HomeMy WebLinkAbout1994-0809.LAHAY.95_08_15
ONTARIO EMPLOYES DE LA COURONNE
CROWN EMPLOYEES DE L'ONTARIO V-
illi GRIEVANCE COMMISSION DE ~\6 <-- I V-
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SETTLEMENT REGLEMENT \) , , (t '" ,
BOARD DES GRIEFS ~ L'(\ t/
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180 DUNDAS STREET WEST SUITE 2700, TORONTO, ONTARIO M5G lZ8 TELEPHONEITEU!PHONE (416) 326-1388
780 RUE DUNDAS OUES~_B_U.REAU 2700 TORONTO (ONTARIO) M5G 7Z8 FACSIMILE ITELECOPIE (476) 326-7396
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, GSB # 809/94
OPSEU # OLB148/94
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-- IN THE MATTER OF AN ARBITRATION
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.-.-..- :: - ~-~ --------- Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OLBEU (LaHay)
Grievor
- and -
The Crown in Right of Ontario
(Liquor Control Board of Ontario)
Employer
BEFORE M Gorsky Vice-Chairperson
FOR THE E Mitchell
GRIEVOR Counsel
Koskie & Minsky
Barristers & Solicitors
FOR THE R Drmaj
EMPLOYER Counsel
Hicks, Morley, Hamilton, Stewart, storie
Barristers & Soliciitors
HEARING June 5, 1995
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D E CIS ION
Ms Mitchell, counsel for the Union, made the following
statements at the opening of the hearing with respect to the
facts said to be material to her application for a declaration
that the discharge of the Grievor was void ab initio
1 On June 13, 1994, Gordon Holmes, the Store Manager at the
store where the Grievor worked in Orillia (Store #175), handed
the Grievor a letter dated June 10, 1994, from Bob Porter,
District Manager #15 of the Employer's Western Region (Exhibit
4)
Dear Mr Lahay [sic]
RE NOTICE OF INTENDED DISCIPLINE
On receipt of this letter June 13, 1994 you are hereby
relieved form duty with pay This action results from
a security investigation in which you were observed
using improper cashiering procedures on May 4, 1994
This is not a disciplinary response but as a result of
these events disciplinary action may be taken against
you
Within three (3) calendar days from receipt of this
letter, you are asked to submlt a written statement by
registered mail to my attention, explainlng the matter
mentioned above
Should a meeting be scheduled following the receipt of
your written statement, you are entitled to Union
Representation, as discipllne may result
If you choose not to respond, Management will act on
currently available information
A decision concerning this matter will be made known to
you in due course
(Emphasis in original)
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2 On June 14, 1994 Mr LaHay sent Mr Porter his written reply
(Exhlbit 5) to Exhibit 4
3 On June 23, 1994, Ron Fisher, Regional Director, Western
Region of the Employer sent Mr LaHay a letter dated the same day
(Exhibit 6) by Priority Post, notifying him that his employment
wlth the Llquor Control Board of Ontario was "terminated for
cause, namely, improper cashiering procedures, effective this
date, June 23, 1994 "
4 On June 20, 1994, Mr LaHay filed a grievance (Exhibit 2),
which it was acknowledged related to his recelpt of the Notice of
Intended Dlscipline (Exhiblt 4) in which he grleved
Statement of Grievance (Clauses violated)
Article 2 1 and 2 7 of OLBEU agreement and article 43 1
of Labour Relations Act also all of the artlcles of
OLBEU, CECBA or Labour Relatlons Act pertalning to this
grievance
5 The settlement desired was
To receive all wages, beneflts and seniority lost
To be made in hole [sic]
6 On June 28, 1994, Mr LaHay filed a further grievance
(Exhlbit 3), which it was agreed related to his being dlscharged
on June 23, 1994 This grievance, in its statement of grievance
and relief requested was identical to Exhibit 2
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7 On August 8, 1994, Mr Fisher sent a letter (Exhlbit 8 ) to
Mr LaHay in connection with his suspension grlevance (Exhibit 2)
indicating that the parties had agreed that a third stage meeting
would not be held and that his grievance would lIadvance to the
Grievance Settlement Board II At the hearing it was agreed that
the discharge grievance was also to go directly to the Grievance
Settlement Board without the need to follow the other steps of
the grievance procedure
8 Ms Mltchell wrote a letter dated August 25, 1995 (Exhiblt
7) to Mr Drma j , counsel for the Employer liRe Discharge
grievance of David LaHay GSB #809-9411, in which she states
We hereby notify you that, in addition to the Articles
grieved in the grievance dated June 20, 1994, the Unlon
also grieves that the employer has vlolated Article
26 3 of the Collective Agreement In particular, the
Union also grieves that the employer did not offer the
grievor union representation in advance of the meetlng
of June 13, 1994, at which time the grievor was
suspended The Union shall raise a preliminary
objection at the hearing of June 5th, 1995, that the
discipline is void ab initio
It is eVldent that Ms Mitchell was referring to both
grlevances although the only one submitted to arbitration was the
discharge grievance
9 Art 26 3, referred to in Ms Mitchell's letter is as
follows
An employee who is required to attend a meeting for the
purpose of discussing a matter which may result In
disciplinary action being taken against the employee
