HomeMy WebLinkAbout1992-3146.Dunlop.95-01-13
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{t>-. ONTARIO EMPLOYES DE LA COURONNE
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~ - CROWN EMPLOYEES DE L'ONTARIO
1111 GRIEVANCE COMMISSION DE
SETTLEMENT REGLEMENT
. BOARD DES GRIEFS
180 DUNDAS STREET WEST, SUITE 2100, TORONTO ON M5G 1Z8 TELEPHONE/TELEPHONE (416) 326-1388
180, RUE DUNDAS OUEST, BUREAU 2100, TORONTO (ON) M5G 1Z8 FACSIMILE/TELECOPIE (416) 326-1396
GSB# 3146/92, 455/93, 1690/93
'OPSEU# 93A229, 930553, 93F742
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECT IV. BARGAINING ACT
Before
THE GRIE~ANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Dunlop)
"' Grievor
- and -
The Crown in Right of ontario
(Ministry of Correctional Services)
Employer
BEFORE N. Dissanaya,ke Vice-Chairperson
P. Klym Member
M. Milich Member
FOR THE L Harmer
GRIEVOR Counsel
Gowling, Strathy & Henderson
Barristers & Solicitors
FOR THE M. Failes
EMPLOYER Counsel
Filion, wakely & Thorup
HEARING January 28, 1994
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PRELIMINARY DECISION
Three related grievances filed by the grievor, Ms. Kim
Dunlop, carne before this Board for hearing on January 28,
1994 Upon the agreement of the parties, only the preliminary
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issue as described below was dealt with that day While the
hearing itself was concluded on January 28, 1'994, the Board
subsequently received a series of correspondence from the two
counsel in which they presented to the Board submissions on
certain decisions of the Board which had been issued
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subsequent to the January 28, 1994 hearing. In making the
determinations herein, we have considered the submissions made
at the hearing as well as that contained in the written
submissions, the last of which was dated July 25, 1994.
At the commencement of the hearing employer counsel
conceded that the Board had jurisdiction to hear grievance no.
3164/92, but took the position that the other two grievances
were beyond the Board's jurisdiction The parties agreed to
hold file 3164/92 in abeyance and to Ideal with the
jurisdictional issue relating to files 0455/93 and 1690/93. "-
( This decision therefore deals solely with that preliminary
issue as to whether the Board has jurisdiction to hear the
merits of the grievances in files 0455/93 and 1690/93
The facts relied upon by the union are as follows The
grievor commenced employment with the Ministry at the
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Millbrook~.! Correctional Centre in December 1989, in the
capacity of a Correctional Officer 1 as a member of the
unclassified service In that position she was a casual
employee working on an "on call" basis She initially had a
series of 3 month contracts but since January 1991 started I
receiving contracts of6 month duration.
The grievor's husband is a correctional officer in the
classified service and also works at Millbrook He does shift
work They have two young children When she was called in
to work, sometimes her husband was also on shift. If neither
parent was available to be with the children, they had to rely
on relatives to baby-sit. However, baby-sitting arrangements
could not always be made because the employer gave her very
little lead-time when calling in
Sometime in 1992 the employer commenced to keep records
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of the on-call employees' availability for shifts The
employer met with a number of employees whose availability was
deemed not acceptable On October 28, 1992, the
superintendent had a meeting with the grievor at which he
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raised concerns about her record of availability The gr ievor
explained that in many cases her unavailability was due to her
inability to make baby-sitting arrangements at the last
minute The superintendent's response was to advise her that
"if Millbrook does not suit your family's needs, then you
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should look for something else " On November 17, 1992 the
grievor filed a grievance relating to that incident, which has
now become file 3164/92, which the parties have agreed to hold
in abeyance
It is alleged that fOllowing the filing of the grievance
and in direct retaliation for her actions, the gr ievor was
subjected to various incidents of unfair treatment and
harassment, which the union claims culminated in the grievor
receiving only a 3 month contract when her last 6 month
contract expired at the end of March 1993. This resulted in
grievance no. 0455/93.
