HomeMy WebLinkAbout1993-2035.Atkins&Taylor.96-03-22
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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 # 2935/93, 2036/93
OPSEU # 93E806, 93E807
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Atkins/Taylor) Grievor
- and -
The Crown in Right of ontario
(Ministry of Transportation)
Employer
BEFORE S Kaufman Vice-Chairperson
FOR THE N Roland
GRIEVOR Barrister & Solicitor
FOR THE S Patterson
EMPLOYER Counsel
Legal services Branch
Management Board Secretariat
HEARING May 9, 1995
August 18, 28, 1995
September 26, 1995
october 13, 19, 1995
November 2, 3 , 1995
February 6, 1996
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INTERIM RlJLING
This case concerns the grievances of Ron Atkins and John
Taylor against a 3-day suspension without pay and an assign-
ment to temporary headquarters and subsequent rearsignments
to a new work location It has been alleged that the
grievors had sexually harassed a co-worker and that the
employer's act~ons were therefore justified
On the second day of hearing, while the complainant was
testifying, union counsel asked employer counsel to provide a
written prognosis and diagnosis of the complainant's condi-
tion, from a qualified medical practitioner. The complainant
had testified that she felt that her health and safety would
be jeopardized if the grievors returned to the location at
which she works She had been seeing a psychologist The
employer sub~equently produced a written report from that
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psychologist, dated August 9, 1995 The p~ycho~ogist, Ann
Dyer, Ph D , was called to testify at this hearing by the
employer, and gave evidence-in-chief on October 19, 1995 At
the conclusion of Dr Dyer's evidence-in-chief, counsel for
the union requested an order directing her to produce the
entire clinical record, including clinical notes, test
results and interpretations, pertaining to the complainant,
and sought an adjournment to prepare a review of the record
Dr Dyer advised that the complainant had authorized her to
speak, but not to release the clinical record The psycholo-
gist and counsel for the parties had further discussions and
it was left in their hands on that occasion to determlne
whether there would be consent or opposit~on to the order
requested No agreement was reached and the matter was
argued on February 6, 1996
Prior to argument as to whether production of the clin~-
cal record should be ordered, argument was made in Dr Dyer's
presence as to whether it was appropriate for her to be pre-
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sent during the argument regarding production Mr Roland's
position was that her presence was inappropriate because he
planned to make submissions as to the relevance of the docu-
ments and the reasons or uses to which he expected to put
them, ~ e he expected to disclose his probable line of
cross-examination Mr Patterson submitted that Dr Dyer
should be permitted to remain and hear the argument regarding
production, to ensure that as a professional with responsibi-
lities to her College, she could be certain that the case had
ibeen thoroughly and carefully argued, to enable her to serve
her patient's and the College's interests.
I ruled that Dr Dyer would be excused during the argu-
:ments regarding production The reasons for so ruling, not
fully stated at the time, were:
1 The arguments I was about to hear and the con-
text in which they were about to be made were simi-
lar to a voir dire as to admissibility Ordinari-
ly, the witness whose proposed evidence is being
examined in a voir d~re as to admissibility is ex-
cused from that process, and not permitted to hear
the submissions, regardless of their occupational
status or professional obligations There were no
compelling reasons in this case to depart from that
convention
2 If a witness whose professional records are
the subject of contention as to production is per-
mitted to hear the arguments and submissions as to
production, slhe may be viewed as having been in-
fluenced in hislher subsequent evidence by those
arguments and submissions Thus, if slhe is ex-
cluded from that part of the process, the integrity
of his/her subsequent evidence is protected, and it
cannot be argued that his/her evidence was influ-
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tion She had testified as to her diagnosis of the complai-
nant and had given her opinion as to cause and effect leading
to that diagnosis The underpinnings of her opinions will be
found in the clinical records, including diagnostic tests and
procedures
Further, where the employer has obtained and introduced
the opinion of an "expert witness" with special expertise,
the opposing side must be permitted to obtain the same data
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upon which the employer's expert witness relied, ;Ln order to
consult its own expert and assess the validity of the em-
ployer's psychologist's opinion without production of the
psychologist's clinlcal records, union counsel's ability to
prepare cross-examination in order(to challenge the opinions
expressed will be severely impaired
Dr Dyer's evidence as to the "stressor", result:i,.ng in
her description of the complainant's condition and her
assessment of her needs, and resulting in the diagnosis she
provided, which she acknowledged was problematic in relation
to the criteria in the D S M for the diagnosis, point to the
relevance of the clinical records in determining the accura-
cy and reliability of the opinions and assessment Dr Dyer
admitted to certain limitations in how she arrived at her
diagnosis and assessment in her evidence-in-chief~ the union
has the right to productlon in order to go behind her evi-
dence The unlon lS not engaged in a fishing expedition
Its request for production is a direct response to the evi-
dence given
The evidence disclosed that the complainant advised Dr
Dyer about earlier personal problems Dr Dyer discounted
the impact of those problems upon how the complainant pre-
sents at this time, and their impact upon her veracity The
evidence-in-chief provided glimpses of what Dr Dyer observed
to Justify her oplnions and conclusions Her opinions and
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conclusions were predicated upon the existence of certain
external stressors
The records are likely to contain information as to whe-
ther or not the workplace was causal of the grievor's condl-
tion apd whether other possible causes of her condition were
not explored which should have been
Privacy was waived when the employer called this witness
and introduced her report,
Should production be refused, one side will have been
able to pick and choose which information in the clinical
record is before the board and to hold back other information
in the record That constitutes an extreme unfairness In
that event, Dr Dyer's evidence should be strlcken, as the
union will have been denled a fair and proper crosls-examina-
tion, and therefore a full and fair hearing
Mr Roland referred me to Vancouver Community College v
Ph~llips, Barratt, (1987) 20 B C L R ( 2d) 289 (B C S C ) and
the recent Supreme Court of Canada decision in Hubert Patrick
O'Connor v the Queen, et al dated December 14, 1995
Employer counsel submitted that in these circumstances
the board has certain alternatives, the first is the
employer's preference
a) make no disclosure Order regarding 'the clini-
cal records;
b) adopt a two-step process, wherein the complete
file may be disclosed to the arbitrator, but
the union must identify specific relevant
tOplCS that it is seeking in the clinlcal
records and only the relevant material will be
produced to the board, thereafter, arguable
relevance must be determined, as well as
materiality;
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c) any order of full or part disclosure of the
record should be subject to extremely rigorous
controls due to its confidential nature
Mr Patterson provided the following material relating
to disclosure of clinical records and to disclosure general-
ly Statutory Powers Procedure Act, R S 0 1990, c S 22, s
12, Mental Health Act, R.S.O. 1990, c. M. 7 , s 35, as amen-
ded, Regulated Health Professions Act, 1991, S 0 1991, c
