HomeMy WebLinkAboutStewart 17-04-03IN THE MATTER OF AN ARBITRATION
PURSUANT TO THE COLLEGES COLLECTIVE BARGAINING ACT
BETWEEN:
SAULT COLLEGE
(the “Employer” or “the College”)
- and -
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(the “Union”)
RE: RELEASE OF RICHARD STEWART
OPSEU # 2015-0613-0009
A W A R D
BOARD OF ARBITRATION
Paula Knopf - Chair
Ann Burke - Employer Nominee
Sherril Murray - Union Nominee
APPEARANCES:
For the Employer: Dan Michaluk, Counsel
Greg Mapp
Rick Webb
Colin Kirkwood
Janice Beatty
For the Union: Chris Bryden, Counsel
Lynn Dee Eason
Frank Turco
The hearings in this matter were held in Toronto and Sault Ste. Marie on
January 11, April 1, October 17, November 28, 2016 and January 17, 2017 .
1
This Award deals with a grievance concerning the release of a probationary
employee. It follows two Preliminary Awards that defined the scope of the
grievance,1 limiting arbitrability to allegations of discrimination, unlawfulness or
violations of the Collective Agreement. The Union alleges that the College‟s
decision to released the Grievor, Richard Stewart, was tainted by anti-union
animus and motivated, in part, by the College‟s irritation with his father, who was
also an employee of the College. This latter allegation was said to have resulted
in discrimination on the basis of family status. The College denies the
allegations, asserting that the release of the Grievor was justified as a result of
the Union‟s cancellation of a Memorandum of Settlement concerning staffing.
This could have been an extremely long and drawn-out hearing. However, to the
credit of the parties and their counsel, they were able to focus and expedite the
case by exchanging and relying upon witness “will say” statements and limiting
cross-examination to areas where clarification was needed or where there were
areas of contention. As a result, few of the relevant facts were in dispute.
The Factual Context of the Grievance
The College offers an Aviation Program devoted to the training and graduation of
professional pilots. The staffing of such a Program is a complex matter, requiring
recruitment and retention of qualified teachers, scheduling that complies with the
Collective Agreement and the offering of courses that meet the standards and
demands set by Transport Canada. In 2013, the College posted two Aviation
Technologist vacancies in the Support Staff bargaining unit. The Union
representing the Academic bargaining unit grieved the posting, alleging that the
responsibilities associated with the positions should “reside” in their bargaining
unit. That grievance was withdrawn in March 2013 when the parties signed a
1 Sault College v Ontario Public Service Employees Union, 2016 CanLII 75652 (ON LA)
Sault College v Ontario Public Service Employees Union, 2016 CanLII 77180 (ON LA)
2
Memorandum of Settlement wherein the College agreed to rescind the
Technologist vacancies and instead to post and fill a minimum of two Flight
Instructor positions in the Academic bargaining unit. The Memorandum also
gave the College flexibility with regard to the scheduling of Instructors and
allowed for the use of sessional Flight Instructors under certain conditions. Its
terms also allowed for the modification of the application of certain clauses in the
Collective Agreement to meet the unique challenges of the Aviation Program.
Most importantly, for purposes of this case, the Memorandum of Agreement
concluded with the following paragraph:
The parties agree that this agreement is made without prejudice and without
precedent to the parties on any respective positions on any matter contained
within this settlement. Further, the parties agree to review this settlement
agreement at the request of either party. Should a renewal agreement not
be reached either party must give at least three months notice of
discontinuation to either party. The parties will revert to their previous
positions in accordance with the Collective Agreement, save that sessional
instructors who have not completed the 36 months described above will
continue under the terms of this agreement unit their 36 month period is
completed.
As an immediate result of entering into this Memorandum of Agreement the
Grievor was hired as a full-time Aviation Flight Instructor effective June 3, 2013,
along with two others. At that time the Collective Agreement provided for a two-
year probationary period. By all accounts, the Grievor performed his duties well.
He received many positive performance appraisals and a great deal of
encouraging informal feedback. Although he did not receive all the formalized
quarterly “progress reports” due to him pursuant to Article 27.02 D, he was given
reason to believe that he could anticipate a long career with the College. He had
relocated his young family from Manitoba to take this position. He was anxious
to succeed and hoped to achieve a professorship. He knew that the College was
targeting people with degrees for that role. To that end, he sought and received
approval from Dean Kirkwood in October 2014 for the funding necessary to
complete a Business Administration degree. His application had read: “With this
education I plan to become a leader here in the Aviation Department.” Mr.
Stewart understood Dean Kirkwood to be supportive of his career aspirations.
3
On November 28, 2014, the Union asked for a review of the staffing
Memorandum of Settlement and put the College on “formal notice” of the Local‟s
intention to discontinue the Memorandum effective February 27, 2015, if the
parties were unable to come to agreement about revised terms. Discussions
between the parties were undertaken, however, no agreement was reached.
The Union then gave notice of discontinuation of the Agreement to the College
on February 27, 2015, indicating that the terms of the Collective Agreement
would apply with the exception of the sessional instructors noted in the
Memorandum. The Union hoped or assumed that the cancellation of the
Agreement would result in the College reverting to use of Instructors and
Sessionals, as had been the practice prior to 2013. However, the College
interpreted the Agreement to allow it to revert to its intended staffing model at the
time it was signed, that being to hire Aviation Technologists in the Support Staff
bargaining unit instead of the Instructors. The parties‟ dispute came to a head
during a meeting on April 8, 2015. They have stipulated that the following
occurred:
The College advised the Union that it was angry/upset at the cancellatio n
of the MOA, that [the] cancellation would result in the lay offs of instructors
and that anyone dissatisfied or affected by lay-offs would be referred to
the Union to get an explanation because it was the Union‟s fault.