shall be made aware of the purpose of the meetlng and
hls/her right to Union representation In advance of the
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meeting The employee shall be entitled to have a
Unlon representative at such meeting provided thls does
not result in undue delay
10 By letter dated August 2, 1994, Jean Chaykowsky, Grievance
Officer for the Union, wrote to the Grievance Settlement Board
requesting a "hearing by the Crown Employees' Grievance
Settlement Board in accordance with art 27 6 of the collective
agreement, " with respect to the discharge grievance that is
before me
11 As has been noted above, at the opening of the hearing, Ms
Mltchell, raised the preliminary objection referred to in Exhiblt
7, based on Mr LaHay not having been made aware of the purpose
of the June 13th meeting and of his right to Union representation
as requlred by art 26 3
12 Mr LaHay had been employed by the Employer for
approximately 10 years, first as a casual employee in the
capacity of a store clerk between 1984 and 1989, in which latter
year he became a full-time employee
13 It was noted that, if necessary, evidence would be called
with respect to Mr LaHay's havin9 been disclplined while a
casual employee without this fact having affected his being hired
as a full-time employee I was advised that the previous
discipline also related to improper cashlering procedures and
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that this did not affect Mr LaHay's being hired as a full-time
employee
14 Ms Mltchell indicated that, if necessary, evidence would be
called that the Grlevor, on June 13, 1994, was working at his job
as a store clerk when he was called into the Store Manager's
office (Gordon Holmes) at approximately 11 30 a m Mr Holmes
was said to have informed Mr LaHay that he was to attend with
him at his office after closing his cash
15 After the Grievor closed his cash, he and Mr Holmes
proceeded into the latter's office followed by three other
persons, two of whom were LCBO inspectors Martha Dugas and David
Hadlow, the third person being Police Sergeant Crockford, who was
attached to the Orillia Police Department
16 After all of the persons In the room were seated, Mr Holmes
handed Mr LaHay the letter of June 10, 1994 (Exhibit 4) It was
Ms Mitchell's position that the meeting of June 10, 1994
represented the beginning of the process leading to the
disciplinary response that culminated in Mr LaHay being
termlnated
17 Mr Holmes gave Exhibit 4 to Mr LaHay at the beginning of
the meeting and then asked him what he was doing on May 4th The
Grievor was supposed to have replied that he dld not know what he
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was doing then and inquired as to whether he was, in fact,
working on that day
18 Mr Holmes then informed the Grievor that he had been
observed on May 4, 1994 while engaged in improper cashiering
procedures in the form of taking cash from the cash drawer, and
he was asked if he had any explanation for his actions
19 The Crievor is supposed to have replied "I don't know -
maybe I was making change for myself "
20 Sergeant Crockford is then supposed to have said "Is that
your statement n
21 The Grievor is supposed to have responded "I ill not making a
statement "
22 Sergeant Crockford then informed Mr LaHay that he was being
charged with theft under $1000 00 and placed him under arrest and
read him hlS rights
23 Mr Holmes then closed out the Grievor's cash drawer,
following which Sergeant Crockford asked the Grlevor if he was
prepared to co-operate, in which case he would not be placed in
handcuffs The Grievor indicated that he would co-operate and
left the store with the officer for the police station where he
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was fingerprinted Later that day, Mr LaHay came back to store
#175 and voluntarily turned ln his keys
24 Prior to the meeting of June 13th, an investigatlon of the
Grlevor had been conducted by the Employer at store #175 and he
was secretly observed and his actions videotaped by an LeBO
investigation team The videotapes were reviewed toward the end
of Mayor early in June of 1994, and the police were contacted
before the meeting above referred to
25 Mr LaHay consulted with a lawyer on June 14, 1994, prior to
preparlng his response to Exhibit 4 Although Exhibit 4 is dated
June 10, 1994, it was handed to the Grievor by Mr Holmes on June
13, 1994 in the manner above recorded
26 After the Grievor met with Union representatives, Exhibit 2
was filed on June 20, 1994
27 There were no other meetings held by the parties prior to
the Grievor belng discharged on June 23rd or thereafter to the
date of the hearing on June 5, 1995
28 The criminal charges laid were dismissed on a prelimlnary
motion
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29 The position of the Dnlon was that the discharge of the
Grievor was void ab lnitio because the language of art 26 3 of
the collective agreement was said to give the Grievor a
substantive right, and that failure on the part of the Employer
to adhere to the requirements of that article vOlded the
imposition of discipline
30 Accordingly, it was submitted that I had no jurisdictlon to
hear the matter on the merits, and that I should declare the
