(85%) of the monthly premium of the Long Term
Income Protection Plan
42 2 1 (a) The Long Term Income Protection benefit
is sixty-six and two-thirds percent (66-
2/3%) of the employee's gross salary at
the date of disability, including any
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retroactive salary adj'ustment to which
the employee is entitled
42 2 3 Long Term Income Protection benefits commence
after a qualification period of six (6) months
from the date the employee becomes totally
disabled, unless the employee elects to
continue to use accumulated attendance credits
on a day-to-day basis after the six ( 6 ) month
period
42 2 4 Total disability means the continuous inability
as the result of illness, mental disorder, or
injury of the insured employee to perform the
essential duties of his normal occupation
during the qualification period, and during the
first twenty-four (24) months of the benefit
period, and thereafter during the balance of
the benefit period, the inability of the
employee to perform the essential duties of
any gainful occupation for which he is
reasonably fitted by education, training or
experience
42 3 The Employer will continue to make pension
contributions and premium payments for the
Dental Plan and for Supplementary Health and
Hospital on behalf of the employee, at no cost
to the employee, while the employee receives
or is qualified to receive L TIP benefits
under the plan, unless the employee is
supplementing aWe B award
42 5 Long Term Income Protection coverage will
terminate at the end of the calendar month in
which an employee ceases to be a civil servant
If the employee is totally disabled on the date
his insurance terminates, he shall continue to
be insured for that disability "
)
Nowhere in these collective agreement provisions is there a
limitation on eligibility for benefits based on an injury being
caused by criminal conduct The employer seems to rely upon the
rule of public policy that a person is not entitled to benefit
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from his own crime As union counsel points out, this is a policy
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which is deployed in insurance cases where, for lnstance, a person
tries to collect on a life insurance policy of a person he or she
has murdered, or to collect on a fire insurance policy where the
insured set the fire himself The issue is Can this rule of
public policy be imported into a collective agreement where
eligibility for benefits is clearly set out and not restricted by
the cause of the injury or illness Article 52 1 makes it clear
that "An employee who is unable to attend to his duties due to
injury is entitled to leave-of-absence with pay" Some
restrictions ensue in Article 52, but they do not have anything to
do with the cause of the injury
Employer counsel cited case law for the proposition that an
employee who is dishonest about his sick leave claims and induces
the employer to grant benefits based on false statements made by
him or her can be disciplined and/or denied the benefits The
problem in this case is that Mr Ally's dishonest explanations
about the cause of his injuries do not appear to go to the root of
his entitlement He was injured, he was unable to work, and no
provision in the collective agreement would seem to disentitle him
to benefits because of the causation of the injury The
Confederation Life insurance policy which we received in evidence
excludes benefits for "A disability caused by lntentional self-
inflicted injuries " This provision is not reflected in the
collective agreement and one can only speculate about a possible
remedy the insurance company may have against Mr Ally Certainly
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it is not within our mandate to enquire into that issue
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In a recent Grievance Settlement Board decision (Phillips,
GSB #2459/92 (Stewart)) a differently-constituted panel of this
Board was required to determine whether an employee who
deliberately and premeditatedly planned in advance to get drunk on
Sunday, thereby incapacitating himself for work on Monday due to
a hangover, was entitled to sickness benefits The Board reviewed
the collective agreement provision (in that case it was the
Canadian Union of Public Employees contract) relating to sick
leave and determined that "It is the existence of this objective
physical incapacity that determines illness and hence entitlement
to sickness benefits under the Collective Agreement " The CUPE
sick leave provisions are not materially different from the OPSEU
sick leave provisions in this regard The Board went on to muse,
at page 8 of the Phillips case, about why collective agreement
provisions as a normal rule do not contain restrictions for sick
leave eligibility based on self-infliction of illness
" To determine whether an incapacity constitutes an
illness on the basis of whether it is self-inflicted
creates real difficulties in application For example,
is lung cancer excluded from the definition of illness
for smokers? Are medical conditions associated with
obesity excluded? In a situation where a woman knows that
a pregnancy will be incapacitating, does her incapacity
not constitute an illness where she has chosen to become
pregnant? Would a different result follow if her
pregnancy were accidental? In our view, these examples
point out the flaws associated with employing the concept
of self-infliction as a basis for determining whether a
condition constitutes an illness The more appropriate
test, and the one that we adopt, is that illness and
hence entitlement to sick leave is established where the
objective evidence establishes a physical (or possibly
emotional) inability to perform work II
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The Board added a caveat to its finding at page 9 as follows
II Our conclusion in this case should not be construed
as an endorsement or condonation of Mr Phillips'
actions Mr Phillips made a conscious decision to drink
alcohol to the extent that he would be incapacitated and
thus unable to attend at work on January 27, 1992 He was
in breach of a fundamental obligation of an employee His
actions were inappropriate and might well attract a
disciplinary response by an employer "
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The Phillips Board was dealing with a denial of sick leave I
This is a discipline case and is therefore prima facie
distinguishable from the Phillips case Unlike the PhilliQS case,
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we cannot draw the inference that Mr Ally set fire to his hands: I
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in order to collect sickness benefits It seems from the findings
at his criminal trial that he set the fire in order to collect fire
insurance proceeds (which of course have been denied him) It was
as a result of his negligence ln setting the fire that he burned
his hands Can we really distinguish his case from that of the
drunk driver who gets himself into an accident while driving
impaired and makes a claim upon the sick benefits? Certainly the
parties are at liberty to include a restriction in their benefits
clauses excluding from coverage people whose negligent behaviour
causes the illness or injury, but they have clearly not done so,
and as the Phillips panel pointed out, it would create a slippery
slope indeed to determine what sorts of negligent or intentional
behaviour should come under the benefit ban
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Mr Ally was dismissed for "profiting from his criminal
conduct" by taking advantage of sick leave benefits The employer
is bound by that reason in seeking to uphold Mr Ally's dismissal
We can find no support for what union counsel describes as "that
fuzzy moral principle" in the collective agreement wording We
cannot alter, expand or modify the collective agreement In reaching
our conclusion As much as we might have liked to reach a different
conclusion in this case, based on moral principle, we cannot do so
The employer has not proved that Mr Ally was dismissed for
just cause and he must be granted a remedy We did not hear any
evidence from or on behalf of Mr Ally, so it is difficult for us
to fashion an appropriate remedy at this time We know that he was
incarcerated for about one year commencing around the time of his
dismissal and he was unavailable for work throughout that period
We know that the employer was trying to get Mr Ally to provide a
medical certificate of fitness to return to work in the summer and
fall of 1991, and we understand no certificate was provided This
could have an important bearing on the timeliness of any remedy
It appears Mr Ally still suffers injuries to this day that may
make him unfit for work We simply do not know Accordingly we will
not reinstate Mr Ally from the time of his dismissal as is the
usual case where just cause has not been found Instead we leave
the matter of remedy to the parties to resolve on their own We
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will remain seized of jurisdiction in the event they are unable to
fashion an appropriate remedy
Dated at Toronto this 14th da y 0 f December, 1994.