On April 10, the VP Academic of the College wrote to the Union President
saying:
As I indicated we are deeply disappointed in the Union‟s decision. The
MOA allowed us to better meet the unique staffing demands of the
aviation program through the effective use of sessional and full-time
instructors. We believe the MOA was a mutual benefit . . . . .
Your cancellation has triggered a reversion to our previous
position/staffing model . . . . The College will shortly take steps to
implement that model.
The College did exactly what it said it would do. On April 17, 2015, the Grievor
and two other Flight Instructors hired following the signing of the staffing
4
Memorandum were released from employment, effective immediately. The
Grievor was told about this by his supervisor, Greg Mapp, the then Operations
Manager and Chief Flight Instructor [now Chair of the Aviation Technology -
Flight Program]. The Grievor was told that his release was the result of the
Union‟s cancellation of the Memorandum of Agreement and that Aviation
Technologist positions would be posted to replace him and the other two Flight
Instructors in the Support Staff bargaining unit. Mr. Mapp encouraged the
Grievor to apply for those postings.
The Grievor was very frustrated and upset to be told that he was suddenly
unemployed. At that point he was 22 months into his 24-month probationary
period. He had assumed that he would be able to complete it successfully
because of the positive feedback he had received. He had a young family. He
had just purchased a new house and he was concerned about having to go
home and tell his wife that he no longer had a job. He did not understand why he
had to lose his job or why he would be expected to make a formal application for
a Support Staff position, given his positive feedback up to that point. The Grievor
recalled saying words to the effect that „we don‟t have to stand for this‟ and „we
should band together to deal with the situation in a better way‟. Mr. Mapp
recalled that the Grievor also said, “We can (or should) stick together as a
department and shut this place down.” The Grievor testified that given his own
frustration and distress at the time, Mr. Mapp‟s recollection about that comment
could be accurate. However, the Grievor‟s testimony also stressed that he never
had any intention of suggesting that the department could or should be closed
down. As he testified, “My intention was to work at the College for years. I never
wanted to shut it down.” He admitted that he might have come across as
sounding “aggressive,” but he explained that any anger was aimed at the
situation, not at Mr. Mapp who he considered to be a friend. Mr. Mapp testified
that he understood why the Grievor was upset.
5
The same day as the three Flight Instructors were released, the College posted
three Aviation Technologist positions and one Lead Aviation Technologist
position to “provide academic and aviation safety support to faculty and
students”. These positions were situate in the Support Staff bargaining unit. In
the course of this hearing, the College stipulated that there is “significant overlap
in the Technologist and Instructor positions in terms of responsibilities.” On April
28th, the Grievor applied for these jobs.
In the week following the release the three Flight Instructors, tensions we re high
in the Department. The remaining staff raised concerns about safety, mor ale and
“feeling disposable.” As a result, Mr. Mapp met with Dean Colin Kirkwood, and
the two of them then met with Leo Tiveri (the then VP Academic), Ron Common
(College President), Matt Casola (Manager, Occupational Health and Safety) and
Rick Webb (Director of Human Resources) on April 23rd. The purpose of the
meeting was for Mr. Mapp to advise them about the Department‟s reaction to the
release of the three Flight Instructors. They also discussed information that had
been received about Aviation Program employees voicing concerns about flight
and work safety and meeting in the Union‟s offices. All this was perceived by the
College as being aimed at putting pressure on the College about the staffing
changes. Mr. Mapp told this management group about the comment the Grievor
had made when he had been released about „banding together and shutting this
place down‟. Mr. Mapp testified: “They did not take kindly to the comment.”
On April 24th, there was a formal work refusal in the Department under the
Occupational Health and Safety Act. An inspector from the Ministry of Labour
attended the hanger. The work refusal was resolved without a finding of any
endangerment and without any orders. There is no evidence to suggest that the
Grievor organized or participated in this work refusal.
On May 7th, the Grievor came to Mr. Mapp‟s office to say that he was filing a
grievance protesting his release in order to try to “protect” himself and his family.
6
He also asked whether he had any future with the College. Mr. Mapp then
indicated that he would like to speak to the Grievor as his friend, not as his
manager. Mr. Mapp revealed that he had relayed the Grievor‟s comments about
„shutting the place down‟ to management and that none of them “took kindly” to
his comment. Mr. Mapp testified that after the subsequent work stoppage
occurred, there was a feeling that the Grievor had played a part in it. As a result,
Mr. Mapp said that he was being “frank” when he advised that he did not know if
the Grievor had a future with the College.
The Grievor was neither interviewed nor hired for any of the posted Technologist
positions. One of the Instructors who had been released at the same t ime as the
Grievor was rehired into one of the Technologist positions. The third Instructor
did not seek re-employment with the College.
The Union has grieved the posting of the Support Staff Flight Technologist and
Lead Technologist positions, claiming that the duties belong in the Academic
bargaining unit. That grievance has been referred to arbitration before another
Arbitrator and has not been resolved at the time of this Award‟s release.
Therefore, the issue of whether these duties belong in this Academic bargaining
unit remains a live dispute between the parties.
On May 9th, the Grievor asked for a letter explaining why he had been released.
The letter was supplied after the grievance meeting held on May 20, 2015. The
letter dated June 4th reads in part:
The Reasons for Release
The College released you during your probationary period
due to the reorganization of our staffing model in the
Aviation department. The re-organization followed the
cancellation of a Local Union-Management agreement that
established a staffing model that led to your hire.
7
The agreement was entered into in 2013 after the College
posted two Aviation Technologist positions. The Union
grieved the postings and the parties reached a settlement.
There are two key components to the agreement:
The College agreed to rescind the two postings and,
instead, meet its staffing needs by posting to hire a
minimum of two full-time instructors.
