HomeMy WebLinkAbout1994-0491.SAMAROO98_02_26
OfofTARIO EMPLOYES DE LA COURONNE
CROWN EMPLOYEES DE L'OfofTARIO
1111 GRIEVANCE COMMISSION DE
SETTLEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST SUITE 600, TORONTOONM5G 1Z8 TELEPHONEITELEPHONE (416) 326-1388
180, RUE DUNDAS OUEST BUREAU 600, TORONTO (ON) M5G 1Z8 FACSIMILEITELECOPIE (416) 326-1396
GSB # 0491/94
OPSEU 94B842
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETfLE:MENT BOARD
BETWEEN
OntarIo PublIc ServIce Employees Druon
(Mohan Samaroo)
Grievor
- and -
The Crown m RIght of OntarIo
(Mirustry of the SolIcItor General and CorrectIOnal ServIces)
Employer
BEFORE Owen V Gray Vice-Chair
FOR THE Craig Flood
GRIEVOR Counsel
Koskie Minsky
Bamsters & SoliCItors
FOR THE Jane Hooey
EMPLOYER Counsel, Legal ServIces Branch
Management Board SecretarIat
HEARING April 1 and 6, 1998
June 8, 1998
DECISION
[1] Mohan Samaroo gneves that he was unjustly dIsmIssed from hIs employ
ment as a correctIOnal officer ThIs decIsIon addresses certam prelImmary Issues
raIsed by the employer concernmg the eVIdentlary effect to be gIVen m these pro-
ceedmgs to the results ofproceedmgs taken agamst the gnevor m cnmmal court
Background
[2] In late October 1993, two female mmates at the WhItby Jail complamed
that a guard - the gnevor - had sexually assaulted them These complamts
were reported to the polIce, who mvestIgated them The MmIstry's Independent
InvestlgatIOn Umt (the "IIU") was also asked to conduct an mvestlgatIOn, whIch
It dId The gnevor was suspended m early November 1993 pendmg completIOn of
the IIU mvestlgatIOn.
[3] When officers from the Durham RegIonal PolIce sexual assault umt mter
vIewed the two complamants, LIsa Watson and Tracy Armstrong, they learned of
a thIrd former mmate, Susan Mame, who was allegedly assaulted by the gnevor
In early November 1993 the polIce charged the gnevor wIth havmg sexually as
saulted Mame, Armstrong and Watson on October 6, 17 and 22, 1993, respec
tlvely
[4] The IIU mvestlgatIOn contmued for several months In the course of It,
the mvestIgator learned of two more women - PatncIa lVl1tchell and Annette
QUlbbel - who claimed to have been Improperly treated by the gnevor whIle
they were mmates at the WhItby JaIl m the fall of 1993 The mvestlgator shared
2 -
thIS mformatlOn wIth the polIce The mvestlgator's report m March 1994 con
cluded that the gnevor had sexually assaulted all five mmates on the occaSlOns
and m the manner that they had descnbed
[5] By letter dated May 19, 1994, the employer mformed the gnevor that It
had deCIded to dIsmISS hIm from employment because It had concluded, on the
basIs of the IID mvestlgator's report,
1 That you engaged ill sexual unpropnetles agaillst five (5) female illmate
offenders between the penod of August 1993 and November 1993
2. In commlttmg these offences you have senously breached the trust placed
ill you as a Peace/CorrectIOnal Officer
3 You have breached the secunty prOVISIOns of the illstItutIOn as outhned ill
the Standmg Orders by removillg an illmate from a segregatIOn cell
wIthout a back up
Mr Samaroo ImmedIately filed a gnevance allegmg that the dIsmIssal was un
Just
[6] The tnal of the cnmmal charges agamst the gnevor began m June 1994
before Judge Dodds The tnal Judge heard testlmony about the three assaults
wIth whIch the gnevor was charged He also admItted, as "SImIlar fact" eVIdence,
testlmony by PatncIa MItchell and Annette QUlbbel about the assaults they al
leged the gnevor had commItted on them. The gnevor testlfied m hIS own de
fence He demed each of the allegatlOns and mamtamed that they must have
been the result of a conspIracy mItlated by one of the complamants At the end of
the tnal, m reasons for Judgment delIvered on March 27, 1995, Judge Dodds
found that all five complamants were credIble and that theIr allegatlOns were
true
[7] Susan Mame's allegatlOns, as the tnal Judgment descnbed them, were
that on October 6, whIle escortmg her to the office of the Jail classIficatlOn officer,
the gnevor had patted her on the nght buttock. She responded by askmg hIm
"What are you domg?", he replIed "Do you lIke It?", she Said "No" and he sald
"Then I won't do It agam."
3
[8] Tracey Armstrong's allegatIOns, as the trIal Judgment descrIbes them,
were that on October 16 or 17 the grIevor dIrected her to approach the cell bars
When she complIed, he reached through the bars and grabbed her breast. She
backed away He mVIted her to return to the bars wIthout her ShIrt or brassIere
She was astomshed, and spoke to hIm rudely
[9] LIsa Watson's allegatlOns, as the trIal Judgment desCrIbes them, were that
on October 22, 1993 the grIevor called her out of her cell to sharpen penCIls As
they were walkmg down a hallway to the desk at whIch penCIls are sharpened, at
a locatlOn out of VIew of other mmates, the grIevor told her that she was a sexy
lady and, approachmg her from the rear, grabbed her breasts wIth such force
that she had to use both hands to dIslodge hIS grasp
[10] Annette Quibbel's allegatlOns, as the trIal Judgment desCrIbes them, were
that durmg a weekend m November 1993 the grIevor made a sexIst remark to
her, to whIch she responded by throwmg a cup of tea on hIm. Somewhat later
that day, the grIevor asked her If she would clean a cell for hIm. She replIed that
she would do so If he gave her a CIgarette He released her from the cell. As they
were walkmg down a corrIdor, the gnevor suddenly commented on her breasts
and reached to touch them She smacked hIS hand away and returned to the cell
she was sharmg that weekend WIth PatncIa MItchell,
[11] PatncIa l\ihtchell's allegatIons, as the tnal Judgment descnbes them, were
that on the day referred to m QUlbbel's testImony, mmutes after Qmbbel re-
turned to theIr cell, the gnevor asked MItchel to clean a cell for hIm. She agreed,
and he released her from her cell. When they were about 15 feet away from the
cell, he pushed her mto a corner, lIfted her shIrt and began klssmg her breasts
He stopped when he heard another guard callmg for hIm, and MItchell returned
to her cell.