It is alleged that the pattern of harassment and
discrimination continued after March 1993 and that it caused
the grievor to go on sick leave in May 1993 due to stress.
Then she received notice on June 22, 1993 that her contract
would not be renewed beyond its expiry date of June 30, 1993
That non-renewal forms the basis of the grievance in file
1690/93.
I with regard to file 0455/93, it is the union's position
I that the employer's decision to limit the grievor's contract
I to 3 months rather than the usual 6 months was because of (a)
I her unavailability for shifts due to baby-sitting problems (b)
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the employer's desire to penalize the grievor for having filed
the discrimination grievance (no. 3164/93).
with regard to file 1690/93, the union claims that in
deciding not to renew the grievor' s contract in June 1993, the
employer was similarly motivated by (a) the fact 9f the
grievor's unavailability for shifts due to baby-sitting
problems, and (b) a desire to penalize the grievor for having
filed the two previous grievances.
It is the contention of the union that in both
situations, the employer's consideration of the grievor's
unavailability for work due to family obligations as a basis
to adversely affect her employment was both a direct and
adverse impact discrimination contrary to article A-1-1 and
that the employer had an obligation to accommodate the grievor
to the point of undue hardship It is further alleged that
the employer's desire to retaliate against the grievor
because she filed grievances as well as the discrimination
contrary to article A-1-1 constitute bad faith.
Counsel for the employer made it clear that the employer
was not conceding any of the factual allegations However, he
agreed that solely for the purposes of arguing the
jurisdiction issue, the Board should assume the alleged facts
to be proven and further assume that those facts establish
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discrimination contrary to article A-1-I, as well as bad faith
on the part of the employer His position quite simply is
that the Board has no jurisdiction to inquire into the
employer's reasoning or motivation for determining the length
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of the contract of an unclassified employee or for deciding
not to offer a further contract upon the expiry of the
existing one In other words, he submits that even if the
employer's decisions were motivated by discriminatory or bad-
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faith reasons, that does not confer jurisdiction on the Board
to deal with the merits of these grievances.
The following statutory provisions were relied upon:
The Crown Employees Collective ~argaining Act,
R S O. 1990, c. C 50, s 18 (1) a
18 (1) Every collective agreement shall be deemed
to provide that it is the exclusive function of the
emp19yer to manage which function, without limiting
the generality,of the foregoing, includes the right
to determine,
(a) employment, appointment, complement,
organization, assignment, discipline,
dismissal, suspension, work methods and
procedures, kinds and locations of
equipment and classifications
The Public Service Act, R S 0 1990, c. p 47:
8 (1) A minister or any public servant who is
designated in writing for the purpose by him or her
may appoint for a period of not more than one year
on the first appointment and for any period on any
subsequent appointment a person to a position in
the unclassified service in any ministry over which
the minister presides
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(2) Any appointment made by a designee under
subsection (1) shall be deemed to have been made by
his or her minister
9 A person who is appointed to a position in the
public service for a specified period ceases to be
a. public servant at the expiration of that period.
Reliance was also placed on section 8 1 of the Public
Service Act which was enacted in 1993 to be in force
retroactive to December 18, 1991. It reads:
8.1-(1) An individual is not considered to be a
civil servant unless he or she has been
expressly appointed as such by the
Commission or by the Lieutenant governor
in council on the certificate of the
Commission.
(2) An individual is not considered to be a
public servant unless he or she has been
expressly appointed as such by the
Lieutenant Governor in Council, the
Commission, a minister or a designee of a
minister.
(3) An individual who is employed in the
service of the Crown is not considered to
be a Crown employee unless the individual
has been expressly appointed as such by
the Lieutenant Governor in council, the
Commission or a minister
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(4) If the Lieutenant Governor in Council
makes a regulation requiring the
appointment of a civil servant, public
servant or Crown employee to be made in a
form prescribed in (the regulation, an
indi vidual is not considered to be a
civil servant, public servant or Crown
employee, as the case may be, unless his
or her appointment is made in the
prescribed form.