The Union agreed to relief from certain Collective
Agreement restrictions that made the use of flight
instructors workable and appealing.
You were hired pursuant to a posting contemplated by the
agreement and worked under the staffing model supported by
the agreement which stipulated that “the parties will revert to
their previous position in accordance with the Collective
Agreement” on discontinuance.
. . .
I do regret all of the circumstances that have led us to this
point. Your experience and skillset leaves me with no doubt that
you will find new employment within a short period of time.
However, for the reasons mentioned above, but not limited to,
your grievance is denied.
The Union‟s case also includes the assertion that he was released, in part,
because of his relationship with his father, Brian Stewart. That is the basis of
the allegation that the release was tainted by discrimination on the basis of family
status. The College took the position that any evidence concerning Brian
Stewart‟s employment is irrelevant. However, since this evidence was integra l to
the allegations of discrimination, it has been considered. However, to be clear,
this Award is not an adjudication of facts and issues concerning Brian Stewart‟s
employment. The following information is presented solely for the purpose of
giving context to the claim of discrimination.
Brian Stewart was hired into the College‟s Aviation Program in 1965 . For the
years 2001-2007 and 2013-2015, he was its Chief Flight Teacher. Since 2009,
he often voiced criticisms regarding some of the Program‟s standards and about
many management decisions. Dean Kirkwood admitted that the College
8
considered Brian Stewart to be a “negative influence on the Depa rtment at
times.” In 2013, Mr. Stewart became particularly critical of the quality and
content of the classes being delivered by another Teacher. In the Spring of
2014, Brian Stewart was troubled about the course assignments given to that
other Teacher for the Fall 2014 semester. In protest, Brian Stewart offered to
resign in the Fall as Chief Flight Teacher if the other Teacher‟s assignment
remained in place. The College‟s response was to accept Brian Stewart‟s
resignation from the role of Chief Flight Teacher effective immediately. The
College also launched an investigation to determine Brian Stewart‟s allegations
were “well founded and, if not, whether [he made] the allegation for an improper
purpose”. An “independent investigator” was retained. The resulting report
concluded that Brian Stewart had “harassed and/or bullied” another faculty
member and made “vexatious comments” that lacked “objective sound
reasoning”. The College relied upon the findings of that report.
As a result, Brian Steward was disciplined. On February 23, 2015, he was re-
assigned to another department for the remainder of that academic year as well
as for the following two years. He was ordered to refrain, “in all regards”, from
attending at the Aviation facility and from taking any action that related to the
affairs of the Aviation Program. The letter of discipline included the statement;
“Quite frankly, we need time to put the program on a more positive track.” Dean
Kirkwood testified that the College felt that Brian Stewart‟s removal from the
Aviation Department was “necessary to put the Program on a more positive
track”. This discipline was grieved. Brian Steward continued to remain at work in
the newly-assigned department. However, when his son, the Grievor, and the
other two Flight Teachers were released from their jobs in April, Brian Stewart
became “psychologically distraught” and felt he could no longer go to work. He
believed and continues to believe that the College took its irritation at him out on
his son. He went on sick leave in June 20, 2015. His grievance has since been
resolved. He was put on paid leave effective October 2015 and he retired
December 31, 2016. Management witnesses vehemently denied that the
9
Grievor‟s release was connected in any way to their dealings with his father or
Brian Stewart‟s history or grievance against the College.
The issue of whether the Aviation Department should be staffed with Instructors
or Technologists in the Support or Academic bargaining units is not before this
Board of Arbitration. Nor will it be commented upon. Whether the College
implemented a staffing model that complies with the Collective Agreement after
the cancellation of the Memorandum of Agreement is not an issue to be
determined in this Award. However, the evidence before us did reveal some
relevant and interesting facts add factual context to the rational behind the
Grievor‟s release.
When the three Aviation Instructors were released and replaced with the four
Aviation Technologists, this resulted in salary commitments of approximately two
times the amount being paid to the Instructors, or approximately $120,000 more
in salary costs. Dean Kirkwood was asked in cross-examination to explain the
rationale behind this. He testified that he had done an analysis of the costs and
impact of hiring under the alternate collective agreements on staffing models
prior to the original postings for Technologists in 2013. He pointed out that that
salary cost is not the only way to measure the overall cost of each staffing model
because there are restrictions on the number of hours that can be assigned to
the Instructors under the Academic Collective Agreement. Considerations of
“productivity” were also said to have played a factor, such as being able to assign
alternative duties to Technologists when flights have to be cancelled due to
weather. He said that he had concluded in 2013 that the “cost per flight hour”
was lower with Technologists. Therefore, operational considerations meant that
the cost per hour of flying would be lower using support staff. However, he could
not recall any of the details about that analysis. He did opine that the four
Technologists “were not necessarily more expensive than the three Instructors
even though their salaries were higher.” When asked if there were any savings
for the College in using Technologists instead of Instructors, he admitted, “We
10
haven‟t done a calculation to establish that.” Nor was he able to say if College
give any reconsideration of the relative costs of retaining the Instructors and/or
hiring additional Sessionals in 2015 after the Memorandum of Agreement was
cancelled by the Union. His evidence made it clear that the College simply
reverted to its pre-Memorandum plan to hire Technologists into the Support Staff
bargaining unit on the basis of the analysis that had been done earlier. In
fairness to him and his testimony, the financial aspect of t he case was clearly not
one that he or the College had anticipated from the exchange of Will Say
statements exchanged by the parties prior to the hearing.
The Submissions of the Parties
Note: The parties did not address the matter of remedy because they agreed to
bifurcate the proceedings and have this Board of Arbitration remain seized with
that issue if necessary.