[12] Judge Dodds found the gnevor gmlty of sexual assault on LIsa Watson
and Tracy Armstrong He concluded that there was reasonable doubt whether
4
the gnevor's unwanted touchmg of Susan Mame had the reqUIsIte sexual ele
ment, and found hIm gUIlty of common assault wIth respect to that mCIdent.
[13] The gnevor was sentenced on June 12, 1995 In hIs submIsSIOns on sen
tence, the gnevor's counsel submItted that the sentence should focus on specIfic
deterrence and rehabIlItatIOn, rather than on general deterrence As for specIfic
deterrence he submItted that
There s no reason to suppose that.rvlr Samaroo IS a threat to anyone at the
present trme. While he's trvmg to get hIs Job back through the gnevance
procedure, I submIt that It IS perfectly ObVIOUS that wIth three convIctIOns
agamst hrm for assaultmg mmates he will not get that Job back, and I
submIt that thIS fact would mdIcate that a harsh sentence IS not necessary
for purposes of specuic deterrence because he IS deterred from ever workmg
m that posItIOn agam. He IS not gomg to be m that posItIon.
[14] In hIS reasons for sentence Judge Dodds stated that he had "no doubt that
thIs man WIll not offend agam m the manner m whIch he has offended m the
past." He Said he would not take the SImIlar fact eVIdence mto account m sen
tencmg, as he belIeved that "he should be sentenced for the matters for whIch he
stands convIcted" He held that whIle speCIfic deterrence was not a factor, gen
eral deterrence was He sentenced the gnevor to two months' mcarceratIOn fol
lowed by two years' probatIOn.
[15] The gnevor appealed the conVIctIOns That appeal was dIsmIssed m late
March 1996
[16] Thereafter, Mr Samaroo's gnevance first came on before me for hearmg
on December 18, 1996 The course these proceedmgs took between then and Feb
ruary 1998 IS descnbed m my decIsIOn of Februarv 25, 1998 It IS noteworthy
that part of the delay m brmgmg thIS matter back on for hearmg resulted from
the partIes' agreement to awaIt the outcome of an applIcatIOn for JudICIal reVIeW
of the October 15, 1996 deCISIOn of the Board (dIfferently constItuted) m Wlute,
810/95 (Dlssanayake)
[17] In Wlute, the gnevor was dIsmIssed from hlS pOSItion as a reSIdential
counsellor for sexually assaultmg a female reSldent m the course of hIS employ
- 5
ment, after he had been charged wIth and conVIcted of sexually assault on the
resIdent. He gneved. He also appealed the conVIctIOn. The appeal was dIsmIssed
When the gnevance came on for hearmg, the employer asked the Board to rule
that It would accept the convIctIOn as conclusIve proof that the gnevor had sexu
ally assaulted the resIdent, and would refuse to allow the gnevor to re-lItlgate
that Issue m the gnevance proceedmgs In the alternatlve, It asked that the
Board rule ~hat the convIctIOn was pnma facLe proof of the assault. WhIle ac
knowledgmg that the Board could admIt eVIdence of the convIctIOn, the umon
took the posItlon that the Board could not and should not treat It as proof of the
sexual assault for purpose of the arbItratIOn proceedmgs before It. The Board
concluded that although the certIficate of convIctIOn would be admItted mto eVI-
dence, It would not be appropnate to accept It as proof of the sexual assault, eI
ther conclUSIvely or on a pnma facLe baSIS
[18] The employer applIed for JudIcIal reVIew of that deCISIOn. In an oral decI
SIOn smce reported at (1997) 32 0 R. (3d) 572 sub nom Re the Queen Ln R~ght of
Ontarw as represented by the Mimster of Commumty and SOCLal SerVLces and
Ontano Crown Employees Gnevance Settlement Board et al, the DIvISIonal
Court saId
In our VIew the Board wa~ m error as to the u~e whIch may and should
properly be made of the conVIctIOn of the gnevor on a charge of sexual
assault the very alleged assault that IS apparently rehed on by the employer
for dIsmIssal. The deCISIOn made ~eems to have been that the certIficate or
other proof of conVIctIOn would be recelVed, but not as pnrna facIR eVIdence of
the fact of the assault. That flIes ill the face of recent Court of Appeal
decIslOns ill thIS provmce illcludillg DernefRr v Bnt~sh Pac~fic L~fe lnsurcmce
Co (1984), 48 0 R. (2d) 266 and Re Del Core and Ontarw College of
Pharrnacl))ts (1985) 51 0 R. (2d) 1
Proceedmg on the baSIS of U E S. v B~beault, [19881 2 S C R. 1048 the
ruhng by the board IS not one whIch can or ought to attract Juchcwl deference
by reason of the Board's speCIal expenence and expertIse and the ruhng goes
to the very heart of the carrymg out of ItS statutory dutIes There IS nothmg
m sectIOn 48(12)(f) of the Labour Relatwns 4.ct that could support the
concluslOn arnved at by the board m ItS prelImmary ruhng As a matter of
rmportant publIc polIcy, It IS not permISSIble for a board m the exerCIse of ItS
duties srmply to Ignore a relevant determmatIOn made ill a crrmmal tnal,
sustamed by our Court of Appeal, as to the accused havmg committed a
certam kmd of assault.