discharge to be void ab initio, and that I did have jurisdiction
which respect to the assessment of amounts owing to the Grievor
and other relief
Mr Drmaj , counsel for the Employer, made the following
staements with respect to the facts stated by Ms Mitchell ln
support of her application
1 The Employer accepted most of the facts set out by Ms
Mitchell However, there were certain of them which it did not
fully accept
2 Mr Porter, the District Manager #15 responslble for store
#175 in Orlllia, had had discussions with LeBO security
personnel, as a result of which it was declded to conduct an
investigation of the Grievor's conduct as a cashier through the
use of vldeo recording and surveillance techniques Based on the
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initiatives taken, the Employer's representatives concluded that
Mr LaHay had been "implicated in a breach of cashiering
procedures established by the employer " His actions were
regarded as representing a "disciplinable event," as well as
amounting to possible criminal activity in the nature of theft
3 Mr Porter had been informed about what had been observed
and what was recorded on videotape concerning the "cashiering
problems" and was also informed that the LCBO securlty personnel
wished to proceed with the matter to see if criminal charges
"could or should be laid"
4 A meeting was scheduled with representatlves of the Orillla
Police Department, and until the meeting was held the issue of
dlscipline was "put in abeyance "
5 On or about June 10, 1994 the investigators went to see
Sergeant Crockford of the Orillia Police Department who was in
charge of the investigation of possible criminal actlvit}
6 Mr Porter was then informed by the Employer's securlty
personnel that there was sufficient evidence to lay crlminal
charges
7 It was Mr Porter's responsibility to be present at meetings
lnvolving dlscussions related to the laying of criminal charges
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8 He was unable to attend the meeting of June 13 because of
family problems and it was indicated that he would testify, if
that became necessary, that that is the reason why the letter
dated June 10th (Exhibit 4) was given to the Grievor on June 13
by Mr Holmes
9 On June 10, 1994, Mr Porter instructed Mr Holmes that he
was to attend a meeting on June 13th with the LCBO investigators
at the Orillia police station in order to view the videotape, at
whlch time a determination would be made as to whether criminal
charges would be laid
10 Mr Porter was also said to have advised Mr Holmes to pick
up a letter in Mr Porter's office in Barrie, being the Notice of
Intended Dlscipline (Exhibit 4)
11 Mr Holmes was said to have picked up the letter early in
the mornlng of June 13 and then to have met with the LCBO
lnvestigators at the police station in Orillia along with
Sergeant Crockford where they reviewed the videotape and other
detalls of the investlgation It was at that time that Sergeant
Crockford is supposed to have informed Mr Holmes and the
investigators that in his view there was sufficient evidence to
lay crimlnal charges against Mr LaHay A discussion then took
place relating to the way that the investigators, Mr Holmes and
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Sergeant Crockford would return to the store and confront and
arrest Mr Lahay
12 When Mr Holmes returned to the store along with the
investigators and Sergeant Crockford, he asked another employee
to replace Mr LaHay and instructed the Grievor to come to his
office
13 Mr Drma j did not agree with Ms Mitchell's recitation of
the order of events at the meeting of June 13th In partlcular,
he dld not agree that the arrest took place only after the Notice
of Intended Discipline was given to Mr LaHay It was the
position of the Employer that the Grievor was told who the other
persons at the meeting were immediately upon their entering the
room and the purpose of their being present, including the
handlng to Mr LaHay of the Notice of Intended Discipllne
(Exhlbit 4) It was suggested by Mr Drma j that the Grievor was
escorted to the station where he was then placed under arrest and
charged
14 Mr Drmaj stated that evidence would be called, If
necessary, that prlor to the meeting of June 13th Mr Porter,
who had a good relationship with the Zone Representative of the
Union, Keith O'Toole, advised Mr O'Toole that an investigatlon
was taklng place and that some actlon would be taken Mr Drmaj
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dld not indicate that Mr O'Toole was told what the action was
about or that it related to the Grievor
15 After Mr Porter returned to his office In Barrie on June
13, 1994, he telephoned Mr Holmes and was told that the Grievor
had been arrested by Sgt Crockford and that Mr Holmes had given
the Grievor Mr Porter's Notice of Intended Discipline (Exhlbit
4)
16 Mr Porter then informed Mr O'Toole what had taken place
17 Evidence would be called, if necessary, that Mr O'Toole
never raised any issue about his not being present at the meetlng
of June 13th, nor did he ask for a further meeting or for
"anything else "
18 The procedure followed by the Employer when discipline may
be lmposed is to issue a Notice of Intended Discipline, which
asks the employee to whom it is given to furnish an explanatlon