A Barrett, Vice-Chairperson
~d -
E Seymour, Member
'1 Dissent' Dissent Attached
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M Milich, Member
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Dissent in the Matter Between
Ally
and
Ministry of Transportation
GSB File 3085/92
I have reviewed the award in this case and cannot agree with the decision of my
colleagues.
The facts in this case are relatively straight forward. The grievor had been convicted
and sentenced for committing arson at the store that he and his wife owned. During
the commision of this crime, he sustained severe bums and was for a period of time
hospitalized. The court found, and this Board accepted as fact, that he sustained his
bums in the course of setting fire to his place of business and, not as, he claimed by a
battery exploding two days prior to the fire.
Mr Ally maintained the charade regarding how his injuries were sustained with the
employer, the insurance company, the police and his doctors throughout the period
from the fire in August of 1988 to September of 1991 when the employer learned
through a newspaper article that the grievor had been convicted of arson and
sentenced to one year in prison. Upon discovery of the conviction, the employer
instituted an investigation and ultimately dismissed the grievor
Mr Ally collected both short and long term sickness benefits under the collective
agreement based on his inability to work because of his bums. Even when the
insurance coverage ended and in the face of the employer"s continued inquirie about
his return to work, the grievor did not inform the employer of the pending charges or
later conviction.
The issue of Mr Ally's entitlement to benefits under the collective agreement is clearly at
the heart of the employer's case. It is my submission that Mr Ally's criminal activity
disentitled him from any benefits to cover his losses arising out of the fire he set to his
place of business. These losses, I submit, include the income which he lost as a result
of his inabiltiy to work because of his bums. These were the losses covered by the
income maintenance provisions for short and long term illness under the collective
agreement.
I believe that my COlleagues are taking too narrow a view of the rule of pUblic policy
argued by the employer's counsel. As I understand it, this rule has been developed
by the courts in contract and tort law and has been applied in insurance cases. Under
this rule, the courts have been unwilling to enforce an agreement where to do so
contravened public policy It has established what amounts to an implied term in a
contract that the courts will not enforce a claim which arises out of an individual's illegal
actions or activity directly connected with the injuries suffered by that person. In other
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words, an individual who suffers a loss for or by reason of the fact that he was engaged
in illegal conduct gets nothing. The courts have decided that a person's clear right to
an entitlement in these circumstances must be rejected as a matter of public policy
Therefore, a car thief who suffers injuries in an accident while speeding away in the
stolen car has been found not to be entitled to any compensation.
The grievor was convicted of arson by the court and found by the same court to have
sustained his bums during the commission of the crime This clearly falls within the
parameters outlined above and, therefore, he is disentitled to any benefits under the
agreement. By receiving the entitlement the grievor benefitted or profitted from his
illegal activities.
There is nothing new to this Board adopting principles developed by the courts to the
interpretation of a collective agreement, or for that matter to the relationship between
the parties. As a matter of public policy, arbitration boards have applied anti-
discrimination considerations to the interpretation of agreements even where no such
provision existed in the collective agreement. Estoppel has been adopted as a matter
of equity The courts have said that it is completely inappropriate to allow an individual
to succeed in a claim arising out of an illegal activity There is no bar to this panel
adopting a similar position. Neither the union nor the employer negotiated the income
maintenance provisions in the collective agreement expecting employees to obtain
them as a result of illegal activities.
Within this context, the case law cited by the employer's counsel regarding the
dishonesty of an employee in obtaining sick benefits will properly subject the employee
to discipline or dismissal is on point. As my colleagues recognize. the grievor's
explanations about the cause of his injuries were dishonest. Nor, did he ever inform
the employer about his pending charges and the possibility of his incarceration which
would and ultimately did prevent him from retuming to work. His behaviour allowed him
to collect the income maintenance benefits to which he was not entitfed under the
policy established by the courts. If the employer had not discovered, through the
newspaper article that the grievor had been convict of and sentenced for arson, his
further absence from work would have continued to be solely attributed to his injuries. I
submit that the grievor's behaviour and actions constituted such a fundamental breach
of trust that the employment relationship was destroyed and was, and should, remain
severed.
For these reasons, I would have dismissed the grievance.
,tv/c(JOeL,fl.
Michael Milich
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