6
In the partIcular CIrcumstances of thIS case the Board ought to have made
It clear that the convictIOn would be receIVed and stand as pnma fOCLe
eVidence of the sexual assault on a female resident of the Huroma RegIOnal
Centre at Onlha. The eVidentiary rulIng was wrong, was patently
unreasonable and cannot stand. The matter will be returned to the Board for
contmuatIon of the hearmg agamst the background of thIS decision
We do not deal with the submissIOns alternatIVely made for the first tune
at thIS hearmg on the Issues of abuse of process and estoppel. We make no
ruhng as to how the eVidence at the hearmg will unfold, or as to the order of
eVIdence. That would be mappropnately to trespass m advance on Issues for
the Board m the conduct of the hearmg
[19] It IS not apparent from the decIsIOn what submISSIOns the employer made
before the court "for the first tIme" that It had not made before the Board at first
mstance m support of ItS pnmary pOSItIOn that the conVictIOns should be treated
as conclUSIve, Irrebutable proof of the mIsconduct for WhICh the gnevor had been
convicted Whatever the dIfferences m presentatIOn may have been, m the end
the court dId not dIrect that the Board treat the conVictIOns as conclUSIve of the
questIOn whether the gnevor m that case commItted the mIsconduct for whIch he
had been conVIcted
The Preliminary Issues
[20] When thIS matter come on for hearmg on February 18, 1998, employer
counsel raIsed certam matters as "prehmmary obJectIOns" My deCISIOn of Febru
ary 25, 1998 descnbed those matters
The employer s prehmmary ObjectIOn IS that the gnevor s conVIctIOns
are conclUSIve proof of certam Issue~ of fact m these proceedmgs ThIS
obJectIOn" rests on these assertIOns of fact that the deCISIOn to dIsmISS the
gnevor was based on five assaults allegedly commItted by the gnevor on
female mmates and that those five assaults are the three assaults m respect
of which the gnevor was conVicted m crunmal court together With the two
assaults about WhiCh the cnmmal court heard Slmuar fact te~tunony The
employer asserts that doctrmes of Issue estoppel and abuse of process reqUIre
that I treat the certIficate of the conVIctIOns together With the Judge s reasons
for Judgment (and perhaps other matenals relatmg to the crunmal
proceedmgs) as concluswe eVidence of all five assaults, and preclude the
gnevor from chsputmg that eVidence m these proceedmgs In the alternatIVe
It contends that the results of the crunmal proceedmgs are pnma foclR
eVidence of the assaults on which the employer relIes m these proceedmgs.
Employer counsel proposed that I determme as a prehmmary matter whether
and to what extent doctnnes of Issue estoppel and abuse of process have the
effects for which she contends m thIS case In that connectIOn employer
7 -
counsel mtends to call the IID mvestIgator and the pollce officer whose
mvestIgatIOn led to the cnmmal proceedmgs, m an effort to establlsh
congruence between the basIs of the dIscharge decIsIOn and the basIs of the
cnmmal conVIctIOn
[21] I determmed that the matters descnbed would be addressed as prelImI
nary Issues Havmg regard to the hIstOry of the matter and the course the hear
mg took on February 18, 1998, I gave detaIled dIrectIOns WIth respect to the de
lIvery of partIculars and dIsclosure of documents m advance of the eVIdentiary
portIOn of the hearmg on the prelImmary Issues, WhIch were confirmed m my de
CISIOn of February 25, 1998
[22] The umon conceded that the three conVIctIOns regIstered agamst the
gnevor could be receIved as pnma facLe eVIdence that he had commItted the mIS
conduct for WhICh he was convIcted the sexual assaults on LIsa Watson and
Tracy Armstrong and the common assault on Susan Mame The Issues m dIspute
that were to be the subject of prelImmary determmatIOn were, therefore,
. whether Issue estoppel applIes so as to preclude the umon and the
gnevor from dIsputmg m thIS proceedmg the cnmmal tnal Judge's
findmgs of mIsconduct by the gnevor toward the five fema!e mmates,
that IS, the three mCIdents of mIsconduct that were the subject of con
vIctIOns plus the two mCIdents of mIsconduct that were the subject of
the "sImIlar fact" eVIdence at the cnmmal tna!,
. whether the umon and the gnevor are or should be precluded from
dISputmg m thIS proceedmg the cnmmal tnal Judge's findmgs of mIS
conduct toward the five fema!e mmates, that IS, the mISconduct for
whIch the gnevor was convIcted and the mIsconduct whIch was the
subject of the "sImIlar fact" eVIdence at the cnmmal tnal, on the baSIS
that dIsputmg those findmgs would be an "abuse of process", and
. If the answer on the first two Issues IS "no" WIth respect to the cnmmal
tnal Judge's findmgs of mIsconduct toward PatncIa MItchell and
Annette QUlbbel, whether those findmgs, whIch were not the subject of
8
convIctIOns, can or should be receIved as pnma fac~e eVIdence of that
mIscond uct
Evidence With Reference to the Preliminary Issues
[23] Employer counsel called Rolph Kluem, of the Durham RegIOnal PolIce, to
testIfy about the mvestIgatIOn he and another officer conducted m 1993 con-
cermng the allegatIOns that led to the cnmmal charges agamst the gnevor She
called Bnan Scott, an mvestIgator wIth the IID, to testIfy about the mvestIga
tIOns he conducted that led to the report on whIch the employer allegedly acted
m dIsmIssmg the gnevor As much of theIr eVIdence as IS necessary for determI
natIon of the Issues at hand has been recIted above m describmg the background
agamst whIch the prelImmary Issues arose
[24] Dmon counsel called the gnevor, whose testImony m chIef addressed hIS
motIvatIOn m pursumg thIS gnevance HIS gnevance seekmg remstatement and
compensatIOn had been filed before the cnmmal tnal started The gnevance and
arbItratIOn process was the only forum through whIch the gnevor understood he
could claim remstatement and compensatIOn. He stated that he had not aban
doned hIS claims to those remedIes and that he stIll WIshed to be remstated and
compensated. In cross-exammatIOn, he stated that he felt he should be rem
stated because he was not gmlty of any of the mIsconduct alleged m the dIs
mIssal letter He acknowledged, or at any rate dId not deny, that the allegatIOns
agamst hIm at cnmmal tnal had been as I have already descnbed, that he had
demed those allegatIOns and stIll demed them, and that he knew of no new eVI
dence WIth respect to them.