(5) Subsection (4) does not apply to an
individual who was expressly appointed as
a civil servant, public servant or Crown
employee before the day on which the
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regulation is pUblished in The Ontario
Gazette.
(6) An individual who is employed in the
service of an agency of the Crown
designated in the regulations is not
considered to be a Crown employee unless
the agency has the authority to appoint
its employees and the individual has been
expressly appointed as a Crown employee
by the agency.
(7) The Lieutenant Governor in Council may,
by order, direct an agency of the Crown
designated in the regulations to
expressly appoint as a Crown employee an
individual who is employed in the service
of the agency.
(8) If the agency does not make the express
appointment within the time indicated in
the order, the Lieutenant Governor in
Council may, on behalf of the agency,
expressly appoint the individual as a
Crown employee.{
(9) An individual who is employed ,in the
\.., service of an agency of the Crown that is
not designated in the regulations is not
considered to be a Crown employee.
(10) In the absence of an express appointment
of an individual as a civil servant,
publ ic servant or 'Crown employee, the
individual's appointment shall not be
inferred solely from the circumstances of
his or her employment.
( 11) This section is deemed to have come into
force on the 18th day of December, 1991
The relevant provision of the collective agreement reads.
ARTICLE A - NO DISCRIMINATION/EMPLOYMENT
EQUITY
All. There shall be no discrimination
practised by reason of race, ancestry,
place of origin, colour, ethnic origin,
citizenship, creed, sex, sexual
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orientation, age~ marital status, family
status, or handicap, as defined in
section 10(1) of the ontario Human Rights
Code (OHRC).
Counsel for the employer relies on sections 8 and 9 of
the Public Service Act as the legal basis of his objection to
jurisdiction Relying on the new section 8.1 he argues that
it reconfirms that the only way one can be appointed to the
classified service is by the procedures set out in that Act
He cited the following decisions in asserting that the Board
has accepted that it had no jurisdiction over employer
decisions relating to utlclassified contracts. Re Simpson
694/85 (Kennedy) , Re Shipley, 0223/86 (Samuels) Re Healey,
0485/88 (Fisher) and Re Milks, 1000/92 (Low).
Counsel for the union submits that while appointment to
the unclassified service and renewal of expired contracts are
generally outside the scope of the Board's review, in the
particular circumstances of this case the Board had
jurisdiction First, it is submitted that where the
employer's decision with regard to appointment, i e to limit
the duration of appointment or to not appoint, has been made
for discriminatory reasons contrary to article A.1.1 of the
collective agreement the Board has jurisdiction Secondly,
the union submits that where those decisions were made in bad
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faith, i e for discriminatory reasons ,and motivated by a
desire to penalize the grievor for having exercised her
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collective agreement right to file grievances, the Board has
jurisdiction It is submitted that to hold otherwise would
result in denying the grievor the benefit of the protection of
article A.1.1 against discrimination and of article 27 which
grants her the right to grieve.
union counsel noted that the decisions relied on by the
employer were decided before article All came into existence
and that while the Milks case was post-article All it made
no reference at all to that article She submitted that the
current law is that contained in the following decisions which
considered the Board's jurisdiction after the enactment of
article All. Re Pitirri 1685/92 (Kaplan), Re Merson 16/93
(Gray) and Re Chircop, 3039/92 (Kaufman) .
In Re Pitirri (supra) the grievor alleged that he had
been unjustly dismissed The employer argued that the grievor
was an unclassified employee whose last contract was not
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renewed, and that S1nce he was no longer an employee after the
expiration of the contract, he had no right to grieve. It was
the employer's position that the Board had no jurisdiction to
determine the grievance In Re Pitirri, the grievor had a
number of employment contracts starting December 4, 1989. His
last contract ran from April 1, 1992 to september 30, 1992
In 1992 he was diagnosed as suffering from ulcerative colitis.