for his behaviour within three days
19 After receiving the employee's response, or if none lS
forthcomlng, the Employer then issues discipllne, If warranted
During the period of the operation of the Notice of Intended
Discipline, the employee continues to be paid
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20 After the Grlevor flled his grievance (Exhlbit 2) , the
letter of dlscharge (Exhibit 6) was issued by Mr Fisher, and
that was the only discipline assessed in relation to the incident
before me
In response to Mr Drmaj's recitation of the Employer's Vlew
of the facts, Ms Mitchell stated
1 As a zone representative of the Union, Mr O'Toole was
responsible for filing grievances in the field and conducting
second stage grievance meetings Third stage grievance meetings
are conducted at the "next layer," which was identified as a duly
authorized representative of the Union, as deflned ln s 27 l(a)
of the provisions with respect to the grievance procedure
contained in the collective agreement
2 In this case, subsequent to the June 13th meeting, there
were no further meetings of any kind between the parties with
respect to this matter where the Union might have informed the
Employer of its posltion or amended the grievance
3 There were no pre-hearing meetings held, as it was agreed
that there was no point in doing so in dlsmlssal cases and there
were no meetings where the Union had an opportunity to elaborate
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on or amend the grievance
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4 The Union has no knowledge of any dlscussions between Mr
O'Toole and Mr Porter, and, in any event, It was the Union's
position that any dlscussions between them dld not meet the
requirements of art 26 3
5 Ms Mitchell did not disagree with the order of the June
13th meeting as it was described by Mr Drmaj Her position was
that whichever order is accepted the Employer chose to conduct a
meeting where there was a discussion of a matter which might
result in disciplinary action being taken against the Grievor,
whlch meeting "triggers" art 26 3
6 Where a meeting such as the one that was conducted on June
13th takes place, it was normal for the Employer to notify the
Union and to offer Union representation to the employee involved
Submissions Made by Way of Argument on Behalf of the Union.
1 Article 26 3 grants a "substantive" rlght to employees and
is not merely procedural
2 The language of art 26 3 makes clear that the nature of the
protection afforded to an employee is mandatory in nature, and
that the Employer had a mandatory obligatlon to advise the
Grievor of hls right to Union representatlon
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3 The Grievor was ordered by Mr Holmes to attend a meetlng
with respect to "discussing a matter which [might] result ln
disciplinary action being taken against [him] " even if Mr
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Holmes did not fully articulate the full purpose of the meeting
4 The Grievor was given a Notice of Intended Dlscipllne and
charged with a criminal offence and arrested
5 The Employer could have separated the criminal matter from
the employment offense, but both of them were intermingled at the
meeting
6 It was clear that the Employer was, at some point proximate
to the meeting, going to discipline the Grievor in the light of
the lntention to lay criminal charges, even if he was not
informed that this was going to happen It was emphasized that
art 26 3 did not use the words "shall result in disciplinary
action" but instead used the words "may result in disciplinary
action " From the manner in which the meeting was conducted it
was clear that both criminal and disciplinary action might be
taken as a result of the meeting
7 Mr Porter was also aware of the investigators' opinion that
criminal charges should be laid against the Grievor
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8 It was "inconceivable" that the meeting of June 13th was
other than a meeting that might result In disciplinary action
being taken against the Grievor, with the Employer treating the
incldent as representing a "very serious offense tI Accordingly,
the Employer had an obligation to make Mr LaHay aware of the
purpose of the meeting and of his right to Union representation,
in advance of the meeting
9 There was no impediment to the Employer informing the
Grievor prior to the June 13th meeting that there was going to be
a meeting on that date to discuss an investigation with respect
to his conduct on May 4, 1994 and of his right to Union
representation at the meeting
10 The nature of the conversation between Mr Holmes and the
Grievor, when the Grievor was asked to come to a meeting, dld not
convey to the Grlevor any information that might cause him to
request Unlon representation
11 There was no suggestion that the provision of Dnlon
representatlon would "result in undue delay "
12 The language of art 26 3 was said to be "broad" so that any
meetlng relating to an lnvestigation of a matter lnvolving
improper cashiering activities fell withln its purvlew
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13 Where a provision is substantive and the language mandatory,
failure to adhere to its provision "voids the disclpllne "