Issue Estoppel
[25] In an exchange of correspondence durmg the hearmg, umon counsel as
serted, WIth reference to the matter of Issue estoppel, that the employer " was
neIther a party nor a pnvy to the cnmmal proceedmg" Employer counsel replIed
9 -
that "[t]he Employer does not dIspute that It was not a party or prIVY to the
CrImmal proceedmgs" She also asserted that
The requrrements Issue estoppel [SlC] are
i) that the same questIOn has been decIded,
ri) that the Juchclal decIsIOn whIch IS smd to create Issue estoppel was final,
ill) That the partIes to the Juchclal decIsIon or therr pnVIeS were the same
persons as the partles to the proceeclmgs m whIch Issue estoppel IS raIsed
or therr pnVles
In response, umon counsel wrote
We note the Employer's agreement that the UnIOn had no status wIth respect
to and that the Employer was not a party or pnvy to the cnmmal
proceeclmg We also note that you have IdentIfied the requrrements Issue
estoppel (SIC)" to mclude ~nter aha, that "the partIes to the Juchclal decIsIOn
or the pnVles were the same persons as the partles to the proceechngs m
whIch Issue estoppel IS rmsed or theIr pnvles "
In lIght of thIS we will be requestmg at the outset of the hearmg on April 6
1998 that the Board chsmlss, wIthout hearmg any further eVIdence, the
Employer's request for a finclmg of Issue estoppel as between the cnmmal
and arbItratIOn proceeclmgs gIVen the acknowledged absence of IdentIcal
partles or pnVIes.
[26] At the outset of the hearmg on AprIl 6, 1998 (the second day of eVIdence
on the prelImmary Issues, before the umon had presented any eVIdence on the
prelImmary Issues) umon counsel dId ask that I rule that there was no Issue es
toppel, on the baSIS of the admIsSIOn that the employer was not a party or prIVY
to the crImmal proceedmgs and employer counsel's deSCrIptIOn of the reqUIre-
ments for Issue estoppel. Employer counsel dId not attempt to wIthdraw the ad
mISSIOn at that pomt. She explamed that she had mIsstated the reqUIrements of
Issue estoppel She saId she would be argumg that the applIcatIOn of Issue estop
pel dId not reqUIre that all of the parties or theIr prIVIeS be the same as the par
ties to the proceedmgs m whIch Issue estoppel IS raIsed or theIr prIVIeS but,
rather, that It was suffiCIent that one of the partIes or ItS prIVY be the same as
one of the partIes to the proceedmgs m whIch Issue estoppel IS raIsed or ItS prIVY
She submItted that the matter of Issue estoppel should not be deCIded before I
had heard that argument I agreed The sIgmficance of the admISSIOn was left to
- 10
be addressed m argument after the hearmg of eVIdence on the prelImmary IS
sues
[27] After the hearmg of eVIdence on the prelImmary Issues had been com-
pleted, durmg her closmg argument on those Issues, employer counsel contra
dIcted the earlIer admIssIon that the employer was not a party or pnvy to the
cnmmal proceedmgs She dId thIS wIthout seekmg leave to wIthdraw the admIs
SIOn or even expressly acknowledgmg that she was domg so She read from her
wntten submIssIOns that "Mr Samaroo and the Crown m RIght of Ontano were
partIes to hIS cnmmal conVIctIOns and of [SIC] the appeal of hIS cnmmal conVIC
tlons" and that "[t]he Dmon and the Crown m RIght of Ontano are partIes to"
thIS proceedmg Havmg noted that the Dmon was the agent of Mr Samaroo m
thIs proceedmg for purposes of advancmg hIS gnevance that there was no cause
for dIscharge, she argued that the CIrcumstances she had reCIted satIsfied the
thIrd of the reqUIrements for applIcatIOn of Issue estoppel IdentIfied by the Court
of Appeal m Rasanen u Rosemount Instrurnents Lwuted (1994), 17 0 R 267
[28] Counsel for the umon objected to counsel's assertmg m argument the con
trary of a fact that she had admItted durmg the eVIdentlary portIOn of the hear
mg He argued that the employer should be held to the earlIer admISSIOn. I
agree My agreement has nothmg to do WIth the fact that I made an order re
qUIrmg the delIvery of certam partlculars Indeed, the subject matter of the ad
mISSIOn arguably fell outSIde the scope of the matters that my order reqUIred the
partIes to partIculanze Nevertheless, emp loyer counsel clearly made and re
peated an admISSIOn of fact on a relevant pomt durmg the eVIdentlary portIOn of
the hearmg on these prelImmary Issues I have not been asked for and do not
grant leave to the employer to WIthdraw ItS admISSIOn. The clalm that Issue es
toppel applIes here must be assessed m lIght of that admISSIon.
[29] The doctrme of Issue estoppel In the law of Ontano was descnbed thIS
way by MIddleton J.A. m McIntosh u Parent (1924), 55 0 L R 552 (C.A.) at 555
Any nght, questIOn or fact chstmctly put m issue and drrectly determmed by
a court of competent JunschctIOn as a ground of recovery or as an answer to a
11-
claun set up cannot be re-tned ill a subsequent SUlt between the same partlRs
or theLr prwlRs though for a chfferent cause of actIOn. The nght questIOn, or
fact, once determmed, must, as between them be taken to be conclusIvely
estabhshed
(emphasIs added)
[30] In McIlkenny v Ch~ef Constable and the West Midlands et al, [1980] 1
Q B 283 (C A.), Lord Dennmg and SIr George Baker held that Issue estoppel
could apply so as to preclude a party from relItIgatmg m CIVIl proceedmgs an IS-
sue decIded agamst hIm as defendant m prevIOUS crImmal proceedmgs, even If
the OpposIte party m the CIVIl proceedmgs was not the prosecutor or a prIVY of
the prosecutor m the earlIer crImmal proceedmgs On appeal to the House of
Lords ([1982] A. C 529, sub nom Hunter v Chwf Constable of West Midlands
Pol~ce et al), however, Lord Dlplock observed (at pp 540-1) that m EnglIsh law
the deSCrIptIOn "Issue estoppel" should be applIed only to "that speCIes of estoppel
per rem Jud~catum that may arIse m CIVIl actIOns between the same partIes or
theIr prIVIeS" The test applIed by the Ontano Court of Appeal m Rasanen v
Rosemount Instruments L~m~ted, supra, followmg McIntosh v Parent, supra, re-
qUIred that the partIes to the proceedmgs m whIch estoppel IS to be applIed must
be the parties or prIVIeS of the partIes to the proceedmgs saId to have gIven rIse
to the estoppel
[31] In VIew of the employer's admISSIOn that It was neIther a party nor a pnvy
of a party to the cnmmal proceedmgs, ItS claim that the outcome of those pro-
ceedmgs gIves rIse to Issue estoppel m thIS one must fall I leave to a more SUIt
able occaSIOn consIderatIOn of the questIOn whether Issue estoppel on the baSIS of
findmgs m a crImmal proceedmg can or should apply m labour relatIOns matters
even If the gnevor was the accused and the employer was, or was the pnvy of,
the prosecutmg entity m the crImmal proceedmgs
Abuse of Process
[32] The Judgments m McIlhenny v Ch~ef Constable of West M~dlaTtds PolLce et
al, supra, and Hunter v Ch~ef Constable of West Midlands PolLce et al, supra,
12
dealt wIth CIVIl actIOns brought by the BIrmmgham SIX, who had been convIcted
m 1975 on 21 counts of murder ansmg out of the bombmg of two pubs They
were sumg the polIce for assault. The assaults alleged were the same assaults