In July 1992 he submitted a medical note which disclosed the
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diagnosis and stated that "he should avoid shift work"
Shortly before the expiry of this last contract the employer
made an offer to accommodate the grievor's illness, which was
contained in an employment contract scheduled to run from
October 1, 1992 to March 31, 1993 It was clear that had the
grievor accepted that offer of accommodation, he would have
been appointed pursuant to that contract. However he did not
accept the contract and took the position that the
accommodation offered was inadequate for his medical
condition. Despite the employer's efforts to convince the
grievor that the accommodation offer was adequate, the grievor
refused to sign the contract on those terms. The ultimate
result was that the grievor's contract was not renewed
The aoard at pp. 14-15 stated
While it is undoubtedly the case that unclassified
employees, at the conclusion of their contract,
have no new Collective Agreement rights, it cannot,
in our view, be correct that the conclusion of an
unclassified employee's contract of employment
extinguishes rights which arose during the period
of employment when the employee was covered by the
Collective Agreement
Article 3 of the Collective Agreement sets out
various entitlements of unclassified employees
What if, for instance, an unclassified employee was
not paid overtime on the last day of his or her
employment According to Mr Benedict, the next
day that person would not be an employee but would
be a member of the public with no right to grieve
and the Board would be without jurisdiction to hear
that grievance In our view, where a Collective
Agreement, entitlement arises during the course of
employment, in some circumstances the individual
may remain an employee for the purpose of filing a
grievance after the employment relationship has
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come to an end Whatever the decision in Parry
stands for, it is not the proposition that
Collective Agreement and statutory rights of
employees that arise during the course of
employment are in every case extinguished at its
conclusion To reach this result would be to deny
employ,ees in some cases, such as this one, the
benefit of the Collective Agreement
In this case the grievor's Article A rights were
allegedly infring~d while he was an employee, and
it is on this basis that we are taking jurisdiction
with respect to his case The first accommodation
offer was made to him one week prior to the end of
his employment contracted and was repeated on the
last day of that contract The offer was declined,
and a timely grievance was filed Obviously in
taking juri~diction in this case we are making no
findings whether the employer had an accommodation
obligation, and if it did have such an obligation,
its nature and extent All we are doing is finding
that th~re might have been a violation of Article A
while the grievor was an employee, and that this
alleged violation is properly before the Board As
already indicated, the fact that the grievor would
have been offered a successor contract had he
accepted the employer's accommodation offer has
figured prominently in our deliberations It is in
this respect that the grievor's allegation of
unjust discharge is directly linked to the
allegation of a violation of Article A
While all the evidence is not in, it is worth
observing at this point that the employer's general
approach to this grievor raises more questions than
answers. The duty to accommodate necessarily
involves consultation with the affected employee
who must in turn respond reasonably to bona fide
accommodation offers A "take it or leave it"
approach in the last week of an employee's
contract, with a promise of renewal if the employee
"takes it", and the prospect of no, further
employment if he or she "leaves it" would not
appear to satisfy the employer's obligation to
effectively consult with the employee To
countenance such an approach would be to gut the
provision, in sofar as it covers unclassified
employees, particularly in a case such as this one
where the grievor had been employed under
successive contracts for several years, and only
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stopped being e~ployed when he sought accommodation
under Article A and did not accept the
accommodat1on that was offered to him In reaching
this conclusion we are not granting any new rights
to unclassified employees at the end of their terms
of employment Rather, all we are doing is
recognizing the necessarily continuing nature of
some Collective Agreement rights including Article
A rights which arise while an individual is an
employee.
Accordingly, the line of cases relied on by the
employed about the status of former unclassified
employees are of no assistance to us in this case.
Likewise, the pre-Beresford cases are of little
value for they predate the existence of Article A.
While panels of this Board were once prepared to
find that a proven violation of the ontario Human
Rights Code was inarbitrable, the existence of
Article A changes that situation for its
incorporation into the Collective Agreement means I
that its alleged violation is properly within the
jurisdiction of the Board.
