HomeMy WebLinkAbout1992-3166.Muir.94-01-12
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ONTARIO EMPLOYES DE LA COURONNE
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1111 SETTLEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST SUITE 2100 TORONTO, ONTARIO, M5G-1Z8 TELEPHONE/TELEPHONE (4,16) 326-1388
180" RUE DUNDAS OUEST BUREAU 2100 TORONTO (ONTARIO) M5G lZ8 FACSIMILE/TELECOPIE (416) 326-1396
I 3166/92
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Muir)
Grievor
- and -
The Crown in Right of ontario
(Ministry of Labour)
Employer
BEFORE: O. Gray vice-Chairperson
s. Urbain Member
M O'Toole Member
FOR THE J. Paul
UNION Grievance Officer
ontario Public service Employees Union
FOR THE B. Doherty
EMPLOYER Employee Relations Officer
Management Board Secretariat
HEARIN,G september 9, 1993
December 7, 1993
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AWARD
The gnevor was appomted to the staff of the Employment Practices Branch of the
MInIstry of Labour effective December 30, 1991 On December 31, 1992 she receIved
a letter from the acting Deputy MImster purporting to release her from employment
In accordance Wlth subsection 22(5) of the Publw SerVLce Act effective December 28,
1992 She gneved.
When the arbItratLOn oftms gnevance came on for heanng on September 9, 1993,
the parties agreed that we should first determme whether the gnevor had been
released pursuant to subsection 22(5) of the Publtc SerVLce Act, haVing regard to the
ttmtng of the employer's communIcations Wlth the gnevor After heanng the parties'
eVidence and argument and deliberatmg bnefly on that pomt, we ruled orally that the
gnevor had not been released m accordance Wlth subsectlOn 22(5) of the Publte ServtCe
Act We undertook to give wntten reasons for thatruhng at a later date. The parties
agreed to adjourn the heanng 'of remamm~ ISsues to a senes of future dates. When the
heanng resumed on December 7, 1993, the parties adVised us that they had reached
a settlement, wluch they Wished mcorporated mto an order of thIS Board.
TIns Award sets out our reasons for the rulmg of September 7, 1993, and our order
giVing effect to the parties' subsequent settlement.
The Preliminary Issue
In November 1992, Paul Evans, the actmg manager of the gnevor's unIt, approved
her takIng her vacation from December 17, 1992 to January 4, 1993, InclUSIVe On
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December 16, 1992, moments before the gnevor was to leave on vacatIOn, Mr Evans
handed her the folloWing note
JudIth,
You will recall that during our meetmg on December 10 1992 I dIscussed with you the
possibihtyof an extension of your probationary period of employment. As I advised you,
the weekly file reVIew sessions followmg our November meetmg wIth John Williamson
dId not show any significant improvement in your performance, which I had indicated
would be required during the remainmg six weeks of your probatIOn. Mr William soon
[SIC] expressed the view that no extension to the probationary period was possible. He
dId, however, mdicate that he would seek adVIce on the issue and provide me WIth a
definIte answer
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My telephone calls to John Wilhamson yesterday afternoon and today have not been
returned. As a result, I have receIved no response to my proposal and must assume that
it is being rejected.
As you are scheduled to be on vacatIOn startmg tomorrow, any deadhne relating to a
deciSIon appomting you to permanent staff will pass during your vacation.
I must confirm to you that it is unlikely that I will recommend your appointment to
permanent Mmistry staff, whIch means that a deCISIon to release would follow
You should expect to meet with me upon your return from vacatIOn on January 5, to
finalize this matter You may WIsh to have a representatIve of your union present for
- any such meeting.
On December 18, 1992, Mr Evans secured the actmg Deputy MinIster's SIgnature
on a letter addressed to the gnevor The letter smd this.
I have recently been advised of the ongomg concerns of your manager regardmg your
ability to meet the requirements of your position as a CollectIOns and Legal Action
officer in the Employment Practices Branch, Collections Umt. Your manager has
reported that he IS not prepared to recommend your permanent appomtment to the
classuied servIce.
As you have been advised, a newly appomted pubhc servant must meet the full duty
requirements of the position within the first year of employment. Smce you have failed
to meet the requirements of your positIOn, I am notuying you of your release from
employment with the MinIStry of Labour m accordance WIth Section 22(5) of the Public
ServIce Act.