The Submissions of the Union
Fundamentally, the Union complained that the Grievor‟s release was unfair and
unnecessary. However, given the limited scope of arbitrability for probationary
releases under this Collective Agreement, the Union‟s case is based on the
assertion that the Grievor‟s release was tainted by anti-union animus and/or
discrimination on the basis of family status.
Acknowledging that the Memorandum of Agreement overarches all the events in
this case, counsel for the Union commented upon the irony of the fact that both
parties relied on the cancellation of the Memorandum to support their cases; the
Union asserting it as a “sword” to reveal the improper reasons for the Grievor‟s
release and the College raising it as a shield, or as a defence to the allegations.
The Union submitted that the “key” proof of the anti-union animus is contained in
the stipulated fact that the College advised the Union on April 8th that it was
“upset/angry at the cancellation” of the Memorandum of Agreement and that
11
anyone dissatisfied or affected by the resulting layoffs “wound be referred to the
Union to get an explanation because it was the Union‟s fault.” These words
were said to be a “threat” that went “beyond the standard of upset you might see
in day-to-day labour relations.” The Union complained that the College took its
anger at the Union out by releasing the three Instructors, including t he Grievor.
The Union submitted that this is confirmed by Dean Kirkwood‟s evidence that
revealed that the College did not consider any options other than the release of
the Instructors after the Memorandum of Agreement was cancelled. While the
Union stressed that this case is not an attempt to challenge the College‟s right to
manage or make staffing decisions, the Union did complain that the College
failed to consider any options other than to carry out its “threat” of layoffs. On
this basis the Union asked that an inference be drawn that the decision to
release the Grievor was tainted by the College‟s anti-Union animus. This was
said to be even more evident given the Grievor‟s release was not prompted by
any concerns about his work performance.
The Union stressed that nothing in the Memorandum of Agreement required that
the Instructors would be released if it was cancelled. Therefore, it was said that
the decision to release the Instructors should be seen as retaliation against the
Union that resulted in the Grievor becoming “collateral damage” with his loss of
employment. The Union relied on the following to assert that it is illegal to have
anti-union animus as even one factor in the termination of employment: Ontario
Labour Relations Act, s. 72, CS Wind Canada Inc. v. IABSRI, Local 721, 2015
CarswellOnt 8699, [2015] O.L.R.D. No. 1668, 262 C.L.R.B.R. (2d) 57 (Misra);
Teamsters Union Local 1000 v. Pop Shoppe (Toronto) Limited, 1976
CarswellOnt 642, [1976] O.L.R.B. Rep. 299 (Burkett).
The Union submitted that the College‟s failure to hire the Grievor back as a
Technologist may have been based on his comments about “sticking together”
and “taking action” on the day he was told that he was being released. This was
said to be patently unfair given that the Grievor was understandably upset and
12
that this comment should not have been held against him or taken out of context.
However, it was conceded that this Board of Arbitration has no jurisdiction over
the issue of the College‟s failure to rehire the Grievor.
The Union‟s second argument is that the College‟s irritation with Brian Stewart
and his grievance were also factors in the decision to release the Grievor. It was
submitted that evidence revealed that Brian Stewart was someone who was
perceived as an “irritant” because he had a history of vocalizing concerns about
quality and standards in the Aviation Program. It was argued that the College‟s
disciplinary “banishment” of Brian Stewart from the Aviation Department
amounted to a disproportionate and “draconian” response to his legitimate
concerns. It was also said to prove that the College wanted him out of the
Department and to remove his influence on its affairs. This was said to be
relevant to his son‟s treatment because the Grievor was released two months
after his father‟s disciplinary transfer was put into effect. The Union argued that
the Grievor „s release was a continuum in the College‟s determination to ensure
that Brian Steward would have no more impact on the Aviation program. The
Union suggested that this can be inferred from the fact that one of the other
Instructors was immediately hired back as a Technologist, whereas the Grievor
was not even interviewed for the new postings.
The Union submitted that the totality of the evidence should also allow this Board
of Arbitration to infer that management cast the Grievor in the same light as his
father and assumed that the comments about “sticking together” and “shutting
down” the Department meant he was also a troublemaker and that he was
involved in the work stoppage that happened after his release.
The Union relied on the following case to support its argument that discrimination
occurs when an employer is dissatisfied with one employee and punishes his/her
relative as a consequence: A. v. B., 2002 SCC 66, 2002 CSC 66.
13
The Union also submitted that the evidence revealed violations of Articles 27.02
D and E arising from the fact that the Grievor was not issued progress reports
every four months during his probationary period and he was not given written
reasons for his release until after the second step grievance meeting.
The Submissions of the Employer
The Employer‟s primary position is that the evidence supports the conclusion that
the sole reason for the Grievor‟s release was the cancellation of the
Memorandum of Agreement. It was also stressed that the release of the other
two Instructors at the same time as the Grievor indicates that the release did not
target the Grievor personally, but was, instead, the direct consequence of the
cancellation of the staffing Agreement. Further, it was pointed out that the Union
was told that the cancellation would have consequences upon staffing, including
layoffs. The Employer argued that since the Agreement had been a compromise
whereby the Union achieved Academic bargaining unit positions in return for the
Employer obtaining scheduling flexibility, the Union should not have expected the
Instructor positions to remain in this bargaining unit after it cancelled the
Agreement.
It was submitted that Dean Kirkwood‟s evidence established that the College
wanted to implement a staffing model with Aviation Technologists in 2013 in
order to achieve flight cost savings and flexibility. It was admitted that Dean
Kirkwood‟s evidence was “vague” about the analysis, however, it was submitted
that the Union failed to meet the onus of proving that the staffing model was
“illegal” or contrary to the Collective Agreement. It was acknowledged that
reversion to the use of Aviation Technologists is currently being challenged. For
purposes of this case, it was stressed that when the Union cancelled the
Memorandum of Agreement, the College simply adopted the staffing model that it
had put in place before the Settlement was reached. This was said to be exactly
what the Settlement allowed.