It is to be noted that the "line of cases" the Board
found to be of no assistance included Re Shipley and RE
Healey, both of which pre-dated article A 1, and which are
relied upon by the employer here
In Re Merson, the grievor was an unclassified employee ,
who had a series of contracts between September 1990 and June
30, 1993. In October 1992 he was injured at work and made a
worker's compensation claim On his return in December, 1992,
he grieved that his work assignments had been changed This
grievance was settled While all his prior contracts were of
6 month duration, in February 1993 the grievor was informed
that upon the expiry of his last 6 month contract on March 31,
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1993, his contract would only be renewed for 3 months He
grieved that decision alleging discrimination On June 22,
1993 he was informed that his contract would not be renewed
beyond June 30, 1993 This decision was also grieved
The employer argued that the Board lacked jurisdiction to
review the length of an unclassified employee's term contract
nor a decision about whether to renew such a contract
The union alleged that the employer's decision to limit
the contract to 3 months and subsequently1to not renew was a
response I to the grievor's injury and workers compensation
claim, as well as his filing of grievances. The union argued
that as an unclassified employee the grievor was covered by
article A (no discrimination) and article 27 (Right to
grieve) . It was the union's position that the employer's
decision to limit the grievor's contract to 3 months and
subsequently to not renew was because he had been injured at
work and had made a worker's compensation claim. These
decisions were made while the grievor was still an employee
and were contrary to article A 1 Similarly, it was argued
that retaliation because the grievor filed grievances amounted
to a denial of the grievor's right under article 27 to grieve.
The Board in Re Merson reviewed the Board's decision in
Re Pitirri, and at pp. 8-9 concluded as follows
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It is true that the factual allegations in
Pitirri were different form those here There, the
disability was persistent and required
accommodation. The employer had offered a form of
accommodation which the grievor considered
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~nadequate The gr~evor was told h~s contract
would be renewed if he agreed to the accommodation
offered. When the grievor persisted in his
,position that the offered accommodation I was
insufficient, his contract was not renewed Here,
there is no allegation that the grievor required
accommodation at the t~me of the impugned
decisions Here, the allegation is that the
employer responded improperly to past events
Given the OHRC definition of "because of handicap"
which the parties have incorporated by reference
into Article A, discrimination because of a past
Workers' Compensation claim is as much a violation
of Article A as a failure to accommodate an ongoing
handicap.
The fact that there is no issue of accommodation
here is not a material aistinction for purposes of
the question now before us. Here, as in pitirri,
the union alleges that a decision not to renew the
contract of an unclassified employee, made while
the individual was still employed and covered by
the parties' collective agreement, constituted
discrimination contrary to Article A of that
collective agreement Here, as in pitirri, the
union alleges that but for the discrimination, the
grievor's contract would have been renewed As in
Pitirri, the issue at this stage of these
proceedings is not whether these allegations are
true; the issue is whether they raise an arbitrable
dispute In pitirri, the Board found that it did
We do too, and for essentially the same reasons
Finally in Re Chircop, the Board held following the
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reasoning in RE Pitirri and Re, Merson, that the Board had
jurisdiction to review appointments to the unclassified
service where there was an infract~on of article A
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Counsel for the employer distinguishes the facts here
from the facts in Re Pitirri He reads the decision in Re
Pitirri as merely holding that the Board had jurisdiction to
deal with a violation of article A 1 which took place during
the period of time when the grievor was still an employee
under contract In that case, according to him the violation
over which the Board seized jurisdiction was the failure of
the employer to offer accommodation in accordance with its
( obligation under article A 1 He compares that situation to
the grievance filed by Ms Dunlop (file 3164/92) alleging
discrimination based on the superintendent's statement to her
at a time when she was still an employee. He concedes that
the Board has jurisdiction in those circumstances. However,
he contends that the Board has no jurisdiction to review the
\ employer's decision at the end of a contract, as to the length
of the next contract or its decision not to offer any contract
at all
Counsel quite bluntly submits that the decisions in Re
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Merson and Re Chircop are simply wrong in assuming
jurisdiction to review employer decisions as to the
renewal/length of unclassified contracts.