18, as amended, and Schedule 1, SSe 1 1, 3 and 41 1, Slavu-
tych v Baker (1975), 55 D L R (3d) 224 (S C C ) ; R v
Gruenke [1991] 3 S C R 263; R v Thurlow (1993), 24 C R
(4th) 166 (Ont Ct Prov Div ) ; R v O'Connor [1994] B C J
No 1116 (B C C A ) , R v Coon (1991), 74 C C C (3d) 146
(Ont ct Gen Di V. ) , Harrop v Markham Stouffville Hospital
et al (endorsement November 1, 1993) ontario Division Court,
R v S T.L [1992] o J No 2809 (Ont Ct Prov Div ) ; R
v J W [1994 ] O~J No 1282 (Ont Ct. Gen Div ) ; R V. Dar-
roch [1994] o J No 63; R v M C [1993] o J No 1130, De-
cision of CNO Discipline Committee re J Qaqish - Disclosure
of PSYChiatric Records, May 6, 1994; Decision of CNO Discip-
line Committee re J Qaqish - Disclosure of Psychiatric Re-
cords, August 15, 1994, R v Barbosa, unreported, Ontario
Court (General Division) August 25, 1994; KLV v D G R
(B.C C A ), Unreported, [1994] B C J No 1978, May 26, 1994,
R v St~nchcombe (1991), 68 C C C ( 3d) 1 (S C C ) , R v
Schoffer [1993] O.J. No. 816 (Ont Ct. Gen. Di v. ) ; R. v. Gin-
gras (1992), 71 C C C (3d) 53 (Alta C A ) , R v Johnston
(1991), 64 C C C (3d) 233 (Ont C A )
He submitted that the provincial legislature and the
cases have recognized the societal interest ln, the reasons
behind, and the importance of the protection of clinical
records The cases examine the four conditions necessary to
establish whether communications are privileged, found in
Wigmore on Evidence, cited in Slavutych, supra
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( 1 ) The communications must originate in a confi-
dence that they will not be disclosed
(2 ) This element of confidentiality must be essen-
tial to the full and satisfactory maintenance
of the relation between the parties
( 3 ) The relation must be one which in the opinion
of the community ought to be sedulously
fostered
(4 ) The lnjury that would inure to the relation by
the disclosure of the communications must be
greater than the benefit thereby gained for
the correct disposal of litigation
The cases indicate that the effect of non-disclosure of
the records is overriden where the interest in confidentiali-
ty is of sufficient weight . . I
Law and publlC POllCY suggest
tof'....,.4~ that such clinical records should be produced in proceedings
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of the nature before this board only in the most extreme
cases In Gruenke, supra, L'Heureux-Dube stated:
Courts and legislators have also been prepared to
restrict the search for truth by excLuding proba-
tive, trustworthy and relevant evidence to serve
some overriding social concern or judicial policy
In Thurlow, supra, the court stated
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to understand the issue in the balance, one must
have some sense of why a sexual assaul~ or rape
victim talks to a counsellor Sexual assault is
unique As a society we are just beginning to un-
derstand the profound and often permanent trauma
experienced by victims of sexual assault Unlike
almost any other crime, sexual assault generates in
the victim a confused mixture of shame, fear, an-
ger, shock, inhibition and pain This may result
ln the victim being unwilling to disclose the as-
saultive incident, particularly where ~he perpetra-
tor could be a friend of family member; or someone
in a position of trust or authority such as a tea-
cher, physician or priest The victim may realize
that in disclosing the assault, she will be expec-
ted to submit to extremely close and pesonal scru-
tiny
The court in Thurlow also quoted with approval from the affi-
davit of the executive director of the local Rape Crisis
Line, which included the following:
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Victims need to know, need to be guaranteed
that nothing would ever be disclosed to anyone
about their abuse and constantly need reassu-
rance that their identity will be protected
.I believe there is a strong likelihood that
the number of adults who seek follow up as-
sistance would drop dramatically if we could
not guaraptee confidentiality [The percen-
tage of victims who report the incidents to
the police] fluctuates with the information
that is heard in the media about the conse-
quences of reporting the intense media
exposure given to the striking down of the
Rape Shield Law discouraged many victims from
reporting their abuse to the police I be-
lieve that if victims of sexual assault heard
that their file information could be
accessed by defence counsel, they would no
longer feel safe at the Rape Crisis Line
These considerations are no less true for complainants
in a harassment situ~tion In view of the provisions in the
Human Rights Code and the collective agreement, I
the employer
does not wish to discourage complainants from seeking thera-
py The possibility that the records of their therapeutic
relationship may be accessed by the people who have harassed
them could prevent complainants from seeking treatment The
right of full reply should be balanced against the right to
maintain the patient-therapist relationship
The B C Court of Appeal in O'Connor, supra, devised a
two-stage review process in considering the production of
such records The standard of "likely relevance" the court
adopted in O'Connor is somewhat higher than the "arguably
relevant" test used before this board It is insufficient
for the union to merely allege likely relevance, The B C
Court of Appeal stated at p 4, supra
While a liberal interpretation of the word
"relevant" is to be encouraged, it is not to be
encouraged without due regard for other legitimate
legal and societal interests, including the privacy
interests of complainants in sexual assault cases
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This view is also applicable to the interests of complainants
in harassment cases This board should not unnecessarily
open the record of a person's life simply on the standard of
arguable relevance The B C Court of Appeal in O'Connor
rejected the standard of "possible relevance [of medical
records] to the credibility of the complainant" as
patently inadequate to justify their production,
in the absence of evidence indicating that there is
likely to be something in those records. relevant to
the credibility of the complainant with respect to
a particular issue in the case Invoking credibi-
lity "at large" is not sufficient to justify such
an interference with the privacy interests of a
complainant
It said the party seeking production must point at something
specific In R v S T L., supra, the court indicated that
the trifling possibility of relevance is not a sufficient
standard for the party seeking disclosure of clinical records
and that the proper test for the court to examine the records
is "a reasonable expectation that the information is rele-
vant" The court in S T L. engaged in the process of balan-
cing the various interests lnvolved in the issue In R v
J W , supra, the court indicated that cogent evidence of
relevance is required
The matters a trial judge is required to take into con-
sideration in determining the admissibility of certain evi-
dence ln sexual assault cases under s 276(3) of the Cr~m~nal
Code are reflected in the policy issues found in the Mental
Health Act and the Regulation Health Professions Act, supra
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In R v Coon, supra, the court looked, at one end of
the scale, at the seriousness of the offence and the ramifi-
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cations of the proceedlng for the accused, and at the other
end, the complainant's right to privacy and dignity and to
not have one's life laid bare There are cases in which the
charge being faced is murder or sexual assault, where the
complainant's dignity is of such significance that it tips
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the scale against disclosure In this case, the penalty was
a 3-day suspension, not the loss of a career or a prison
term When you place the penalty imposed on the grievors on
the scale against the complainant's right to privacy and
dignity, the complainant's right should weight more heavily
The employer's concern is to avoid further victimization
of the complainant In R v Barbosa, supra, the court
stated
the pursuit of full answer and defence on behalf