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You are hereby released effective December 28, 1992. From today, you are not required
to report to work. In lIeu of notice, you will receive two weeks' pay in accordance wIth
Section 57 of the Employment Standards Act.
I wIsh you the best In your future endeavours.
Mr Evans testIfied that he thought that thIS letter was sent by regIstered mail on
December 18, 1992 He dId not mail It hImself, however The person who dId that dId
not testily The gnevor received the letter by regIstered mail III early January 1993,
m an envelope post-marked December 24, 1992 That post-mark IS the best eVldence
before us of when the letter was mailed. December 24, 1992 was a Thursday It was
also Chnstmas eve. There was no reasonable prospect that a letter tendered to the post
office ~m that date for dehvery by regI.stered mail would reach the gnevor before the
end of her probatIOnary year
The gnevor testrfied that she waS at her home m Toronto until December 21, 1992,
when she left for Flonda. There IS no eVldence of any attempt to contact her before
then. The grievor returned home on December 31, 1992 Some tIme that day a couner
arnved at her home With a copy of the letter of December 18, 1992 The bill of ladIng
which accompanIed the letter appears to IndIcate that tlus copy of the letter was put
m the hands of the couner on December 30, 1992
SectIon 22(5) of the Publ~c Sermce Act, whIch proVldes that
22(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.
The subsectIon speaks of a "release from employment" "dunng the first year of
employment." It does not specIfy how the deputy mInIster IS to go about releaSIng an
employee
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A "release" IS a termInatIOn of employment. Employment IS a contractual
relatIOnshIp whIch may be brought to an end In a vanety of ways ThIS IS not the
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occaSIOn for an extended dIscourse on that subject. Suffice It to say that unless It
proVIdes otherwIse, a contract of employment of mdefimte duratIOn will not be brought
to an end by the mere desll'e of the employer to end It rl'the employee has no notlce of
that desire.
The employer dId not challenge the proposItlon that the employee must be given
notlce of it In order for a decisIOn to release to be effectlve It dId not suggest that
Mr Evan's memo of December 16,1992 had gIven the gnevor the required notlce, and
It IS clear that It dId not. The employer's argument was that notIce was given on
December 18, 1992, when It clalmed the actlng Deputy MinIster's letter had been
mailed. In the altemauve, It argued that notlce must be treated as haVIng been glven
a reasonable tIme after the letter was mailed. In support of tlns, the employer's
representative argued that the Government of Oiltano should not be "penalIZed
because the Post Office IS slow", and expressed a concern that a requirement that the
notIce be receIved In order to be effective would be problematic rl' an employee went
Into hIding to aVOId notice. I
The umon's representatlve argued that the employer's pOSItIOn that the notlce was
effectIve when mailed IS mconsIstent With the result In WaLnnght et al., 0717/88
(l\1cCamus) There, the Crown successfully argued that an apphcatlon to the Gnevance
Settlement Board for the heanng of a gnevance IS not made until receIved by the
Board. an apphcatIOn mailed before but receIved after the tlme hmIt specIfied In the
collectlve agreement was ruled untimely
The union's representative also referred to the awards of arbItrator O'Shea In Re
Holmes Foundry Ltd. and Umted Automobde Workers, Local 456 (1974) 7 L.A.C (2d)
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276 and Re Madame Van~r Ch~ldren s Serv~ces and Ontano Publw Sermce Employees
Unwn (unreported decIsIon dated February 13, 1984) In iboth cases the Issue was
whether the gnevor had completed hIS or her probationary penod before beIng
dIscharged.
In Holmes Foundry, supra, the gnevor had completed worlang the last day of hIS
probatLOnary penod when he was told he was suspended as a result of somethIng the
employer learned had taken place that day He was later dIscharged effective that day
He gneved. The employer obJected that the gnevance was In arbItrable because the
gnevor was still a probationary employee. ArbItrator O'Shea held that the dIscharge
could not be effectIve anyearher than the pOInt In time when the gnevor was told he
was bemg suspended. He then observed that
In the mstant case the company has the onus of proving that the dIscharge took
place prior to the completIon of GO days worked by the grlevor If the company had
informed the grievor that he was discharged prior to the completion of his work on May
17th, hIS discharge would have been prIor to the completIOn of this 60th workmg day
and would therefore not be subject to the grievance procedure.