they had alleged m theIr cnmmal tnal as the basIs for theIr claIm that confes
SIOns they had gIVen whIle m polIce custody were mvoluntary and therefore m
admIssible After a vo~r d~re, the tnal Judge m the cnmmal tnal had found that
the SIX had not been beaten whIle m polIce custody, and had ruled the confes
SIOns admIssible EVIdence of the confessIOns had then been put before the JUry,
as had the accuseds' eVIdence that the confessIOns had been beaten out of them
The tnal Judge mstructed the JUry that If they dId not accept that the confessIOns
were voluntary, It would not be safe to convIct them. The JUry convIcted them,
from whIch It appeared that the JUry had rejected theIr claIm that they had been
assaulted by the polIce
[33] The SIX mtended to mtroduce through theIr CIVIl tnals new eVIdence m
support of theIr claIm that the polIce had beaten them, apparently m the hope
that If they succeeded on that baSIS m the CIVIl proceedmgs thIS would pressure
the Home Secretary mto pardomng them or reopemng the cnmmal case The
polIce moved to have the actIOns dIsmIssed on the baSIS that the findmgs of the
Judge and Jury gave nse to an estoppel or, alternately, that the actIOns were an
abuse of the court's process The Court of Appeal granted the motIon on both
grounds The House of Lords sustamed the result solely on the ground of abuse
of process Lord DIplock observed (at p 451) that the plamtIffs' dommant pur
pose m pursumg the actIOns was not to recover the monetary remedy aVaIlable to
them m those actIOns, It was "to establIsh that the confessIOns on the eVIdence
on whIch they had been convIcted were mduced by polIce VIOlence WIth a VIew to
puttmg pressure on the Home Secretary to release them from the lIfe sentences "
He observed that
The abuse of process whIch the illstant case exemplIfies IS m the illItwtIOn of
proceedmgs m a court of JustIce for the purpose of mountmg a collateral
attack upon a final deCISIOn agamst the mtendmg plamtill whIch has been
made by another court of competent JUriSdIctIOn ill prevIOUS proceedmgs m
13
whIch the mtendmg plamtill had a full opportumty of contestmg the decIsIOn
m the court by whIch It was made.
[34] ThIs doctrme of abuse of process was applIed m Ontano m Demeter v
Bnt~sh Pac~fic L~fe Insurance Co et al (1983), 43 0 R. (2d) 33 (Osler, J), affd,
(1984), 48 O.R (2d) 266 (Ont C.A.) Peter Demeter had been convIcted of the
murder of hIS wIfe, Chnstme The convIctIOn had been confirmed by the Ontano
Court of Appeal and by the Supreme Court of Canada Mr Demeter contmued to
proclaIm hIs mnocence He brought CIVIl actIOns agamst three msurance compa
mes, to enforce polIcIes that provIded for payment to the survIvor of hIm and hIS
wIfe upon the death of the other In ItS defence, each msurer alleged that Mrs
Demeter had dIed as a result of the cnmmal conduct of Mr Demeter, and that
the polIcies were therefore unenforceable (because publIc polIcy precludes any
person from benefitmg from hIS or her own cnmmal act) They pleaded that be-
cause he had been conVIcted of the murder of hIS wIfe he was estopped from dIS
putmg hIS cnmmal responsibIlIty m the CIVIl actIOn and, m the alternative, that
It would be an abuse of process for hIm to do so
[36] Durmg a pre-tnal de bene esse exammatIOn he conducted, Mr Demeter
had stated that he was not there for the money, he was there to re-open hIS case,
to establish hIS mnocence After pleadmgs had been completed and examma
tIons for-dIscovery conducted, the msurers sought a determmatIOn of the effect
that mIght be gIVen to the conVIction m the tnal of Mr Demeter's actIOns and
whether those actIOns should be dIsmIssed as an abuse of court's process Mr
Demeter's counsel argued that the law m OntarIO was as stated m Hollmgton v
F Hewthorn & Co Ltd, [1943] 1 K.B 687 (C.A.) There, the plamtIff m a negli-
gence actIOn ansmg out of a motor vehIcle collISIOn asserted that the defendant
had been conVIcted of careless dnvmg m connectIOn WIth the collISIOn, and
sought to enter a certIficate of the defendant's convIctIOn as pnma faCIe eVIdence
of the defendant's neglIgence The EnglIsh Court of Appeal upheld the tnal
Judge's rulmg that the certIficate was madmIssIble for that purpose
14 -
[36] In Demeter, Mr JustIce Osler concluded (at 48) that HollLngton u Hew-
thome was not good law m Ontano On the questIOn of the eVIdentiary effect to
be gIven to the convIctIOn, he determmed that proof of It "may be receIved m eVI
dence and, If thIS IS done, should be regarded as pnma facLe proof of that Issue,
subject to rebuttal by the plamtIff on the ments" On the Issue of abuse of proc
ess, however, he found that the actIOns were an abuse of process m the sense de-
scnbed by LE)rd Dlplock m Hunter, and for that reason could not proceed
[37] The Court of Appeal upheld JustIce Osler's deCISIOn. 48 0 R (2d) 266 In
an oral Judgment that quoted m full the passage from the de bene esse examma
tIon m whIch Mr Demeter Said he was not there for the money but to re-open hIS
case and prove hIS mnocence, the Court saId (at 268) that
Weare equally of the VIew that the use of a CIvil actIOn to mItIate a collateral
attack on a final decIslOn of a cnmmal court of competent JunsillctIOn m an
attempt to relItIgate an Issue already tned, IS an abuse of the process of the
court. The alleged fresh eVIdence or eVIdence of fraud or collUSIOn falls far
short of supportmg an argument that an exceptIOn should be made to the
general rule of publIc polIcy
[38] One of two Issues before the Ontano Court of Appeal m Re Del Core and
Ontarw College of PharmacLsts (1985), 51 0 R (2d) 1, was whether the dIscIplme
commIttee of the respondent college had commItted revIewable error by accept
mg a certlficate of conVIctIOn as proof that the pharmaCIst named m It had com
mltted the offence for whIch he had been convIcted All three members of the
court found that It could Although m that case the pharmaCIst had not pre-
sented a rebuttal, all three members of the court addressed the questIOn whether
he could have done so
[39] Mr Justlce Fmdlayson saId that the pharmaCIst could have called "evI
dence m mItlgatIOn or by way of excuse for the offence," but that by mSlstmg that
the tnbunal be satlsfied by mdependent eVIdence that the offence dId take place
the pharmaCIst was Imtlatmg a collateral attack on a final deCISIOn of competent
JunsdIctIOn. ThIS seems to suggest that somethmg lIke the abuse of process doc
trme would have applIed so as to prevent the pharmaCIst from attemptmg to
15 -
persuade the dlscIplme commIttee that he had not commItted the offence wIth
whIch he had been convIcted
[40] Mr Justice Houlden dIsagreed He revIewed a number of authontIes
whIch, he concluded, supported Mr JustIce Osler's conclUSIOn m Demeter, supra,
that a certIficate of convIctIOn was pnma facLe but not conclUSIve eVIdence of the
commISSIOn of the offence He then observed (at p 18ff) that the abuse of process
doctrme does not apply to every SItuatIOn m whIch a party to CIVIl proceedmgs
takes a pOSItion contrary to the outcome of earher cnmmal proceedmgs agamst
hIm.