14 Reference was made to the case of Hickeson-Langs Supply Co.
(1985) , 19 LAC (3d) 379 (Burkett) , where the majority of the
board stated (at p 392)
Although the meeting conducted between the company
and Mr Laidlaw was part of an investigation, the fact
remains that it was a meeting with management withln
the meaning of e~ther art 6 02 or art 6 06, and that
Mr Laidlaw was denied the representation to which he
was entitled, the purpose of which has been described
in Re Canadian Canners Ltd. And Int'l Assoc of
Machinists (1974) , 5 LAC (2d) 323 (Brandt) [at p
325] , as
to ensure that the employee is fully advlsed
of his rights and also to facilitate some
discussion which might lead to an amicable
settlement of the dispute, short of any formal
action being taken
In the face of the meeting having been conducted
without Mr Laidlaw having union representation, as he
was entitled to, and consistent with the cases that
have held that discipline subsequently lmposed in this
case lS null and void if the employee's contractual
rlght to due process is ignored, we hereby flnd that
the discipline that was subsequently imposed in this
case is null and void The parties negotiate certain
safeguards with respect to the manner in which
discipllne is to be imposed and/or the employer is to
confront the employee with respect to any other matter
under the collective agreement These safeguards are
In the nature of a contractual due process While It
may seem unfair to the employer to have its actions
found to have been null and void, the due process
provisions are central to the representatlon provided
under the collective agreement and, in our view, there
is no other way to give real meaning to them
15 Employees may be unable to properly act for themselves
because of the stress of the moment Reliance was had on Queen
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Elizabeth Hospital (1988), 2 LAC (4 th) 1 (Davis) In that
case, at p 6, the arbitrator stated
such representative will be in a better mental
state at that moment to cope with the issue than the
grievor and will be able to provide the grievor with
timely advice
16 It was submltted that a Union representative might have
intervened on the behalf of the Grievor and made submisslons
which raised mitigating factors
17 It was submitted that the provisions of art 26 3 are to
protect the Grievor, and it is not my role to conjecture about
whether the presence or absence of a Union representative would
have affected the result
18 It was submitted that Mr O'Toole's knowledge or lack of
knowledge did not alter the obligation of the Employer under art
26 3 Mr Porter is alleged to have informed Mr O'Toole about
an investigation and that some action would be taken In this
case, the Grievor's rights under art 26 3 were not honoured and
these rights must be honoured in advance of the meeting when he
must be made aware of the purpose of the meeting and his right to
Union representation
19 Evidence of a vague conversation between Mr O'Toole and Mr
Porter does not meet the requirements of art 26 3 Mr O'Toole
was the wrong person for the Employer to communicate with in
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order to achieve compliance wlth art 26 3 In any event, there
was no indication of a clear "direction" to Mr O'Toole by Mr
Porter as to when the meeting would take place and who and what
would be involved, and there was no indication that Mr O'Toole
passed on to the Grievor any information that might arguably
satisfy the Employer's obligation under the latter article
20 At the very least, Mr LaHay should have been told about the
fact that Mr O'Toole had been spoken to and informed about the
nature of that conversatlon - which did not happen
21 Even if the Employer may delegate the responsibility to
inform an employee as is required under art 26 3, here, the
facts are vague, and it is not even certain whether the name of
the employee under investigation was made known to Mr O'Toole
22 Although the Union did not raise the violation of art 26 3
until Ms Mitchell wrote Exhibit 7 to Mr Drmaj on May 25, 1995/
art 26 3 is a substantive rlght and the Employer cannot rely on
its own wrongdoing as a defense to the breach of the artlcle In
any event, there must be a clear indication of walver of the
employee's right under art 26 3
23 There was nothlng in the facts to demonstrate that the
Grlevor was aware that he had the rights afforded him under art
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26 3, and he could not be expected to waive a right that he had
not been made aware of
24 Because of the way in which the matter proceeded, the
necessary II groundwork II had not been establlshed by the Employer
to support a claim of waiver In the circumstances, there was no
way for the Unlon to have amended the grievance to raise a
specific violation of art 26 3 The only meeting at which the
right could be raised was that of June 13, 1994 The way in
which the Employer approached the matter indicated that there was
nothing more to be done after the meeting of June 13 except to
notify the Grievor that he was being discharged, which was
accomplished through the mail
25 Reference was made to the language of the agreement in
Hickeson -Langs, at p 380
6 02 Representation
An employee shall have the right of the
assistance of a Union Representatlve In any
matter under this Agreement concerning him
and which requires his meeting with
Management
6 06 A Steward shall be present in any formal
meeting between an employee and the Company,
where the matter discussed is to become part
of the employee's performance record
7 02 For a grlevance to proceed to arbitratlon (as
outlined below) the Union or the company, as
the case may be, shall specify the provlslon
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or provisions of thlS agreement that are
alleged to have been violated
There is also the following signed letter of
understanding
This will confirm the agreement between the
Company and the Union on November 9, 1983
concerning the administration of Section 6 06 of
the Collective Agreement between Hickeson-Langs --
Toronto Branch and Teamsters Union Local 419
In the administration of Section 6 06, where a
steward is not readily available, a senlor
bargaining-unit employee of the employee's choice
who is readily available will be present (in lieu
of a steward) in any formal meeting between an
employee and the Company
26 Reference was also made to the statement of the facts found
at pp 380-1
The company, an institutional suppller of foods,
had been encountering a theft problem at the time the
grievor was discharged and had responded by increaslng
the surveillance of its premises The sequence of
events leading up to the discharge of the grievor is
not dlsputed Mr Laidlaw was seen coming out of the
warehouse at about 3 00 a m during the course of his
Shlft on Friday, March 8, 1984, and placing some goods
in his car He was then brought back into the
warehouse for questioning by Messrs Lloyd (loss