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We cannot agree with the restrictive reading of Re
Pitirri advocated by employer counsel At p 2 the Board
notes that the grievor "grieves that he has been unjustly
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dismissed from employment It is clear that the grievor was
alleging that this unjust dismissal took place when the
employer decided not to renew his contract In that case, the
employer's offer of accommodation and the grievor' s refusal to
accept the same were considerations which ultimately caused
the employer to decide not to renew the grievor's contract.
At p. 15 the Board states "As already indicated, the fact that
the grievor would have been offered a successor contract had
he accepted the employer's accommodation offer has figured
prominently in our deliberations. It is in this respect that
the grievor's alleqation of unjust discharqe is directly
linked to the allegation of a violation of Article A. "
(Emphasis. added)
The grievance there was about the "unjust dismissal"
arising out of the employer's decision to not renew the
employment contract The Board seized jurisdiction over that
grievance on the grounds that the employer's decision was
tainted by an inappropriate consideration, namely, the
employer's unwillingness to accommodate the grievor's
disability as required by article A
The Merson case is remarkably similar to the case before
us. There the Board seized jurisdiction to review the
j employer's decisions to limit the grievor's contract to only
3 months and to subsequently not renew it at all, on the basis
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that there had been violations of the collective agreement in
the course of the decision making process
In those cases the factual basis for the employer's
decision [i e. the failure to accommodate (Re Pitirri) and the
grievor's claim for workers' compensation ~nd filing of
grievances (Re Merson)] which gave rise to the violation of
the collective agreement, occurred while the grievor was still
an employee. And the employer's decision with respect to
renewal were also made while the grievor was still an
employee. Thus the employer's decisions regarding the i
unclassifi:~d contracts were "directly linked" to the
violations of the collective agreement
The case before us is no different. On the assumed
facts, the employer's decisions with regard to the grievor's
employment contracts were taken for discriminatory reasons,
which are proscribed by the collective agreement, arising out
of circumstances that occurred during the grievor's period of
employment
We do not find the Pitirri, Merson or Chircop decisions
to be manifestly wrong. Indeed, we find that, the only
sensible interpretation of the relevant statutory provisions
is that taken in those case The employer in those cases
relied on the same pre-article A line of cases The Board in
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each case took a different approach in view of the existence
of article A We agree with the approach in the post-article
A cases. To do otherwise would be to draw an artificial
boundary between the events which occurred during the tenure
of the contract and the renewal decision, when in fact the
renewal decision is inextricably linked to those events which
form the basis of the violation of the collective agreement
For all of the foregoing reasons, we have concluded that
if the union is correct that the impugned decisions of the
employer were taken because of reasons which constitute a
violation of the collective agreement, the Board does have
jurisdiction to deal with the two grievances in question
Having rendered our decision as to the board's
jurisdiction, we refer the matter back to the parties Unless
the parties are able to resolve these grievances, either party
may request for a hearing of the mer its of the grievances
before a panel of the Board. This panel is not seized of
jurisdiction for that purpose
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Dated this 13th day of January, 1995 at Hamilton, ontario
N Dissanayake
Vice-Chairperson
ll(-~l/~
p Klym
Member
'I Dissent' Dissent Attached
M. Milich
Member
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? Dissent in the Matter Between
OPSEU (Dunlop)
and
The Ministry of Corredtional Services
I have read the award in the above matter and must disagree with the decision.