The remammg Issue IS whether the defendant should have been
prohibIted from mSlstmg m hIS defence on havmg the substance of hIS
conduct retned because thIS would be an abuse of process defined m the
Demeter case As It was m thIs case the defendant who was seekmg to contest
a convlctlOn whIch was tendered by the party who was m effect, the plamtllf
m the proceedmgs the doctrme of abuse of process m the Demeter case has no
apphcatlOn.
The doctrme of abuse of process enunciated m Demeter was formulated by
the House of Lords m Hunter u Clnef Constable West lYhdlands Pol~ce et al.
(1982] A.C 529 The doctrme apphes accordmg to Lord Dlplock, where a
plamtllf mltIates CIVIl proceedmgs, WIthout any real mterest m the outcome
m an attempt to challenge a pnor convlctlOn. That the rule apphes only
where the plamt~ffhas been convIcted and IS mltlatmg the ClVll proceedmgs
IS made clear by Lord Dlplock at p 541
The abuse of process whIch the mstant case exemplifies IS the mltwtlOn
of proceedmgs m a court of JustIce for the purpose of mountmg a
collateral attack upon a final declslOn agamst the Lntendmg plamtLff
whIch has been made by another court of competent JunsdlctlOn ill
prevlOus proceechngs m whIch the mtendmg plamtLff had a full
opportulllty of contestmg the declslOn m the court by whIch It was made
(EmphaSIS added.)
The eXIstence of an ultenor motlVe for brmgmg the proceedmgs IS
unportant ill the abuse of process cases As Lord Dlplock stated m Hunter at
p 54 1
the dommant purpose of thIS actlOn has not been to recover damages
but IS brought m an endeavour to estabhsh that the confesslOns on the
eVIdence on whIch they were convIcted were mduced by pohce vlOlence
WIth a VIew to puttillg pressure on the Home Secretary to release them
from the lIfe sentences
The motlVes of lYlr Demeter were apparently unportant to the Court of
Appeal m Demeter because MacKmnon A.C J 0 quoted, ill an otherwIse very
short Judgment, an excerpt from a de bene esse exammatlOn m whIch the
appellant said. "I am not here for the money I am here to reopen my case"
16 -
The abuse of process doctrme does not apply m thIS case because .Mr Del
Core IS not the notIOnal plamtllf who mItlated the proceedmg he IS the
defendant. Further he IS very mterested m the decIsIOn that the cIvIl court
comes to potentIally a chscIplmary suspensIOn whIch, as the Supreme Court
of Canada has noted, can have grave and permanent consequences upon a
professIOnal career
WIth respect, I cannot agree wIth Fmlayson J.A. that by mSIstmg m hIS
defence on havmg the substance of hIS mIsconduct retned, the respondent IS
mItIatmg a collateral attack on a fmal decISIOn of a crunmal court of
competent JunschctIOn. If that proposItIOn IS correct, the Demeter case has
brought about an astoundmg amalgamatIOn of crunmal and cIvIl law whIch
has heretofore been unknown m Canachan law
[41] Mr JustIce BlaIr agreed wIth Houlden, J.A. that the certIficate of conVIC
tIon was pnma facLe but not conclusIve eVIdence mother proceedmgs of the
commISSIOn of the CrIme, and added (at p 22) that
Smce eVIdence of pnor convIctIOns affords only pnma facw proof of guIlt
It follows that ItS effect may be countered ill a vanety of ways. For example
the convIctIOn may be challenged or ItS effect mItIgated by explanatIOn of the
CIrcumstances surroundmg the convIctIOn. It IS both unnecessary and
unprudent to attempt any exhaustIve enumeratIOn. The law of Ontano IS
only now emergmg from the long shadow cast over It by the decIsIOn m
Holhngton v Hewthorn, supra. It would be hIghly undesIrable to replace thIS
arbItrary rule by prescnbmg equally ngId rules to replace It. The law should
remam fleXIble to permIt ItS apphcatIOn to the varvillg CIrcumstances of
partIcular cases
As for the doctrIne of abuse of process, Mr Justice BlaIr noted that thIS IS a
qualIficatIOn to the general rule that a conVIction IS only pnma facLe proof of
gUilt m subsequent proceedmgs and subject to rebuttal.