of an accused person should be achieved without in-
discriminately or arbitrarily eradicating the pri-
vacy of the complainant. Systemic revictimization
of a complainant fosters disrepute for the criminal
justice system
The same concern is applicable to the arbitration system In
Barbosa, the court emphasized the importance of balancing the
competing interests
Th~re is no need for the disclosure of the clinical
records The union has had full opportunity to examine the
complainant regarding the factual basis of her complaints,
and has full opportunity to cross-examine the psychologist
To permit the union to view the entire clinical record in the
hope that it may find some incidents which may discredit tpe
complainant or the psychologist is abusive and simply too
broad Disclosure should not be ordered in these circum-
stances
If disclosure is appropriate, the union should ~entify
the issues lt feels are relevant, the records should be pro-
duced to the arbitrator, and the records should not be re-
leased unless they meet the test of materiality and there is
a likellhood of a miscarriage of justice if they are not re-
leased, Further, if disclosure is appropriate, it should be
made available subject to the strictest privacy provisions
Access to the records should be limited, and access to the
information in them should also be strictly limited, to pre-
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vent any discussion of the details of the complainant's pri-
vate llfe in the workplace
Mr Roland replied that the union was forced to seek
productlon of the clinical records owing to the employer's
decision to call Dr Dyer as its witness and the evidence
glven to date The possibility that the clinical records
would be requested should have been considered before the
employer called her to give evidence Nevertheless, it is
entirely artificial to separate the psychologist's written
and oral evidence The union wishes to examine tpe records
of the complainant's statements, to impeach their reliabllity
and the conclusions drawn from them The union is entitled
to production of the clinical records Dr Dyer relied upon
them in giving her evidence and the union should not be
deprived of sn opportunity to review them and challenge her
evidence Further, Dr Dyer made certain assumptions as to
the reliability of the information she was receiving from her
patient She indicated that the complainant saw her as a
result of events which are central to this case, that she has
explored that and reviewed or analyzed the complainant's past
history, all of which laid the groundwork for her conclusions
as to causation and diagnosis Her entire file will be
relevant
The clinical records are clearly relevant to an lssue in
this proceeding Consequently, this board does not have to
determine their relevance and can by-pass the first step of
the process advocated by employer counsel At the second
stage the court determines the materiality of the records and
releases it subject to the determinations it makes as to
materiality and subject to the limitations it deems approp-
riate to impose
The topics which the employer argues the union is oblig-
ed to disclose in order to justify production have been
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raised by the employer in calling this witness with respect
to the employer's suggestion that the arbitrator review the
records and determine their relevance, the parties are in a
better position than the arbitrator to determine their rele-
vance The clinical record deals with all the issues in dis-
pute in this proceeding In seeking production, the union is
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attempting to make full answer and defence to evidence which
is relevant, and is defending against evidence which the em-
ployer presumably views as relevant The union is seeking
production of any and all documents upon which Dr Dyer based
or could have based the opinions she expressed in her evi-
dence to date
The union does not request disclosure of the clinical
record indiscriminately or arbitrarily or because evidence of
harassment complainants is inherently unsafe It makes its
request on the basis of the evidence provided by the complai-
nant, and does not intend to revictimize the complainant It
is prepared to accept certain limits on the sharing of the
information in the records with the grievors It does not
seek to provide the grievors a copy of the records or to read
them to them verbatim It wants to be able to ch~ck the sub-
stance of the records with the grievors, without disclosure
of their contents to the grievors, and to disclose the
records to its own psychiatrist
The employer's cases are distinguishable from the one
before this board The recent Supreme Court decision in
O'Connor, supra, was decided on appeal from the B C Court of
Appeal decision upon which the employer relied It is the
Supreme Court's decision which should be given the most defe-
rence Consideration should also be given to Sopinka J 's
comments with respect to stereotypical and anachr9ristic
myths impacting upon production of clinical records
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The Board's Considerations:
The material supplied by counsel indicate that over the
past approximately 15 years, the matter of the production to
defense lawyers of clinical and other records compiled by
psychiatrists, psychologists, social workers, rape crisis and
sexual assault centre staff, and other counsellors has been
carefully considered and developped by various courts, prima-
rily in criminal law proceedings There has been some uncer-
tainty as to when and whether those records will be produ-
cible The opinions of the majority of the Supreme Court of
Canada (L'Heureux-Dube, La Forest, Gonthier, McLachlin, Cory
and Iacobucci) in O'Connor v R et al , supra, are the la-
test and most compelling expression of the public interest
and judicial considerations surrounding the production of
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private or privileged documents or records in judicial pro-
ceedings The variations in the decisions of the members of
that court in that approximately 163-page decision reflect
that the most highly regarded jurists in this country differ
as to precisely how this issue should be approached
Although the proceedings before me are administrative
rather than criminal, the public policy considerations exa-
mined in O'Connor are worthy of consideration in the labour
relations/workplace context of this dispute L'Heureux-Dube
J. , writing for the majority, at p 41, stated
the principles and guidelines outlined herein
are equally applicable to any record, in the hands
1 of a third party, in which a reasonabl~ expectation
of privacy lies
She identified and discussed the competing constitutional
rights at issue regarding the production of such records as
a) the right to a fair trial (p 45)
b) the right to privacy (p 47)
c) the right ~o equality without discrimination(p. 54)
She indicated that in the context of criminal proceedings the
constititional guarantee of the right to a fair hearing in-
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eludes the right to make full answer and defence, but "the
most favourable procedures imaginable" are not necessarily
part of the guarantee She remarked, at p 45
The principles of fundamental justice vary accord-
ing to the context in which they are invoked
She noted, ln her discussion of the right to privacy, at
p 48, supra, that the right to security of the person encom-
passes the right to be protected against psychological trau-
ma She observed that the stigmatization and loss of privacy
and psychological trauma experienced by the accused in crimi-
nal proceedings is also potentially experienced by sexual
assault complainants I agree with that observation and find
it also applicable to persons who allege that they have been
victims of harassment, particularly sexual harassment, in the
workplace Depending upon the individual, there may be no
less psychological trauma and loss of privacy experienced by
victims of harassment as well as those accused of harassment,
in the determination of whether the harassment alleged has
occurred and other matters which may flow from the alleged