14
The Employer‟s second position is that the reversion to the staffing model of
using Aviation Technologists in the Support Staff bargaining unit was not
motivated by anti-Union animus. Acknowledging that the College was angry at
the Union for the cancellation of the Memorandum of Agreement, the anger was
said to have arisen because the Settlement had been a “good thing” for both
parties and its cancellation prompted negative consequences. It was also
submitted that “anger” is a common reaction in labour relations and does not, in
itself, signal anti-union animus. Support for this was said to be found in a
decision between these parties that is based on many of the same events that
are relevant to this case: Sault College and OPSEU, Eason Grievance, Decision
of Stout, Burke and Murray, dated April 11, 2016.
Addressing the allegation that the Grievor‟s release was connected to the
College‟s “irritation” with his father, the Employer primarily submitted that any
evidence about Brian Stewart‟s actions and discipline are irrelevant. In the
alternative, it was stressed that there was no evidence that linked the decision to
release the Grievor with his father. The fact that the Grievor‟s release occurred
just two months after the father‟s discipline was said to be an “incredibly weak
link”. It was also submitted that the College‟s treatment of Brian Stewart was an
appropriate response to what an independent investigator found to be “serious
misconduct”. Further, it was stressed that the evidence demonstrated that the
Grievor had enjoyed a good relationship with his supervisor and his Dean, that
his work had been supported and that he had been approved for professional
development opportunities during the same timeframe as his father was under
investigation and being disciplined. This was said to disprove any suggestion
that the College perceived the Grievor to be linked to any disruptive influence on
the department.
Further, it was submitted that the evidence does not support a finding that the
Grievor was released because of any perception that he was involved in the work
refusal because the decision to release him had been made before he suggested
15
a work stoppage and before it took place. However, it was acknowledged that
management did link the work stoppage to the Grievor thereafter because of the
comments he made on the day he was released. While it was stressed that this
was not a reason for his release, it was pointed out that the College did rehire the
Instructor who had been released at the same time but who had not made similar
comments. It was submitted that the Grievor should not have said what he did
and that his comments had the “consequence” of him not being considered for
rehire.
The Union’s Reply Evidence
The Union distinguished this case from the Eason Grievance, supra, by stating
that the College‟s anger and “threat” of layoffs expressed to the Union as a result
of the cancellation of the Memorandum of Agreement are different than the kind
of “passionate” language that is often used in a grievance or confidential
meetings.
Further, the Union submitted that the evidence does not support the notion that
the College had to release any Instructors as a consequence to the cancellation
of the Memorandum of Settlement. It was also stressed that the College did not
even revert to its “previous” staffing model because Technologists had not been
used before the Memorandum was signed. Therefore, it was submitted that the
Union could not have foreseen that the cancellation would necessarily lead to the
layoff or release of Instructors because other options were available to the
Employer.
The Decision
We should begin with the simpler issues concerning whether the College violated
Article 27 with respect to the Grievor‟s specific contractual rights as a
probationary employee. The Collective Agreement provides:
16
27.02 D During the probationary period an employee will be informed in
writing of the employee‟s progress at intervals of four months continuous
employment or four full months of accumulated non-continuous
employment and a copy given to the employee.
27.02 E A probationary employee may be released upon at least 30
calendar days‟ written notice or pay in lieu thereof. If requested by the
employee, the reason for such release will be given in writing.
The evidence indicated that the Grievor did not receive all of the formal progress
reports mandated by Article 27.02 D. This was raised a concern by the Union at
the hearing but not grieved. Nor did this impede the Grievor‟s ability to progress.
The formal and informal feedback he was given was consistently positive and
constructive. Therefore, while the provisions of the Collective Agreement should
be respected and adhered to, he was not deprived of any significant information
that would or could have affected his ability to achieve success as a probationer.
Therefore, it shall not be referred to again.
There can be no finding of a breach of Article 27.02 D. The main reason is that
this Board of Arbitration ruled in our second preliminary award: “. . . .while we will
hear evidence about the delivery of the reasons for the release, this will not be an
arbitration about what relief may flow from an alleged violation of this provision”,
see Sault College v Ontario Public Service Employees Union, 2016 CanLII 77180
(ON LA). Further, it must be pointed out that the Grievor did receive the reason
for his release in writing. This was received only after he had requested it and
after a grievance meeting was held. The College provided the explanation for
the delay. The delay does not appear to have been intentional. Nevertheless, it
was unfortunate and added fuel to the perception of unfairness. However, the
Collective Agreement does not impose a time requirement on the delivery of the
reasons for the release..
The relevant contractual and statutory framework for the more complex and
pressing issues concerning the Grievor‟s release are as follows:
17
Colleges Collective Bargaining Act
Interference with employee organization prohibited
53. (1) ... an employer or a person acting on behalf of the Council or an
employer shall not,
(a) participate in or interfere with the formation, selection or
administration of an employee organization or the representation of
employees by an employee organization; or
(b) contribute financial or other support to an employee organization.
(2) Nothing in subsection (1) shall be interpreted to deprive the Council,
an employer or a person acting on behalf of the Council or an employer
of the freedom to express views so long as coercion, intimidation,
threats, promises or undue influence are not used. 2008, c. 15, s. 53 (2).
Interference with employees rights prohibited
(3) ….. an employer or any person acting on behalf of . . . an employer
shall not,
(a) refuse to employ or to continue to employ or discriminate against a
person with regard to employment or any term or condition of
employment because the person was or is a member of an employee
organization or was or is exercising any right under this Act;
(b) impose any condition in a contract of employment or propose the
imposition of any condition in a contract of employment that seeks to
restrain a person employed by an employer or a person seeking
employment by an employer from becoming a member of an employee
organization or exercising any right under this Act;
(c) seek by intimidation, by threat of dismissal or by any other kind of
threat or by the imposition of a pecuniary or any other penalty or by any
other means to compel a person employed by an employer to become or
refrain from becoming or to continue to be or cease to be a member of
an employee organization, or to refrain from exercising any right under
this Act.