Although it is true that it is the company's right to decide whether an employee
is satisfactory, this decision must be taken and acted upon prior to the completion of the
60th workIng day in order to prevent the employee from havmg the rIght to grieve hIS
discharge pursu~nt to art. 8.(2)(c) of the collectIve agreement.
In Vamer Chddrens SerVtces, supra, the employer had notIfied the gnevor that hIS
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employment would be tennmated at the end of the last day of his probatIOnary penod.
The relevant prOVISIOns of the collective agreement prOVIded that an employee
tennmated "dunng his probationary penod" would not acqUire senIOnty and could not
grIeve termInation. The maJority award held that for an employee to be termInated
"dunng lus probabonary penod" Ius work would have to be dIscontInued before the end
of the probabon penod. an employee ternunated at the end of the penod had the nght
to gneve the termInatIOn.
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N eIther of these awards of arbItrator O'Shea had to address the preCIse
proposIbons In ISSU~ here that nobce of termmatIOn IS effecbve eIther when maIled,
or WlthIn a reasonable bme thereafter The employer's representative argued that
there IS a common law rule that nobce IS effective when maIled. He offered no
authonty for that proposIbon, however, and we are not aware of any
As a matter of general pnncIple, a nobce sent to someone has legal effect only
when It comes to hIS or her attentIOn, m the absence of an apphcable statutory or
contractual rule to some other effect. It was not suggested that there IS any apphcable
statutory or contractual rule. 1\.8 for the argument about employees' gOIng Into huhng
to aVOId recelVlng trmely nobce of release, It IS hard to Imagme that an employee's
gOIng mto ludmg for that reason would not Itself proVlde cause for the very result It
sought to aVOId. In any event, that IS a problem best addressed If and when It ever
anses. If anyone was hldmg here, It was not the grlevor
N obce to the gnevor was not effecbve when maIled. In our Vlew, It was only
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effecbve when receIved. The result here would not have been dIfferent, however, If the
rule were that mailed nobce was effecbve Wlthln a reasonable brne after mailing A
reasonable tIme would be the tune Wltlun wluch It wouid be reasonable to expect that
the nonce would come to the attenbon of an addressee who was not aVOIdIng It. As we
have already observed, there was no reasonable prospect that a letter tendered to the
post office on thursday, December 24, 1992 for dehvery by reglstered mail would reach
the gnevor before Wednesday, Decembe'l" 30,1992, the anmversary of her first day of
employment. .
Because the gnevor was not glven nobce dunng the first year of her employment
of the actIng Deputy Mimster's deCISIon to release her, the release was not effected
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WIthm the tune contemplated by subsectLOn 22(5) of the Publ~c Serv~ce Act and, so, she
was not released In accordance WIth that subsectIOn
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The Settlement
At the heanng held on December 7, 1993 we were adVIsed that everyone In the
umt ill winch the gnevor would have continued to work had she not been released has
Sillce been declared surplus. The partles told us they had agreed that she be reInstated
and made, whole for any loss flOWIng from her termmatIOn In particular, the parties
have agreed that
1) the employer shall remstate the gnevor to employee status effective as of the
date her employment was termmated, so that her senIOnty and benefits
entitlement will be what they would have been had her employment not been
termInated,
2) the employer shall compensate the gnevor for any loss she has suffered as
a result of her termmatIOn, such compensation to mclude Interest; and,
3) the employer shill place the gnevor on the surplus hst referred to In ArtIcle I
24 of the collective agreement, effectIve December 8, 1993
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The partles agree that the calculatIOn of compensatIOn to whIch the gnevor IS entitled
must take mto account the obhgatIOn to mItigate her loss whIch the gnevor bore
throughout the penod for whIch compensatIOn IS to be p31d. They also agree that thIS
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panel shall be seIsed WIth any Issue ansmg out of the ImplementatIOn of theIr
settlement, Incluchng the assessment of the amount of compensatIOn to be paId.
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We order that the partIes abIde by the obhgatlOns they have agreed to assume, and
we remaIn seIsed In accordance With that agreement.
ThIs matter remams scheduled for heanng on February 28, 1994 Any unresolved
Issues will be dealt With at that tIme, unless the parties otherWIse agree or the
RegIStrar otherWise dIrects. In that regard, the parties are to adVIse the RegIstrar by
January 31, 1994 whether they still reqUire the February 28, 1994 hearing date
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Dated at Toronto thIS 12th day of January, 1994. J
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S UrbaIn, Member
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M. O'Toole, Member
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