prevention) and Baird (district manager) Mr Laidlaw
denied any wrongdoing and eventually agreed to go to
his car in the presence of the two company officials
Twenty-five salmon steaks and four tins of lobster meat
were found in Mr Laidlaw's car He was again brought
back into the warehouse and police were called without
there being any further discussion between Mr Laidlaw
and the company officials While waiting for the
police to arrive Mr Laidlaw asked for and was given
the telephone number of Mr Sean Floyd, the union
business agent He was allowed to call Mr Floyd and
to speak wlth him from a separate office Shortly
thereafter the police arrived and Mr Laidlaw was
arrested He was taken to the police station where, he
was asked if he wished to retain a lawyer, he asked and
was allowed to call Mr Floyd Mr Floyd, therefore,
spoke with the grievor on two occasions durlng the
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night in question Mr Floyd arrived at the warehouse
after Mr Laidlaw had been taken to the police station
~ The union dld not advise the company of ltS
intention to rely on art 6 of the collective agreement
until the day before the hearing Employees have had
the benefit of unlon representation at the
investigation stage in the past, but this is the first
theft case
27 Reference was also made to the statement of the board at p
386
We now turn to the doctrine of waiver The
doctrine of waiver has been applied by labour
arbitrators in circumstances where, in the face of a
procedural or technical defect in the filing or
processing of a grievance, the affected party continues
to process the grievance without objection In these
circumstances it has been held that the affected party,
by its silence, has "waived" its right to rely on the
procedural or technical defect
28 And to statements at p 387
Notwithstanding the judgment of the court [in Re Candl e
and Stevenson et al. (1984) 5 D L R (4th) 676, 44 0 R
(2nd) 656 (Ont Div Ct ) ] arbitrators should be
extremely careful in applying the doctrine of walver to
the exercise of substantive rlghts Thls is so because
employees are not usually represented by counsel during
the grievance procedure and sometimes not at
arbltratlon, and because the statutory purpose of
labour arbitration is to resolve labour disputes
arising from alleged breaches of a collective
agreement As distinct from a flnding of waiver in
respect of a procedural lrregularity, whlch then allows
the grlevance to be heard on its merits, a findlng of a
waiver of a substantive right limlts the scope of the
hearing on the merits and/or deprlves an employee of a
rlght to which he or she would otherwlse be entitled to
rely upon
29 Further at pp 388-90
We are of the view that Mr Laidlaw was entitled to
unlon representation under art 6 06 Artlcle 6 06
stipulates that "a steward shall be present in any
private meetlng between an employee and the company,
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where the matter discussed is to become part of the
employee's performance recordll Where the matter to be
discussed at a meeting between an employee and
management offlcials is the company's suspiclon that
the employee has engaged in an act of theft, the matter
discussed, if the company suspicions are confirmedl is
to become a part of the employee/s performance record,
as it did in this case We do not accept that so long
as the meetlng is investigatory in nature it cannot be
a meeting within the meaning of art 6 06 The
employer in Re Williams et al. and Treasury Board (Post
Office Department) (1979) I 22 LAC (2d) 94 (Abbott) I
attempted to make the distinction between investigatory
interview and a disclplinary interview as is made in
thls case The relevant clause in the collective
agreement in that case was entitled IIRight to
representation in case of disciplinary action" and
provided that IIAn employee summoned for disciplinary
reasons shall have the right to be accompanied by a
representative of the Unionll The arbitrator found in
that case that the lnterview of an employee by two
postal inspectors in connection with the investigation
of a fraud relating to overtime was a meeting at which
the employee was entitled to union representation The
arbitrator in that case reasoned as follows [p 99]
I am quite satisfied, on the eVldence before me,
that the postal inspectors lntended thelr meetlng
with Mr Williams to be an opportunity to further
their investigationl by obtaining from hlm
admissions of culpability or exculpatory
informationl and that they would take into account
whatever they obtained fromMr Williams In
declding whether dlsclplinary action should be
taken against him This is exactly the sort of
lnterview of which an employee should have advance
notice and should have the opportunity to be
accompanied by a union representative It iSI
therefore I precisely the sort of situation
contemplated by the parties to the agreement In
cIs 10 04 and 10 06
We adopt this reasoning A meeting at which an
employee is summoned to answer questions from company
offlcials with respect to whether or not he has
commltted a theft wherel If the company/s SUsplclons
are confirmedl the matter will become part of an
employee/s performance record lS a formal meeting
wlthin the meaning of art 6 06 It is required,
thereforel that a steward be present There was no
steward present at the meeting between Mr Laidlaw and
the two senior company officials in the early morning
(
I
24
hours of March 9, 1984 The company is free to
lnvestigate suspected improper or unlawful conduct to
whatever extent it desires However, when it decldes
to confront an employee, as happened in thls case, the
employee is entitled to union representation under art
6 06 of the collective agreement
Alternatively, the grievor was entitled to
representation under art 6 02 Mr Laidlaw was
required to meet with management when he was
apprehended in the partlng-lot and, clearly, even if we
accept that the meeting was in connection with an
investigation and that a distinction can be made
between an investigatory interview and a disclplinary
interview for purposes of activating art 6 06, it was
nevertheless a meeting dealing with a matter under the
collective agreement at whlch he was requlred to attend
and, therefore, a meeting within the meanlng of art
6 02 We are satisfied, therefore, that Mr Laidlaw
was entitled to the representation provided under art
6 02 when he met with management in the early hours of
March 9, 1984
30 Reference was also made to Milnes Fuel Ltd. (1981) , 29
LAC ( 2 nd ) 427 (Brown) , where the provision relied upon was
The steward shall be present when an employee lS
dismissed, suspended or disciplinary actlon taken
In that case (at p 428) the unlon took the posltion that the
dlsciplinary actlon taken by the employer was vOld ab lnitio
because there was no meeting concerning the grievor's discharge
at whlch a steward was present
31 In Milnes, at p 430-1, rellance was had on Re Budd
Automotlve Canada Co. Ltd. (unreported) , February 1972 (Brown)