Ontario Human Rights Code
5. (1) Every person has a right to equal treatment with respect to
employment without discrimination because of race, ancestry, place of
origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation,
gender identity, gender expression, age, record of offences, marital status,
family status or disability. [emphasis added]
10.(1) “family status” means the status of being in a parent and child
relationship
18
The Collective Agreement
3.02 The Colleges and the Union agree that there will be no intimidation,
discrimination, interference, restraint or coercion exercised or practiced by
either of them or their representatives or members because of an
employee's membership or non-membership in the Union or because of
an employee's activity or lack of activity in the Union or because of an
employee's filing or not filing a grievance including participation in the
workload complaint system.
The case law that the parties cited adds some context to the se provisions. In the
Sault College and OPSEU, Eason, supra, case, the Stout Arbitration Board dealt
with the impact of a heated exchange between this College and its Union leaders
during a meeting convened to discuss sensitive labour relations issues related to
the College‟s financial situation, staffing and restructuring. Those issues overlap
with the issues in the case at hand. The following passage is instructive:
19. . . . . . it is still not unusual for union and management to take
forceful positions and become passionate during grievance and/or
confidential meetings, such as the meeting that occurred on April 8,
2015. In most situations, the parties will attempt to persuade each other
of the merits of their position. There is no doubt that on some occasions,
these debates become very heated and some participants may make
inappropriate comments, which outside of this forum might be perceived
as unprofessional or offensive.
This paragraph acknowledges that heated discussions and differing positions are
the norm in labour relations. Anger and frustration often erupt when the parties
cannot find a way to resolve issues that mean a great deal to their operations
and the people they represent. Inappropriate, unprofessional and offensive
comments are often made as tempers flair.
However, the fact that an employer may be angry at a union for its conduct or its
decisions does not automatically trigger a finding of anti-union animus or a
breach of the statute. Employers are often angry at unions for a myriad of
legitimate and/or unwarranted reasons. If the existence of anger against a union
triggered a finding of anti-union animus, employers might be in breach of the
19
statutes every day, several times a day. A finding of anti-union animus requires
more than that. Anti-union animus is a term of art adopted to reflect unlawful
conduct that interferes with a union‟s or employee‟s exercise of their statutory
rights. The test is contained in the statute and based on interference in the
institutional rights of a union or interference in an individual‟s ability to exercise
his/her rights under the Act. This was explained in the case of CS Wind Canada
Inc. and IABSRI, Local 721, supra:
376. The test the Board applies when considering an allegation that an
employer has acted with anti-union animus was outlined in Springs
Canada Inc., cited above, as follows:
98. The test in considering whether the employer has
committed an offence under the Act and had an anti-union
animus is the same sort of consideration that would arise
under a section 50 complaint under the OASA. For
example, the Board in Westinghouse Canada Limited,
[1980] OLRB Rep. Apr. 577 stated:
44. We now turn to the unfair labour practice
provisions underlying this complaint and to a
consideration of the law as it relates to the
degree of anti union motive necessary to
establish such violations of the Act. For the
purpose of our analysis it is useful to
distinguish between decisions affecting
individual employees and major business
decisions having potentially broader impact. In
dealing with the treatment of individual
employees this Board has consistently held
that if only one of the reasons for an
employer‟s actions against an employee
(discharge, layoff, transfer, demotion, etc.) is
related to union activity the action is in
contravention of the Act. Given the reverse
legal onus mandated by section 79(4a) the
Board has held that to find there has been no
violation of the Act in these kinds of cases it
must be satisfied that the employer‟s actions
were not in any way motivated by anti-union
sentiment. The Board summarized this
approach and the effect of the statutory
reversal of the legal burden of proof in The
20
Barrie Examiner case, [1975] OLRB Rep. Oct.
745 as follows:
… the appearance of a legitimate reason for
discharge does not exonerate the employer, if
it can be established that there also existed an
illegitimate reason for the employer‟s conduct.
This approach effectively prevents an anti-union motive
from masquerading as just cause. Given the requirement
that there be absolutely no anti-union motive, the effect of
the reversal of the onus of proof is to require the employer
to establish two fundamental facts – first, that the reasons
given for this discharge are the only reasons and, second,
that these reasons are not tainted by any anti-union
motive. Both elements must be established on the
balance of probabilities in order for the employer to
establish that no violation of the Act has occurred.
This passage highlights an important point. If an employer‟s actions against an
employee are in any way related to union activity, the action is in contravention of
the statute. It is often difficult to make such a finding because offenders rarely
advertise their transgressions, so inferences can be drawn from the evidence
that is presented. This was explained in Pop Shoppe, supra:
5. In cases such as these the Board is very often required to render a
determination based on inferential reasoning. An employer does not
normally incriminate himself and yet the real reason or reasons for the
employer's actions lie within his knowledge. The Board, therefore, in
assessing the employer's explanation must look to all of the circumstances
which surround the alleged unlawful acts including the existence of trade
union activity and the employer's knowledge of it, unusual or atypical
conduct by the employer following upon his knowledge of trade union
activity, previous anti union conduct and any other "peculiarities”. These
determinations, however, are most difficult and require an incisive
examination of all the evidence. Not only must the Board "see through" the
legitimate reasons which often co-exist with the unlawful, but at the same
time the Board must be capable of distinguishing between the unlawful and
the unfair. The Board cannot find, and neither should it automatically infer,
that an employer who has engaged in conduct which is unfair has violated
the Act even if the unfair treatment is coincidental with an organizing
campaign. However, because of the nature of the proceedings and the
frequent requirement for inferential reasoning the Board would be
21
delinquent if it did not consider, for purposes of drawing an adverse
inference, unfair treatment during an organizing campaign of itself or in
conjunction with the other circumstantial evidence. The Board, therefore,
must be acutely sensitive to all of the circumstances and must not be
unduly swayed by either the co-existence of unfair treatment or by the co-
existence of legitimate reasons for the employer's conduct in determining if
the Labour Relations Act has been violated.