harassment
L'Heureux-Dube J also remarked that complainants
must contemplate the threat of disclosing to the
very person accused of assaulting them i,n the first
place, and quite posssibly in open court, records
containlng intensely prlvate aspects of their
lives, possibly containing thoughts and statements
which have never even been shared with the closest
of friends and family
Those observations apply equally to complainants of sexual
harassment in the workplace
L'Heureux-Dube J expressed the view that the right to
liberty in s , 8 of the Charter includes the right to be free
from unreasonable search and seizure, and that an essential
component of what it means to be free includes respect for
individual privacy She incorporated the views of Cory J in
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Hill v Church of Scientology of Toronto, [1995] 2 S C R
1130 at page 51 of her decision
reputation is intimately related to the right to
privacy which has been accorded constitututional
protectlon
In this case, the reputations of both the complainant and the
grievors are at stake At this stage of the proceeding, it
is the complainant's interest in maintaining her privacy that
the employer legitimately seeks to defend The board must
also be mindful of the grievors' privacy rights However,
the therapeutic records and personal histories of the grie-
vors have not beep put in issue to this point
L'Heureux-Dube J observed at p 52, supra,' that "priva-
cy can never be absolute" and "must be balanced against legi-
timate societal needs" She observed that "the greater the
reasonable expectation of privacy and the more significant
the deleterious effects flowing from its breach, the more
compelling must be the objective and the salutary effects
of disc+osure of private records to justify inte~eference
with this right", and said that in deciding whetper such re-
cords should be produced, the degree of expectation and the
significance of the deleterious effects must be balanced
against the objective and the salutary effects of disclosure
The process of determining whether disclosure of records
in sexual harassment cases is warranted has already been seen
by this board as a balancing of interests In B,asso (May 16,
1991) Kaplan (cited in Wharton, 2345/93 (Mikus) at p 4) ,
which dealt with the grievance of certaln employees discip-
lined in respect of alleged harassment, Vice-Ch~ir Kaplan
stated
On the one hand it is necessary to ensure that
obstacles to harassment complaints not be created
It is essential that complainants feel free to
complain, and that witnesses feel free to testify
On the other hand, we must also ~nsure procedural
fairness for a grievor seeking review 'of discipline
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in cases of this kind, and that is the objective or
(sic) our disclosure order
However, the Basso decision appears to have compelled the
disclosure of documents underlying the investiga~ion of the
complaint, and does not appear to have dealt with disclosure
of complainant's clinical records in the hands o~ a third
party The latter appears to be an "emerging issue" before
this board
In O'Connor, supra, L'Heureux-Dube J noted
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The essence of privacy, however, is that once
invaded, it can seldom be regained
This observation applies equally to the complainant and the
grievors in this case The grievors' reputation and privacy
have arguably been damaged/invaded by the allegations and the
actions of the employer in response They seek to regain
their reputation in this process In their case, the horse
is already out of the barn This board can at this point
only guard against unnecessary and unjustifiable .invasion of
the complainant's privacy, mindful that once violated, it can
seldom be regained L'Heureux-Dube J said at p 53-54, a
"reasonable system" of "pre-authorization" is required "to
justify court-sanctioned intrusions into the private records
of witnesses in legal proceedings", because the disclosure of
such records displaces the reasonable expectation of privacy,
and is an invasion of the individual's dignity and self-
worth
She also observed, at p 55, that
disclosure rules or practices which make mental
health or medical records routinely accessible in
sexual offence proceedings will have disproportion-
ately invasive consequences for women, particularly
those with disabilities, and children
and that in addressing disclosure
the courts must take care not to create a class
of vulnerable victims who have to choose between
accusing their attackers and maintaining the con-
fidentiality of their records
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She said that
..a legal system which devalues the evidence of
complalnants to sexual assault by de facto pre-
suming their uncreditworthiness would raise .
concerns (emphasis in original)
that the complainants' s 15 Charter rights, to equality be-
fore the law and the right to equal protection and benefit of
the law without discrimination, was being violated She cau-
tioned, at p 56
Routine insistence on the exposure of complainants'
personal backgrounds has the potential to reflect
a built-in bias in the criminal justice system
against those most vulnerable to repeat victimiza-
tion Such requests, in essence, rest on the
assumption that the personal and psychological
backgrounds and profiles of complainants of sexual
assault are relevant as to whether or not the com-
plainant consented to the sexual contact, or whe-
ther the accused honestly believed that she consen-
ted Although the defence must be free to demon-
strate, without resort to stereotypical lines of
reasoning, that such information is actually rele-
vant to a live issue at trial, it would mark the
triumph of stereotype over logic if cou~ts and
lawyers were simply to assume such relevance to
exist, without requiring any evidence t9 this ef-
fect whatsoever. (emPhasis in original)
She noted that in cases in which private files were sought by
the defence in situations not involving sexual as~aults e g
murder and assault, requests for the disclosure of files
which might have enabled the defence to impeach the credibi-
lity or establish the propensities of certain witnesses were
declined, notwithstanding the seriousness of the offences
Rather than assuming relevance, she said, the courts conclud-
ed in one case that the request amounted to a fishing expedi-
tion, and in another the "contents of the file were characte-
rized as hearsay, as potentially based on unfounded allega-
I
tions, and as generally irrelevant". She concluded that the
credibility and privacy rights of sexual assault complainants
should be treated no differently than the credibility and
privacy rights of witnesses in other offences She stated at
p 58 that
,
'i'
~
J 8
t
a privacy analysis creates a presu~ption against
ordering production of private records, but
ample and meaningful consideration must~ be given to
complainants' equality rights under the Charter
when formulating an appropriate approach to the
production of complainants' records
These remarks should be born in mind when the production of
clinical records of complainants in sexual harassment cases
is requested It should be noted that where it is suggested
that the acts alleged did not occur at all, or occured with
consent and/or the complainant's conduct was such as to in-
vite some or all of the behaviour now complained of, such
posltions bear some parallels to the defences of consent or
the honest belief of consent in sexual assault cases
L'Heureux-Dube J was of the view that in determining
whether production should be ordered, the competing interests
of privacy and equality and the right to full ans~er and de-
fence must be balanced so that they co-exist rather than any
of them trampling upon the other At this point in the
decision, she was discussing the criteria which would permit
the court to consider whether to order production of the
sought-after documents to the court, rather than to the
parties, for further consideration at the second stage of the
process She said that the applicant must show that the use
of "State power to compel production is justifiediin a free
and democratic society" in order to violate the privacy
rlghts of others.