The nght to challenge a conVIction IS subject to an unportant
qualliicatIOn. A convIcted person cannot attempt to prove that the conVIctIOn
was wrong ill CIrcumstances where It would constItute an abuse of process to
do so Demeter supra, and Hunter v ChlRf Constable of West L1-hdlands
PolLce, [1982] AC 529 Courts have rejected attempts to rehtIgate the very
Issues dealt WIth at a crunmal tnal where the CIVIl proceedillgs were
perceIVed to be a collateral attack on the cnmmal conVIctIOn. The ambIt of
thIS qualliicatIOn remams to be determilled ill future cases
Some confUSIOn appears to have ansen between the rule that eVIdence of
pnor conVIctIOns IS admISSIble and the doctrme of abuse of process ThIS
appears from the passage quoted above from the McArthur case and ill other
mcta. It was argued that such eVIdence could only be admItted where It
would be an abuse of process to challenge the conVIctIOn. ThIS IS not so The
admISSIbIlIty of such eVIdence IS not dependent on a determmatIOn that It
would be an abuse of process to attack the conVIctIOn As I have explamed
above eVIdence of pnor conVIctIOns IS admISSIble ill all cases where It IS
17
relevant. The abuse of process doctnne can only be mvoked, m partIcular
cases to prohIbIt rebuttal of such eVIdence
[42] If the abuse of process doctrme dIctated that no one convIcted of a CrIme
could seek to counter the eVIdentiary effect of a certIficate of that convIctIOn m
subsequent CIVIl proceedmgs, then the abuse of process exceptIOn would swallow
up the rule that the conVIctIOn IS pnma facLe but not conclUSIve eVIdence of gUIlt.
That IS clearly not what the maJorIty m Del Core had m mmd In Hutchmgs v
Nevm (1992), 9 0 R. (3d) 776, Mr Justice Hames summed up the doctrme m a
sentence (at 783)
The doctrme of abuse of process as set out m Demeter and referred to m Del
Core apphes where a plamtili has mItIated CIVIl proceedmgs WIthout any
apparent mterest m the outcome WIth the mtentIOn of challengmg a pnor
conVIctIOn.
As descrIbed by the maJorIty m Del Core, the doctrme does not apply to a party,
whether defendant or plamtIff, who has a real mterest m the outcome of the CIVIl
proceedmgs m whIch he or she seeks to rebut the eVIdentIary effect of a pnor
convIctIOn. Taylor v Banbeau (1985), 51 0 R. (2d) 541 (Ont DIV Ct), RLdley v
Blanchard Mutual Insurance Company, [1995] I L R. ~1 3209 (Ont. Ct, Gen.
DIV)
[43] I do not find It necessary to assess whether, as the umon argues, the pOSI
tIOn of a gnevor m a dIscharge case IS more akm to that of a defendant m CIVIl
court proceedmgs than to that of a plamtIff. The grIevor clearly has a real mter
est m remstatement and compensatIOn, the remedIes sought m these proceed
mgs The grIevor attacks the convIctIOns only m answer to the employer's claIm
that they prove he has done somethmg that Justified ItS termmatIOn of hIS em
ployment It does not appear to me that the grIevor IS usmg these proceedmgs to
mount a collateral attack on the earlIer crImmal proceedmgs of the sort that
would attract applIcatIOn of the abuse of process doctrme m the CIVIl courts
[44] The employer argues that It IS an abuse of process for the gnevor to seek
to prove that he dId not commIt the CrImes of WhICh he was convIcted If he has no
fresh eVIdence or eVIdence of fraud or collusIOn to offer ThIS appears to confuse
18 -
the abuse of process Issue WIth another Issue that may well anse m thIS case but
IS not yet properly before me for determmatIOn.
[45] The remarks of ASSOCiate ChIef JustIce MacK.Innon m Demeter (quoted
above at paragraph [37]) mdlcate that CIVIl proceedmgs mltIated wIthout any
apparent mterest m the outcome, wIth the mtentIOn of challengmg a pnor con
vlctIOn, may not amount to an abuse of the process of the CIVIl court If the plam
tIff offers fresh eVIdence or eVIdence of fraud or collusIOn that meets a certam
standard In other words, proceedmgs that would otherwIse be an abuse of proc
ess may not be so If the plamtlff offers such eVIdence It does not follow that the
fallure to offer that kmd of fresh eVIdence or eVIdence of fraud or collusIOn trans
forms proceedmgs mto an abuse of process If they would not otherWIse be so,
havmg regard to the convIcted person's motIvatIOn m those proceedmgs I have
found that the gnevor's motIvatIOn m challengmg the convIctIOn does not brmg
thIS matter wlthm the ambIt of the abuse of process doctrme In those CIrcum
stances, the apparent absence of fresh eVIdence or eVIdence of fraud or collusIOn
does not make these proceedmgs an abuse of process
[46] In Wlnte, the DIVIsIOnal Court dIrected that the Board receIVe a certIficate
of conVIctIOn as pnma facLe eVIdence that the gnevor had commItted the cnme of
whIch he had been convIcted The Court dId not say what standard rebuttal eVI
dence would have to meet m order to outweIgh the pnma facLe effect that publIc
polIcy reqUIred that the Board gIVe to the certIficate If a gnevor attempts to re-
but a certIficate of conVIctIOn by presentmg the same eVIdence that the cnmmal
court reJected m convlctmg hIm, and nothmg more, would treatmg that eVIdence
as havmg shIfted the burden of persuaSIOn back to the employer amount to domg
what the DIVISIOnal Court has saId the Board could not do - Ignore a relevant
determmatIOn made m a cnmmal tnal? That questIOn WIll have to be answered
m thIS case If, mdeed, thIS gnevor has no eVIdence to offer m rebuttal that the
cnmmal court dId not hear It IS not one of the prelImmary Issues I undertook to
address m thIS phase of the proceedmgs, however
19
[47] Employer counsel also argued that the submIssIOns on sentence quoted at
paragraph [13] above amounted to a submIssIOn that the grIevor's sentence
"should be mItIgated due to hIS Job loss," and that It was an abuse of process and
contemptuous for the grIevor to seek remstatement m these proceedmgs after
havmg made that submIssIOn to Judge Dodds The grIevor's counsel at the
crImmal trIal told Judge Dodds that the grIevor was trymg to get hIS Job back
through the.grIevance procedure In the remarks that followed, counsel appears
to mVIted the Judge to assume that hIS attempts would be unsuccessful It would