This case emphasizes that adjudicators can and must be able to draw infe rences
from the evidence to see if there has been any interference with a union‟s or an
employee‟s exercise of statutory rights. However, even evidence that reveals
unfairness will not necessarily trigger a finding that there has been any
interference with statutory rights.
This Employer has conceded that it was “angry and/or upset” at the Union about
the cancellation of the Memorandum of Agreement that had provided benefits to
both parties. It gave the College relief from aspects of the Collective Agreement
and flexibility with regard to scheduling. It also achieved coveted full-time
positions in this bargaining unit for the Union. When the Union sought, as was its
right, to renegotiate the Settlement, it is unfortunate that no mutually acceptable
modifications could be reached. When the Union then cancelled the Agreement,
as was its right, it triggered a series of events that were beyond the Union‟s
immediate control.
The College‟s response to the cancellation of the Memorandum appears to have
been an almost reflex reaction. The College immediately released the three
Instructors who had been hired pursuant to the postings promised in the
Memorandum. It then posted four vacancies the same day for positions with
significantly similar responsibilities that would reside in the Support Staff
bargaining unit.
Did this amount to an unlawful treatment of the Grievor? For a finding of a
breach of s. 53 of the Colleges Collective Bargaining Act, there has to be
22
evidence that he was released, even in part, because the Employer interfered
with his individual rights or the rights of the Union.
Turning first to the Grievor‟s individual rights, the College is not allowed to refuse
to employ or to continue to employ or discriminate against a person with regard
to employment or any term or condition of employment because s/he was a
member of this Union or was or is exercising any rights under this Act. That is
activity that the Act protects. However, there is no suggestion in the evidence or
the submissions that the Employer‟s decision to release the Grievor was related
to the fact that he was a member of the Union engaged in Union activity or
exercising his rights under the Act. The decision to release the Grievor and the
other two Instructors was implemented immediately after the cancellation of the
Memorandum of Agreement. The decision to do that was made before
management was told that the Grievor said anything about “shutting this place
down.” So even if the Grievor was involved in some form of legal or illegal union
activity as a response to the release of the Instructors, his release cannot be
connected to anything he said or did before that statement was uttered.
Therefore, there is no basis for a finding that the Employer breached the
Grievor‟s individual rights under s. 53(3)(a).
This brings us to the question of whether the Employer interfered with the
Union‟s institutional rights under s. 53(1). The relevant portions of that section
prohibit employers from interfering with the administration of a Union or its
representation of employees. It allows employers to “express views so long as
coercion, intimidation, threats, promises or undue influence are not used .” It is
noted that the Union characterized that the College‟s declaration as a “threat “
when it said that it would send any laid off employees to the Union because their
loss of jobs was the “Union‟s fault.” However, that statement must be recognized
for what it was. The College was forewarning the Union of the fact that staff
would be laid off or released as a consequence of its decision to cancel the
staffing Settlement. Indeed the College President did inform the Faculty that the
23
Union‟s decision was the reason for the changes. However, there is no evidence
to support a finding that the College‟s decision to release the Grievor and/or the
other Instructors interfered with the administration or activities of the Union.
We were not told why the talks about renegotiating the Memorandum of
Agreement were initially undertaken or why the parties‟ discussion yielded no
solutions. We suspect that the reasons are complex and that both parties share
responsibility for the breakdown of the discussions. However, we cannot ignore
the evidence that did reveal that the College had many options other than
releasing the Instructors after the Memorandum of Agreement was cancelled. It
is true that the language allowed the College to “revert to its previous position in
accordance with the Collective Agreement.” What that means may have to be
interpreted by another Board of Arbitration. But the evidence bef ore us did
suggest that the College had options beyond the release of the three Instructors:
It could have left the Flight Instructors in place and proceeded to
arbitration to determine whether their duties fell within the Academic or
Support Staff bargaining unit. If the Employer succeeded with that
grievance, the existing Instructors could/would then be declared to be
members of the Support Staff bargaining unit as of their date of hire;
and/or
It could have re-visited the analysis of the relative costs and efficiencies of
the Support v. Academic staffing models; and/or
It could have considered alternate staffing models involving the use of
additional Sessional or other categories of employees; and/or
It could have continued to propose creative ways to modify the
Memorandum of Settlement.
Perhaps there were more options. The important point is that the release of the
Instructors was not the only option available to the Employer. Nothing in the
wording of the staffing Agreement directly triggered the immediate release of the
three Instructors. But it cannot be ignored that “substantially the same
responsibilities” held by the released Instructors were posted as vacancies the
24
same day, indicating a continuing need for the same work to be done. Therefore,
the only real question that divided the parties after the Memorandum of
Agreement was cancelled was whether those duties and responsibilities fit
properly within the Academic or Support Staff bargaining units. That might have
been able to be determined by an arbitration without the displacement of the
people doing that work. That is why it is understandable that the Grievor and the
Union perceived his release to be so unfair.