In providing guidance to courts, L'Heureux Dube J said,
at p 60-61, that when the following criteria are met, the
use of compulsory production of private records will be
justified in a free and democratic society
1 the information sought cannot be obtained by
any other reasonably available and effectlve
alternative means;
2 the production ordered is as limited as rea-
sonably possible to fulfil the right to make
full answer and defence,
.-
~
19
t
3 the argu:ments in support of production must
rest upon permissible chains of reasoning,
rather than upon discrimlnatory assumptions
and stereotypes;
4 there is proportionality between the salutary
effects of production on the accused's right
to make full answer and defence as compared
with the deleterious effects upon .the party
whose private records are being p~oduced
She said, at p 63, that where records are sought at the
hearing, the judge should follow a two-stage approach. The
applicant seeking production initially "must demonstrate that
the information contained in the records lS likely to be
relevant either to an issue in the proceedings or to the com-
petence to testify of the person who is the subject of the
records" (emphasis added) Where the information in the re-
cords does not meet this initial threshold of relevance, a
production order should not be made
The decision of the minority of the Supreme Court of
Canada in O'Connor concurred in the use of a two-step process
to determine whether confidential records should be ordered,
and concurred that at the first stage, a determination should
be made as to whether the records should be produced to the
court Lamer C J and Sopinka J disagreed with the majority
as to the appropriate standard or threshold the applicant
must meet to persuade the court to order production to the
court at the initial stage At p 65 of the decision of the
majority in O'Connor L'Heureux-Dube J stated the view of the
minority, that the standard of "likely relevance"' should not
be interpreted as an onerous burden and indicated why that
view is not appropriate ln criminal proceedings She did not
dispute that the minority's standard would apply in a CiVll
proceeding
I would begin by notlng that Carey arose in the
context of a civil action in which neither the
right to full answer and defence nor any constitu-
tlonal right of privacy were engaged, it therefore
has no application here
!
------- --
"
20
t
The Chief Justice and Sopinka J stated at p 12 of
their minority decision in O'Connor that the "likely rele-
vance" test
should be confined to the question of whether the
right to make full answer and defence is implicated
by information contained in the records Moreover,
a judge will only be in an informed position to en-
gage in the required balancing analysis once he or
she has had an opportunity to review the records in
question
They said that at the stage of determining whether the re-
cords should be disclosed to the court, the test of "rele-
vance" is whether the information "may be useful to the de-
fence" They described that as a lower threshold and, at p
14, described it as
simply a requirement to prevent the defence from
engaging in 'speculative, fanciful, disruptive,
unmeritorious, obstructive and time-consuming'
requests for production
If the initial test of relevance is met, L'Heureux-Dube
J stated, at p 63
the court must weigh the positive and negative con-
sequences of' production in order to decide whether
and to what extent production should be ordered
At each stage counsel for all interested parties
should be permitted to make submissions
She described the above procedure as a second stage which has
two parts (p 71) The "salutary and deleterious effects of
ordering production of the records having regard to the
accused's right to make full answer and defence, and the ef-
fect of such production on the privacy and equality rights of
the subject of the records" must be balanced by the decision-
maker in determlning, at that stage, whether the records
should be produced to the court for inspection She also
said that claims of relevance should be carefully scrutinized
"in a manner sensitive to the therapeutic context and the
nature of the records created in that context" to avoid the
danger that "records having no real relevance will be pro-
~
;,'!'
21
~
duced, the search for truth frustrated, and the rights of
complainants needlessly violated" (p 69) She also said
that "in borderline cases the judge should err on the side of
production to the court" and will guard the witness's privacy
to the best of his or her ability (p 72)
L'Heureux-Dube J acknowledged at p 72 that. the minori-
ty did not share her view as to the need to balance these
intrests in the process of determining whether production to
the court is warranted The Chief Justice and Sopinka J
stated at p 11 of their dissenting decision that that
balancing should be undertaken only after th~ test of likely
relevance has been met and after the documents hav~ been
ordered produced to the court
McLachlin J , concurring with the decision of the
majority, stated that the Charter
guarantees not the fairest of all possible trials,
but rather a trial which is fundamental~y fair R
r Harrer, [1995] S C J No 81 (File No 24141)
What consitutes a fair trial takes into account not
only the perspective of the accused, but the prac-
tical limits of the system of justice and the law-
ful interests of others involved in the process,
like complainants and the agencies which assist
them in dealing with the trauma they may have suf-
fered. Perfection in justice is as chimeric as
perfection in any other social agency What the
law demands is not perfect justice, but fundamen-
tally fair justice
Conclusions:
A) Stereotypes underlying requests for disclosure
In most cases of alleged sexual harassment, the complai-
nant will be a woman and the alleged harasser a man In such
cases, the rationale behind the request for production of
clinical records pertaining to the complainant can easily be
subjected to the allegation that it is founded upon sexual
--.------
"
'(il
22
t
stereotypes of female victims, without a specific foundation
for that allegation Without a specific foundatlon, a board
of arbitration must bear in mind that sociological feature of
the dispute and approach the request for production by consi-
dering the evidence heard up to the point of the request and
the submlssions supporting the relevance of the documentation
requested and whether disclosure may be justified, and with-
out viewing the documents at this stage, base its decision
upon the information and rationale provided by both parties'
representatives, rather than on submissions that the request
is tainted by being predicated upon stereotypes As well, it
must be born in mind that at this point, the contents of the
records in question are in the hands of a third party, Dr
Dyer, and not known by counsel for either party and therefore
the submissions of both parties necessarily suffer from the
disadvantage of being somewhat speculative
B) The Wigmore Test:
I conclude that the clinical records pertaining to the
complainant meet the following requirements of the Wigmore
test
( 1 ) The communications must originate in a confi-
dence that they will not be disclosed
( 3 ) The relation must be one which in the opinion
of the community ought to be sedulously
fostered.
It was not argued that disclosure would harm the speci-
fic relationship between the complainant and her psycholo-
gist As a result, some question remains as to whether the
second requirement of the Wigmore test has been satisfied
(2 ) This element of confidentiality must be essen-
tial to the full and satisfactory maintenance
of the relation between the parties
However, it was not particularly disputed between the parties
that the records ordinarily fall within the description, as
.
~ 23
t
therapeutic records, Df those in which a reasonable expecta-
tion of priva~y lies The fourth element of the Wigmore test
( 4.) The injury that would inure to the relation by
the disclosure of the communications must be
greater than the benefit thereby gained for
the correct disposal of litigation
cannnot be fully and meaningfully determined in this case
without knowledge of the contents of the records
C) Further Applicable Law and Procedure:
The majority and the minority decisions of the Supreme
Court of Canada in O'Connor agree that in deference to and in
furtherance of the privacy rights of alleged victims and
their confidential relati9nships with their therapists,
courts should adopt a cautious approach to requests for
production This caution should be exercised through the use
of a two-step process The party seeking production of re-
cords in the hands of third parties should seek production
initially to the court, rather than to the partie? or their
representatives, for the court's inspection and further con-
sideration as to relevance and the balancing of the various
interests, before the court makes a further deciston as to
what, if any, portions of the records will be produced to the
parties, and if any, under what circumstances they may be re-
viewed and used They agree that in view of the sensitive
nature of confidential documents, particularly clinical re-
cords, the conflicting rights of the victims and the accused,
and the societal interest in limiting any invasions ~nto an
alleged victim's privacy, production to the court should only
be ordered where the court concludes that the doc~ments are
likely to be relevant and the circumstances cause it to be
reasonable in a free and democratic society to violate that
privacy right with such an order They agree that if the
court determines that the records meet the initial threshold
test justifying production for inspection to the court and
orders production, the parties and the person whose privacy
i
~.