The provislon in the collective agreement in the
Budd case, supra, was as follows
7 01 Any employee who is to receive a written
warning, suspension or discharge shall be
removed from his work statlon and taken to an
offlce He may, if he so desires, request
and obtain the presence of his steward to
(
25
represent him during such an intervlew
During such an interview the employee will be
advlsed of the offence committed
The arbitrator in that case, in dealing with that
provision in the circumstance where the union alleges
that by non-compliance of the company with such a
provision, the penalty warning was invalid, stated
The parties have developed a grievance
procedure to handle alleged violatlons of the
collective agreement and have agreed to certain
time-limits within which the procedure must be
followed In that regard art 6 10 provides In
essence that if the grievance is not carried on to
the next step within the time-limits, or within
the limits otherwise agreed by the parties, the
grievance is automatically settled on the basis of
the last decision given on the grievance form
This provides for a penalty in the event of non-
compliance with this procedure and in light of the
most recent arbitration decislons in similar
situations, it would follow that these are
mandatory provisions which must be strictly
applied These form part of the rules of
procedure for grievances There is no such
penalty provisions in the collective agreement
covering the failure to comply wlth arts 7 01 and
7 02, but lS that not simply a recognitlon that
these provisions do not form part of the rules of
procedures, but have been recognized by the
parties as matters of right The company has the
substantive right under the collective agreement
to impose discipline against its employees In
the lmplementation of that right, it is provided
that the company must comply with certain rules In
the interest of the employees concerned which are
set out In arts 7 01 and 7 02 I flnd these
provisions to be completely independent of what
may follow In the grlevance procedure resulting
from the company's inltlal action and are the
basic rlghts of an employee He has been given by
the parties the right to receive the charge
against him in the privacy of an offlce, the right
to know the penalty within the time stipulated in
art 7 02 and the right of representatlon These
are substantive rights which must be accorded to
the employee if the right of the company to
initiate discipline is to be given weight The
fallure, then, to allow these rights to the
employee is not a failure to follow procedure
In my view the parties have balanced the basic
(
\
26
rights of the company and the employee for the
purpose of discipline by which the exercise of the
company's rights to discipline must be met wlth
the employee's right It is not a matter going
solely to the assessment of the penalty but goes
to the very action of discipline itself
Article 7 01 provides that the charge shall
be made known to the employee and by art 7 02 the
company assesses the penalty and lS obligated to
advise the employee wlthin the time provlded The
damage from the breach of such provision would be
the negation of the employee's basic contractual
rights to the protectlon provided by the partles
in disciplinary matters
The arbitrator went on to find that art 7 01 was not
procedural but, provided a substantive right to the
employee which could not be denied by the company, and
must be strictly applied In the event of the failure
by the company to grant such rights, the imposition of
discipline was void ab initio
32 Further In Milnes, at p 434, the majorlty of the board
stated
The clear lntent of this article in our view lS, that
when an employee is as in this case, being dismlssed
and that decision "has been taken, he is entitled to be
told or advised in the presence of his steward which
might be for the purpose of representatlon at that time
or for protecting any other rights he may have with
regard to the grievance procedure, but the nature of
that protection afforded to the employee by the partles
is representational in effect To omit that right, In
our opinion, is an omisslon of a substantive right and
not merely a procedural step under the grievance
procedure, default of which might be the subject of
relief through the provislons of the Labour Relatlons
Act, R S 0 1970, c 232 The agreement does not
provide that In the absence of this step belng
fulfilled the disciplinary action is a nulllty, but the
effect of failure to comply with a substantive right of