Nevertheless, the release of the Instructors remains as one reasonably arguable
and foreseeable exercise of management rights after the staffing Agreement was
cancelled. While the College was admittedly “angry/upset” about the
cancellation, that reaction cannot be elevated to a finding that there was any
interference with the formation, selection or administration of the Union or its
representation of employees. The College‟s notice to the Union that it would be
blamed for any layoff cannot be found to be a “threat” because it simply reflected
the College‟s intention to cast blame for the outcome on the Union. While that
may have been unnecessary or even unfair in all the circumstances, that does
not allow for an inference that it interfered with the exercise of the Union‟s rights
under the Act.
As the Pop Shoppe, supra, case advises, there is a difference between unlawful
and unfair. In this case we can appreciate the perceived unfairness to the
Grievor. He was a promising employee who was released for no reason related
to his performance. This was done to him after he worked hard, when he had all
but completed his probationary period and after he had organized his family and
educational plans in the reasonable anticipation of a long career with this
College. He was, indeed, the victim of the parties‟ inability to reach agreement
about staffing. However, this Board cannot find or infer from the evidence that
the College engaged in conduct that violated the Act.
25
This College may have acted precipitously or unfairly. Its determination to assign
these duties in the Support Staff bargaining unit may or may not be in
contravention of the Academic Collective Agreement. That is not for this Board
of Arbitration to determine. Even if the Union is correct in some of its assertions
that are outside of this grievance, they do not amount to unfair labour practices.
The Act is not violated every time there is any unfairness or violation of the
Collective Agreement or every time an employer is angry at a union.
Accordingly, we cannot infer that the Grievor‟s release or the College‟s actions
establish interference with his individual or the Union‟s institutional rights that are
protected by the governing statute.
This brings us to the question of whether the Grievor‟s release was stimulated, in
whole or in part, by the College‟s irritation with his father. If the evidence
supported that conclusion, it could amount to discrimination on the basis of family
status, see A. v. B., supra. However, the evidence in this case does not support
that conclusion. The evidence revealed that the College‟s irritation with the
Grievor‟s father developed over the long period of his vocal criticism of
management, the program and one of his colleagues. Regardless of this, during
the same period that the College was concerned about the negative influence
that Brian Stewart was having on the Aviation Program, the College hired his
son, gave him positive reinforcement about his work and financially supported his
ambitions to obtain the kind of university degree that could lead to a
professorship. The evidence also indicated that even at the moment that the
Grievor was told that he was being released, his supervisor, Mr. Mapp,
encouraged him to reapply for one of the Support Staff vacancies. All this leads
to the conclusion that while the College decided to release all three Instructors
because of the cancellation of the Memorandum of Agreement, it was still
prepared to immediately re-hire the Grievor into its other bargaining unit. That
intention only changed after management heard the Grievor‟s comment about
having the department band together or to “shut down” the Program.
26
My father used to warn us that a person takes a lifetime to build a reputation and
only a moment to destroy it. The Grievor spent almost two years earning his
supervisors‟ respect and trust, and then damaged his reputation with one
comment. Could the College‟s reaction of “not taking too kindly to that remark”
been because management thought the Grievor might become a negative
influence on the Program, like his father had been? Did the College fear, “like
father like son”? Could management have feared that the Grievor might be
planning to promote some sort of lawful or unlawful Union activity? We cannot
conclude that such thoughts or fears played any role in the Grievor‟s release
because the evidence is clear that the decision to release him had been made
before he uttered those unfortunate words. Therefore, the evidence does not link
the College‟s actual decision to release the Grievor to anything relating to his
father or any union activity.
In a more reflective setting or if the tension in the Department had not be so
severe, the Grievor‟s comment might have been recognized as a spontaneous
expression of frustration, erupting from the realization that he no longer had a
job. However, it must be emphasized that the Union properly conceded that this
Board of Arbitration has no authority over the College‟s decision not to rehire the
Grievor. Our only authority is over the College‟s decision to release him. In that
regard, the evidence is clear that the decision to release the Grievor was made
before he made any remarks that might have caused concern.
Accordingly, the evidence does not support a conclusion that the Grievor‟s
release was, in whole or in part, tainted by any discrimination on the basis of
family status or that there was interference with either his or the Union‟s statutory
rights.
Therefore, the grievance against the Grievor‟s release must be dismissed.
27
We are grateful to counsel for their assistance and cooperation i n the
presentation of this case.
Dated at Toronto this 3rd day of April, 2017
Generated by CamScanner
__________________________
Paula Knopf - Chair
I concur - See Addendum “Ann Burke”
___________________________
Ann Burke - Employer Nominee
I dissent “Sherril Murray”
____________________________
Sherril Murray - Union Nominee
28
ADDENDUM
I have now had an opportunity to review the award in this matter and feel
obliged to make the following comments. I make these comments in the
context that we ruled in our preliminary decision, dated November 9, 2016,
that articles 27.02 D and E were not grieved.
In its essence, this is a grievance in which it is alleged that a probationary
employee was released from employment contrary to art. 4 of the
collective agreement due to suspected union activity and discrimination o n
the grounds of family status. These were the grounds on which the case
went forward. Neither of these claims were made out on the evidence. In
my view, that ends the matter.
This is not a grievance alleging any violation of the collective agreement
relative to the College‟s conduct in the discussions following the Union‟s
unilateral notice of the cancellation of the Memorandum of Agreement. It is
not a grievance concerning the College‟s right to revert to their position
prior to the Memorandum of Agreement. The grievance before us does not
allege a violation of the CCBA. While the Union did file a grievance
concerning the assignment of work to employees in the support staff
bargaining unit, that grievance is not before us.
In this context, in my respectful view, there was no reason for the College
to defend their decision to revert to their former position and, that decision
is entirely unrelated to the matter before us. I therefore view all comments
concerning how the College might have responded to the Union‟s decision
to cancel the Memorandum of Agreement as obiter dictum addressing a
collateral matter and unfair criticism of the College, in all the
circumstances.
Dated this 30th day of March, 2017 Ann E. Burke