24
t
interest is affected are entitled to notice of that decision
and to make further representations as to whether it is jus-
tifiable that any portion of the documents be viewed by the
parties or their representatives, and if so, under what
circumstances
This board is mindful of a number of competing issues in
this dispute over the production of the records in question
a) the sensitive and private nature of the reco~ds
of which the grlevors seek disclosure,
b), the complainant's and the public's interest in
protecting and fostering the patient-therapist relationship,
which is predicated upon confidentiality,
c) the seriousness of the allegations made against
the grievors;
d) the grievors' right to prepare a full and fair
defense to the allegations;
e) the labour-management community's interest in
carrying out hearings of disputes of this nature with minimal
intrusion upon the privacy rights of the complainant and the
grievors,
f) that community's interest in ensuring the
f
fairest hearing possible, while addressing those competing
lnterests,
g) that community's interest in ensuring that qom-
plainants are not discouraged from bringing their complaints
forward,
h) the potential impact that this interim ruling
I
will have on future possible complainants and their
therapists
No findings have yet been made as to whether there has
been sexual harassment in this case It is appropriate to
bear in mind that sexual harassment in the workplace may have
a different impact upon each victim In some cases the vic-
tim experiences profound pain, embarassment and humiliation,
"
~
25
t
I
public and private, as well as the prospect of having to
interact with the alleg~d harasser who may remain in the same
workplace On the other hand, an employee who may have been
wrongfully or mistakenly accused and determined by the em-
ployer to have sexually harassed another employee is likely
to experience similar pain, and public and private embarass-
ment and humiliation, if not some ambivalence or opposition
to remaining in the same workplace as the complainant At
this stage of the proceedings, to determine whether the em-
ployer's actions were justifiedl this board is engaged in a
fact-finding exercise It has heard substantial evidence but
has made no determination as to the credibility of either the
complainant or the grievors or any other witnesses' and as to
what occurred as between the complainant and the grievors
\
The Grievance Settlement Board has the authority to or-
der the production of documents under s. 48 ( 12 ) (a) and (b)
of the Labour Relations Act, 1995, S 0 1995, C. 1 (formerly
s 45 ( 8 1) , subpara 1 and 2 of the Labour Relations Act,
R S 0 1990, C L 2), which provides
(12) An arbitrator or the chair of an arbitration
board, as the case may be, has power,
(a) to require any party to furnish particu-
lars before or during a hearing,
(b) to require any party to produce documents
or things that may be relevant to the
matter and to do so before or during the
hearing;
The standard that is generally applied by this board in de-
termining whether to order production of documents, including
medical records, is that of "arguable relevance" Koonings/
Fromer 3483/92 etc (Stewart) , O'Brien 1948/93 etc (Finley) ,
Wharton 2345/93 (Mikus)
Once the employer called Dr Dyer to testify and once
she gave her evidence-in-chief pursuant to the complainant's
-
26
I t
partial consent "to speak", i e to testify, any right of
privacy they wished to claim with respect to the clinical
records was put at risk Vancouver Community College, supra
Dr Dyer's opinions and observations expressed in her evi-
dence-in-chief were in whole or in part based on her observa-
tions and test results and other material contained in the
clinical record To determine whether the action~ taken by
the employer in respect of the grievors was justified or con-
trary to the collective agreement or offended a fundamental
principle of justice, this arbitration hearing is in the pro-
cess of examining, among other things, the veracity of the
complainant's allegations, her current psychological or psy-
chiatric diagnosis and prognosis and needs for accomodation,
if any, in the workplace A witness proferred as an expert
with respect to any of these issues may not select which ob-
servations and opinions s/he will share, but is ordinarily
obliged, once s/he testifies, to disclose the entire basis of
his or her opinion, i e the complete clinical record, and
permit her opinions to be challenged through informed cross-
examination, in order to enable the board to weigh and assess
and determine whether to accept those opinions and observa-
tions Further considerations with respect to th~ privacy
and confidentiality of the records, their relevance, and the
competing interests discussed above may, only in appropriate
circumstances, llmlt that obligation
An expert witness may be requested to attend a hearing
before this board, in a summons issued by the board, at the
request of either party and served upon him/her The summons
may specifically request, by the insertion of appropriate
words by the party requesting the summons, to bring to the
hearing all books, records, documents, etc touching upon the
matters in question in the proceeding Such a summons may
serve as notice to the prospective witness that the clinical
records may be subject to production The witness may then
.
.~
~ 27
wish to consult with the party calling him/her as to the ad-
visability of same and consult his/her own legal advisors
Where the expert witness may object to or beiunable to
consent to the disclosure of the records, the party request-
ing the expert to testify should serve a summons and indicate
in it that they are requested to bring the records underlying
their evidence with them This will hopefully al~rt and in-
vite the witness to disclose his/her position to the party
calling them, which should then be disclosed to the other
side at the earliest possible opportunity The issue of
whether Dr Dyer had been so summoned was not explored in
argument and the issue is not particularly material at this
point These remarks are made with the intention of provid-
ing guidance in future cases, to avoid delays
The submissions proceeded informally on February 6,
1996 The Supreme Court of Canada has indicated that in pro-
ceedings as to production of documents in which there is a
privacy ~nterest to be protected, notice of those proceedings
should be given to the party in possession of the records,
and the person with a direct privacy interest in the records,
in addition to the parties to the dispute As a matter of
prudence, such notice should be given to those persons in
proceedings before this board In keeping with the informal-
ity of the proceedings before this board, the notice need not
be in writing, dependlng on the circumstances, provided that
the board receives as'surance from counsel that it has been
1
given I under,stand that the complainant was given notice of
the request for production of the records made on October 18,
1995, within a reasonable period thereafter and that with her
consent, counsel for the employer, rather than her own law-
yer, represented her position when submissions were made on
on February 6, 1996 I am satisfied that when I heard sub-
missions on that date, all those entitled to notice that the
board would be considering the issue were notified
i
~
~ 28
t
The competing interests of the complainant and the grie-
vors as well as the labour relations context requires this
board to approach the issue of production of confidential re-
cords with the caution and care described by the ~ustices of
the Supreme Court of Canada The fact that this dispute as
to productlon has arisen in a labour relations context rather
than a criminal context does not suggest that any less cau-
tion and respect for the competing interests of both parties
should be used in dete+mining whether the records should be
produced than was recommended by the Supreme Court of Canada
in O'Connor While I recognize that such an approach will
lengthen these proceedings, it must be recognized that this
dispute has arisen between employees who are members of the
same bargaining unit and who have an interest in seeing
that their competing rights are respected in this process
As well, how this determination is made will likely impact
upon whether other complainants will wish to come forward in
future In this context, it is important that the decision
as to the requests for production of confidential records be
made carefully, and be seen to be made fairly, without the
appearance of arbitrariness, such that the employer and all
members of the bargaining unit retain respect for the
process
I therefore conclude that this board should apply the
two-stage approach described by the majority of the Supreme
Court of Canada in O'Connor, with some modificatio~s in
recognition of the fact that this is a civil proce~ding, and
that these proceedings are intended to be informal I turn
now to the first stage of the process
At the point at which they are asking the board to order
documents to be produced to the board, neither the applicant
nor the responding party will necessarily have knowledge of
the contents of the records, which have presumably remained
private I conclude that the means by which an applicant can
.