be premature for me to assess the accuracy of that predIctIOn. It IS for the CrImI
nal court, not thIS Board, to determme whether the grIevor's havmg contmued to
try to get hIS Job back through the grIevance arbItratIOn process amounts to con
tempt of that court. In any event, It does not appear to me that there was any
contempt The court was not mIsled about the grIevor's mtentIOn to pursue the
claim now before me There was no undertakmg that the grIevor would abandon
hIS claim for remstatement The sentence Imposed dId not reqUlre that he aban
don It The submIssIOns hIS counsel made to the crImmal court WIth respect to
sentence do not make the grIevor's seekmg remstatement an abuse of thIS
Board's process
The Evidentiary Status of the Findings of Judge Dodds Concerning the
Alleged Assaults on Patricia Mitchell and Annette Quibbel
[48] The last of the prelImmary Issues IdentIfied m paragraph [22] above IS
whether the crImmal trIal Judge's findmgs of mIsconduct toward PatrICIa
MItchell and Annette QUlbbel, mIsconduct whIch was not the subject of any con
vIctIOn, can or should be receIVed as pnma facLe eVIdence of that mIsconduct m
these p roceedmgs
[49] Taylor v Banbeau, supra, was a CIVIl actIOn arIsmg out of a collISIOn be
tween automobIles drIven by Band J A passenger m J's vehIcle dIed m the COllI
SIOn. The passenger's estate sued Band J B was convIcted of dangerous drIvmg
on the occaSIOn of the collISIOn. In hIS reasons for Judgment, the crImmal trIal
Judge found B solely responsIble for the aCCIdent. One of the Issues raised m the
20
CIVIl proceedmgs thereafter was whether that and other findmgs of fact by the
cnmmal tnal Judge would constitute pnma facLe eVIdence of theIr truth as
agamst B The DIvIslOnal Court noted that will.le dangerous dnvmg "WIll trans
late mto CIVIl neglIgence," the Issues m the two proceedmgs were not IdentIcal
because there were Issues of contributory neglIgence and causatlOn m the CIVIl
actIOn. It observed (at 51 0 R. (2d) 545-6) that "[e]ven though Judge Zalev may
have felt that Issues of causatlOn and contributory neglIgence had some bearmg
on the Issues m the cnmmal proceedmg, he was not reqwred to deCIde them."
Agamst that background, It held that although a certIficate of the convIctlOn was
pnma facLe proof, the reasons for conVIctIOn or findmgs of fact m support of the
convIctlOn were not admISSIble m eVIdence m the CIVIl proceedmgs
[50] A findmg that the gnevor assaulted PatncIa MItchell or Annette Qmbbel
or both was not a logIcal or legal prereqmsIte to findmg hIm gmlty of the offences
of WhICh he was convIcted The findmgs that the cnmmal tnal Judge dId make m
that regard were not reqwred m that sense They do not have the same eVIden
tIary sIgmficance as the Judge's findmgs that the gnevor was gmlty of the cnmes
for whIch he was convmced In the absence of the clearest authOrity, I am not
persuaded that I am oblIged to treat the cnmmal tnal Judge's findmgs that the
gnevor assaulted PatncIa MItchell and Annette Qmbbel as pruna facLe eVIdence
m these proceedmgs that he dId so
Restrictions on Remedy
[51] When argument of the prelImmary Issues Identified m paragraph [22] be-
gan, employer counsel asked me to determme a further Issue m a prelImmary
way She asked me to rule m advance that If I accepted as fact the conVIctIOns
and SImIlar fact findmgs of the cnmmal court, then the pOSSIble outcomes m thIS
proceedmg would be lImIted to upholdmg the gnevor's termmatIOn or awardmg
hIm a sum of money m lIeu of remstatement
[52] If I ultimately find that the gnevor "applIed force" to an mmate "except
the mmImum force necessary for self-defence or the defence of another person" or
21
that he "sexually molested" an mmate, then even If I conclude that hIS mlscon
duct was msufficlent cause for discharge, subsectIOn 7 (4) of the Crown Employees
Collectwe Bargammg Act, 1993, S 0 1993, c.38 ("CECBA") provides that I am
without power to order that he be remstated to a posItion that mvolves "direct
responsibilIty for or that provides an opportumty for contact with" mmates Sub
sectIOn 7(6) of CECBA prOVIdes, however, that I could m those Circumstances or
der that he be returned to employment m another "substantially eqUIvalent pOSI
tIon." What counsel for the employer was seekmg, then, was an advance deter
mmatIOn that I would not exerCise that power m the gnevor's favour
[53] In support of tills submIssIon, assertIOns were made about the gnevor's
qualIficatIOns and the unavailabIlity of "substantially eqUIvalent posItIOns"
There was no eVidentiary support for those assertIOns, as employer counsel con
ceded Further, and more fundamental, the submissIOns were Simply out of or
der ThIs was not an Issue I undertook to determme on a prelImmary baSIS, and
was premature I declme to deal WIth It at thIS stage
Summary
[54] The umon has conceded that the three conVictIOns registered agamst the
gnevor can be receIVed as pnma fane eVIdence that he had committed the mIS
conduct for whIch he was conVicted the sexual assaults on Lisa Watson and
Tracy Armstrong and the common assault on Susan Mame The same does not
apply to Judge Dobbs' findmgs that the gnevor assaulted PatncIa MItchell and
Annette QUlbbel, which assaults were not the subject of conVictIOns The gnevor
IS not precluded by doctnnes of Issue estoppel or abuse of process from attempt
mg to rebut the facts of which the conVIctIOns WIll be treated as pnma facLe eVI
dence
[55] QuestIOns about the nature of the eVIdence necessary to rebut the facts of
whIch the conVIctIOns Will be treated as pnma facLe eVIdence, and particularly
whether the burden of persuaSIOn would be shifted to the employer If the gnevor
were to present the eVidence that the cnmmal court rejected m convlctmg him
22
and nothmg more, are not properly before me at thIS prelImmary stage Nor are
questIOns about the remedy that mIght be granted If I am ultImately persuaded
that dIsmIssal was an exceSSIVe reactIOn to any mIsconduct of whIch the gnevor
IS found gUIlty m these proceedmgs Such questIOns may be raIsed at a more ap
propnate stage of the proceedmgs
IS 1J~
Dated at TOl'onto thIs JAth day of September, 1998