The fundamental issue with which we are dealing is a time limited contract of
employment. The unclassified employee entered into an individual employment
contract with a specified commencement and expiry date. Upon expiry of the contract,
the employment of the individual ends. There is nothing in the collective agreement nor
in the statutes which guarantees the renewal of the contract to the unclassified
employee, or, for that matter, obligates the employer to grant a new a contract. In fact,
s. 9 of the Public Service Act reinforces the cessation of the employment relationship
when It states that at the end of the contract the individual is no longer a publiC servant
Once the contract has expired on its specified date, there is no issue of dismissal
which would permit the board to review the employer's actions under s. 18(2) of the
Crown Employees Collective Bargaining Act. This seems to be the principle which all
the cases from Shipley 223186 (Samuels) through Milks 1000192 (Low) and Chlrcop
3039/92 (Kaufman) seem to accept
In Chlrcop, the Vice-Chair, while attempting to rationalize the different approaches
taken by various panels, found that as atirst principle the board under the normal
course of events did not have any jurisdiction to review the decision of the employer not
to renew an \lnclassified employee's contract, even in the face of bad faith. On page
16, she states: -
"It is clear as a first principle that the appointment ( and non-appointment) of
employeees to the unclassified public service is a function reserved exclusively to
management by statute and that upon the expiry of an appointment to the unclassified
public service, the person so employed ceases to be a publiC servant. In situations
where an employee's appointment is simply not renewed, that will usually end the
matter, and a panel of the Grievance Settlement Board will not take jurisdiction of a
grievance from the non-renewal or dismissal, notwithstanding an a/legation of bad faith:
Milks. supra"
She does, as do my colleagues in this case and the Vice-Chairs in Pitlrrl1685192
(Kaplan) and Merson 16193 (Gray), accept the line of cases which found that Article A
allows a board to review the employer's decision not to renew I submit, however, that
in doing so the board is exceeding its jurisdiction. Article A does not change the simple
fact that the unclassified employee and the employer agreed to the terms of the
contract before it was accepted and signed by both. The employee by signing the
contract agreed that hislher employment would end at the expiry of the contract. It is
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that simple However one wants to view it, Article A does not override the expiry date
It does not provide the employee with a promise of continued employment.
There is no question that Article 3 provides an unclassified employee with certain
benefits and a degree of protection under the collective agreement, including Article A.
These rights are for the term of the contract of employment which the employee signed.
These rights do not survive the expiry of the contract except for the right to grieve, in a
timely fashion, a contravention of the collective agreement during the term of the
contract To the extent that the decisions cited above upon which my colleagues rely
purport to extent the Board's jurisdiction and remedial authority beyond the expiry date
of the employment contract, they are incorrectly decided. The board's jurisdiction to
review and to provide a remedy is resticted to the term of the employment contract. Its
authority does not go beyond the the expiry of the contract.
S. a and s a 1 of the Public Service Act clearly outlines who has the authority to appoint
public servants. The Board is not one of those authorities. We should bear in mind
that, whatever the semantics may be, a renewal of a contract is in fact the granting of a
new contract of employment and can only be done in accordance with s. a and s. a.1
The collective agreement does not override these statutory requirements.
In circumstances that parallel the type of case that we have before us, the panel in
Hunt GSB #2562/92 (Devlin) found that it had no jurisdiction to hear the grievance. In
that case, a retiring employee had grieved that the employer had not granted him an
overage appointment The panel found that it had no jurisdiction because these
appointments were not covered by the Crown Employees Collective Bargaining Act nor
the collective agreement. That is exactly the type of situation we have here. Article 3
and its collective agreement protection is triggered after the unclassified employee has
signed hislher contract and has been appointed to the public service in accordance
with s.a and 8.1 The collective agreement's protection ends with the expiry of the
contract both by its own terms and under statute. We do not have the authority to go
beyond the term of the contract of employment whatever the employer's reasons for
not granting a new contract may be. We do not have the authority to imply any sort of
permanence to what is essentially a temporary arrangement regardless how often the
contracts may have been renewed. Whatever wrongs may need redress must find a
forum other than this one for thier resolution.
For these reasons I would have found that we do not have the juri~diction to hear this
grievance.
d~flV:Cx
Michael Milich
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