'"
t 29
!
demonstrate the relevance of confidential records in such
circumstances is by reference to additional and/or alterna-
tive facts of which it already has knowledge and which it
intends to prove and/or by reference to the evidence given to
that point, and to advocate that the records, to the extent
that they likely deal with those facts or evidence, have a
likely potential to shed light upon the issues predicated
upon those facts I am supported in this conclusion by the
remarks of the Chief Justice and Sopinka J at p 14 of their
decision in O'Connor wherein they discuss prior Supreme Court
of Canada decisions which commented upon the inability of the
applicant to prove relevance of documents not seen prior to
the application. They said, at p 15
the concern expressed in these cases applies
with equal force in the case at bar, where the ul-
timate goal is the search for truth rather than the
suppression of potentially relevant evidence
The proceedings before this board are civil proceedings
The offence alleged has criminal overtones, but the actions
of the employer, which are subject to review before this
board in the context of this grievance, took place in a non-
crimlnal, civil context, in the workplace
In view of the remarks of L'Heureux-Dube J regarding
the standard for production to the court in civil proceedings
and the remarks of the minority, I conclude that the test
that must be applied at this stage of the proceedings is that
of "llkely relevance" as described by the minority decision
of the Chief Justice and Sopinka J in 0' Connor, i.e whether
the records "may be useful to the defense", in this case, the
grievors I also conclude that for all practical purposes,
that test of likely relevance and the test of arguable rele-
vance used by this board, are indistinguishable
--------
.
,.,
- ,,: 30
~
Although these are civil proceedings and the test of
"likely relevance" is somewhat lower than that set out in the
judgment of L'Heureux-Dube J , in view of the potential inva-
sion of the complainant's right to privacy, I agree with her
view, that in determining initial relevance at the first
stage of the process, "it cannot be assumed that such records
are likely to be relevant" and that if the applicant fails to
demonstrate that likely relevance, an appearance of a fishing
expedition will arise and production should be refused How-
ever, I agree with Lamer C J and Sopinka J that the burden
of establishing likely relevance should not be onerous
While the authorlty of an administrative tribunal is not
entirely parallel to "State power" in a criminal proceeding,
the legislature has empowered this board with a quasi-judi-
cial authority to "require production" and thereby the poten-
tial authority to violate privacy rights In my view, that
authority should not be exercised lightly The decision of
the majority in O'Connor indicated that to meet the threshold
test for production of the records to the board, the board
must be persuaded, through the consideration of 4 criteria
that its use of its power to compel production is justified
in a free and democratic society Although because this lS a
civil proceeding, that threshold test may not be applicable,
in my view the board should consider the 4 criteria in
determining whether disclosure to the board is warranted
with respect to the first criterion
1- the information sought cannot be obtained by
any other reasonably available and effective
alternative means,
there does not appear to be any other reasonably available
and effective means by which to obtain the information in Dr
Dyer's records The information is unique to the confiden-
tial relationship between her and the grievor, and could only
possibly be obtained by means of a private investigator who
~,
~ .
ti 3 1
?
undertook a study of the complainant's personal and social
history Such an investigation has the potential of consti-
tuting an even less discreet violation of the complainant's
privacy than the production of the records to the board
With respect to the second criterlon
2 the production ordered is ~s limited as rea-
sonably possible to fulfil the right to ~ake
full answer and defence,
the entire clinical record has been requested, including test
results In the absence of any indication that certain parts
of the record have no bearing on these proceedings, and in
the absence of an inventory of what the records contain, it
is premature for the board to determine any limitations on
production to itself, if it decides to order production
With respect to the third criterion
3 the arguments in support of production must
rest upon permissible chains of re~soning,
rather than upon discriminatory assumptions
and stereotypes;
there have been no submissions by counsel for the grievors
that would indicate that his request for productlon of the
records is founded upon an assumption that the grievor, by
virtue of being a female complainant, lS less than. creditwor-
thy, or on an assumption that the existence of a therapeutic
relationship signals that her testimony is unreliable It
appears to be based on the nature and quality of certain
aspects of the complainant's and Dr Dyer's evidence, which
are unrelated to their sex or sexual stereotypes While
there may be some concerns on the part of the employer that
the request for production is fueled by discriminatory
assumptions and stereotypes of the grievors, that is a matter
that can be dealt with if the board directs production of the
records for inspection by the board, and if production to
counsel for the parties is ultimately warranted We are not
at that stage yet.
--.- - -
~
0
~ ~~
J~
t
With respect to the fourth criterion
4 there is proportionality between the salutary
effects of production on the accused's right
to make full answer and defence as compared
with the deleterious effects upon the party
whose private records are being produced
there is always a potential for harmful consequences where
records in which an expectation of confidentiality was placed
are ordered to be produced Complalnants and victims may
decline therapy before litigation is resolved, and maintain
an uncomfortable and unpleasant emotional state, with nega-
tive impact upon themselves, the workplace and the employer
The patient in therapy may lose confidence in the therapeutic
process and discontinue it Therapists may be reluctant in
future to maintain written records for patients caught in
litigation, and their therapy may be less effective for the
lack of a written record If the records are ordered pro-
duced to the board, they can and will be maintained in a se-
cure place and be viewed only by the board at this stage of
the proceeding They may never be disclosed to c0unsel for
the parties or anyone else, depending upon the outcome of the
second stage of consideration Consequently, any salutary
effect on the grievors' right to make full answer and defence
if the records are disclosed only to the board remains to be
seen There have been no submissions that the complainant
would suffer any untoward effects if the clinical records
were examined by this board There appears to be no lmmedi-
ate benefit to the grievors if the board examines the clini-
cal records I therefore conclude that the test of propor-
tionallty is met
In view of the foregoing, I conclude that the production
of the records to this board in this case would constitute a
limited violation of the grievor's privacy which is justified
in a free and democratic society
,;~
.ij'
., ... ...
.J .,
t
The next issue to be determined is whether the submis-
sions and evidence heard to date establish a sufficient deg-
ree of relevance of the records so as to justify their pro-
duction to the board There is no requirement in the stan-
dards established in O'Connor that union counsel identify
each of the issues to which the records are relevant I am
supported in that conclusion by the indication of L'Heureux-
Dube J at p 77 that if, upon inspection, material is ~ound
in the records "that is essential to the accused's ability to
ij, even if it was not argued as
make full answer and defence, a
baSlS for production" that material should be disclosed She
also remarked, at p 78
in some such cases, sensitivity to the complai-
nant's privacy rights and security of the person
might dictate that the plaintiff be given the
option of withdrawing from the prosecution rather
than facing production of the records in question
In administrative proceedings such as these, in approp-
riate cases, a complainant and/or employer counsel may have
the option of withdrawing the evidence of an expert in whose
hands rest records of a particularly sensitive nature
The employer called Dr Dyer as its expert witness In
doing so, it put her opinions, upon which it ostensibly
relies, in issue in this proceeding Dr Dyer gave evidence
as to her diagnosis of the grievor's current condition, which
she acknowledged was somewhat at variance with the criteria
in the D S M She also gave opinion evidence as to the eti-
ology of some of the complainant's symptoms and ability to
perceive and recall social interaction accurately Her opi-
nions were based in part upon her understanding of the com-
plainant's personal and social history If her understanding
was ln error, or if she gave weight to certain aspects of
that history and not to others, the opinions and conclusions
that she stated in her evidence-in-chief may have been erro-
neous and misleading It was.not disputed that in all proba-
bility her clinical records contain her notes from her meet-
~
(~'"
. 34
\
t
ings and contacts with the complainant and others in the
course of treating her, and test results and her interpre-
tation of them, which formed the basis of her understanding
of the complainant's history and symptoms and reliability as
a witness, to which she testified I conclude, therefore,
that the information in her records "may be useful" to coun-
sel for the grievors and "implicates", in the words of the
Chief Justice and Sopinka J , the grievors' right to make
full answer and defence In view of the foregoing, I con--
elude that counsel for the grievors has satisfied the appro-
priate test of likely relevance
I therefore order Dr Ann Dyer to produce her complete
original clinical records with respect to the complainant,
including but not limited to all written notes, letters,
papers, documents, tests, test results and interpretations,
to the Registrar of the Grievance Settlement Board in a
sealed envelope, where they will be kept in a secure place,
for my inspection Dr Dyer may, of course, retain a photo-
copy of the clinical records pending return of the originals
This ruling has been written in a discursive manner to
provide an understanding to the parties of the reasons behind
it, and on the understanding communicated to me by counsel
for the parties that it will be made available to counsel for
the College of Psychologists of Ontario and th~t its contents
will not be disclosed to Dr Dyer until after her evidence
has been completed
I believe at this point in the proceedings it will be
useful for the parties, the complainant, and the College of
Psychologists of Ontario to be aware of the approach approved
by the Supreme Court of Canada in O'Connor, supra, to deter-
mlne whether, after inspection and careful consideration of
each document, dlsclosure to the party requesting same is
warranted, and if so, under what terms and conditions I
-.' "
I ~
t~'
-I;; 35
t
therefore have provided a brief statement of that Court's
recommended approach at the second stage, after production to
the court has been ordered, in the attached Addendum After
the clinical records have been produced to the board, the
second-stage conslderations will be applied If any form or
degree of disclosure of the records to the parties is ruled
appropriate, the board will consider what limitations, if
any, would be appropriate and effective in order to protect
the privacy and integrity of the records
The complainant and Dr Dyer or her representative, if
any, and counsel for the parties, may request the opportuni-
ty, after production of the records to the board, to make
submissions as to these and any other matters of relevance in
determining the matter, before a ruling at the second stage
of the recommended process is made
Dated at Toronto this 22nd day of March, 1996
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ADDENDUM TO INTERIM RULING
L'Heureux-Dube J said at p 74 that if the court deter-
mined that it was appropriate that the confidential material
be produced to the court for inspection, having received and
inspected the material, it should only order production of
those "parts of the records that have significant probative
value that is not substantially outweighed by the danger of
prejudice to the proper administration of justice or by the
harm to the privacy rights of the witness or to the privileg-
ed relation " She set out a "not exhaustive" list o'f factors
at p 74-75 which should should be considered in deciding
whether production is warranted
( 1 ) the extent to which the record is necessary for the
accused to make full answer and defence,
(2 ) the probative value of the record in question,
( 3 ) the nature and extent of the reasonable expectation
of privacy vested in that record,
(4 ) whether production of the record would be premised
upon any discriminatory belief or bias;
(5 ) the potential prejudice to the complainant's digni-
ty, privacy or security of the person that would be
occasioned by production of the record in question,
(6 ) the extent to which production of records of this
nature would frustrate soclety's interest in encou-
raging the reporting of sexual offences and. the ac-
qUlsition of treatment by victims, and
(7 ) the effect on the integrity of the trlal process of
producing, of failing to produce the recqrd~ having
in mind the need to maintain consideration in the
outcome
She also stated, at p 77, that at this stage the court
should lnquire into whether the issues to which the records
are said to be relevant "are collateral to the real issues at
trial" , and that as "the defence cannot pursue inconsisten-
cies on collateral issues", production on collateral issues
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does not advance its position and serves no useful purpose
Consequently, she said, declining production of "information I
relating only to collateral issues will not impair the ac-
cused's right to full answer and defense" She stated that
justice dictates production of material found by the inspec-
ting court to be "essential to the accused's ability to make
full answer and defence, even if this information was not
argued as a basis for production".
She stated, at p 78, that the court "should inspect
each individual record for materiality", and "may, in certain
cases, wish to hear submissions on whether the vetting of the
records should be assisted by counsel for the complainant, or
for the guardian of the records" She approved the review of
the records in camera and keeping the records sealed and in
the custody of the registrar, prohibitions on reproduction,
and publication bans on such terms as are deemed appropriate,
and keeping "all records produced to the court but not ultl-
mately to the defence sealed and retained in the file in
the event that they should need to be reviewed later" She
sald
In exceptional cases, the court may consider making
an order prohibiting defence counsel from discuss-
ing the contents of these records with the accused
The Chief Justice and Sopinka J were of the view that
the court's determinations as to the production of clinical
records for the court's inspection and whether and to what
extent disclosure should be permitted should be approached
separately from the issue of admissibility of the records i~
the proceedings (p 13) They indicated that depending upon
their temporal connection with the events in question; such
records may be relevant to the unfolding of events leading to
the complaint, the influence of therapy and other factors
which bear upon the complainant's memory and quality of per-
ceptlon of the events (p 17) They agreed that if the court
was of the view at the first stage of the process that the
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records were likely relevant and ordered them produced to the !
court, that the court should balance the competing'rights in
question However, they limited their agreement to a consi-
deration at that stage of the first five of the seven factors
L'Heureux-Dube J recommended, and were of the view that the
last two factors should be considered at the stage of deter-
mining admissibility
The Chief Justice and Lamer J said that at the second
stage, in determining whether production should be ordered,
the test should be higher, and that
the presiding judge must be satisfied that there is
a reasonable possibility that the information is
logically probative to an issue at trial or the
competence of a witness to testify
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They stated that relevance to "an lssue at trial" includes
"evidence that may be probative to the material issues in the
case (i e the unfolding of events)" as well as "evidence
relating to the credibility of witnesses" and the reliability
of other evidence