a mandatory nature contalned in the collectlve
agreement conflicts with the baslc rights of the
employees in relation to the right of the company
subject to the term of the collective agreement, to
lmpose dlscipllne
(
27
33 To the same effect are Re Toronto Western Hospital (1985) ,
19 LAC (3rd) 191 (M G Picher) at p 191 and p 201, Re St.
Joseph's Hospital (Brantford) (1987) , 28 LAC (3rd) 408 (P C
Picher) at pp 411 and 419, Re Weetabix of Canada (Mfg. ) Ltd.
(1987) , 31 LAC ( 3 rd) 444 (Draper) at p 447 (where the board
also stated "Waiver connotes knowledge of a right and the
intention to surrender or abandon it ") , Re Queen Elizabeth
Hospital (1988) , 2 LAC (4th) 1, at pp 2 and pp 4-8, Re
Glengarry Memorial Hospital (1990) , 11 LAC (4th) 325 at p 329
and p 331, Re Valdi Foods (1987) Inc. (1990) , 16 LAC (4th)
318 (Brandt) at p 323; and Re Brewster Transport Co. Ltd.
(1992), 26 LAC (4th) 240 (Tettensor)
34 It was submitted that the fact that the Employer paid the
Grievor from the time he was no longer at work on June 13th to
the tlme of his discharge on June 23rd represented no "real
dlstinction " It was submitted that the discipline commenced on
June 13th, and reference was made to the words "that as a result
of these events dlsciplinary action may be taken against you," in
Exhlblt 4 If the payment to an employee in the circumstances of
.
the Grievor during a period of suspension could change the
result, then this would "take the guts out of art 26 3 " The
"disclaimer" that disclpline might follow cannot assist the
Employer
(
28
Mr. D rma J made the following submissions by way of argument
, on behalf of the Employer.
1 That the issue before me is whether art 26 3 is procedural
or substantive
2 If substantive, it covered such a narrow range of situations
that it is not applicable to the facts before me and is merely
dlrectory
3 If I found that art 26 3 was substantive and mandatory,
then it concerned only the notice of intended discipline The
meeting of June 13 did not represent a "disciplinary encounter"
so as to void the discharge if the meeting was not carried out in
accordance with the requirements of art 26 3
4 If I found that the meeting of June 13, 1994 was
disciplinary ln nature and wlthin the purview of art 26 3, then
Exhlbit 4 related only to the June 13th suspenslon that was
grieved in Exhibit 2 and not to Exhiblt 3, the discharge
grievance
5 The discharge of the Grievor that followed the fillng of
Exhibit 2 led to an additional grievance being filed on June 28th
(Exhibit 3), which represented an entirely different matter from
(
29
the Gr1evor's suspension meted out in exhibit 4, and was
I unrelated to the meeting of June 13th
6 There was no requirement for a meeting to be convened in
order to deal with the actual discharge or discipline of the
Grievor Accordingly, the Letter of Discharge (Exhibit 6) was
valid If I rejected all of the other arguments made on behalf of
the Employer, only the suspension might be declared 1nvalid
7 The Union, by its conduct in not raisi~g the matter relating
to art 26 3 until May 25, 1995, waived any breach of that
article by the Employer
8 If I rejected the argument of the Employer based on waiver,
then any remedy afforded the Grievor should cons1der when the
obJection was ra1sed (on May 25, 1995) and restrict rel1ef to the
per10d from that date
9 A substant1ve r1ght in the Grievor 1S only created by clear
and unequivocal language Reference was made to such substantive
rights as the right to Union representation during the gr1evance
procedure and in connection with seniority rights, where the
language of the collective agreement was said to be clear and
unequivocal
10 Reference was made to art 27 3(a) (ii)
(
30
Unless otherwise agreed betwe~n the employee and
hls/her supervisor, a meeting in respect of an
employee's complaint shall only be attended by the
" employee and hls/her supervisor
11 This provision lS found in art 27, which is headed
"Grievance Procedure " Art 27 3 is headed "Stage 1 (Complaint
Stage) " and art 27 3 (a) (i) provides, inter alia
An employee who has a complaint or a dlfference shall
discuss the complaint or difference with his/her
supervisor, as designated by the Employers
12 It was submitted that art 27 3(a) (ii) specifically deals
with the subject of who is to be present at the meeting referred
to This was said to be unlike the provisions of art 26 3,
where there is no specific reference to who must be present at
the meeting
13 It was submitted that art 26 3 should not be "lsolated"
from the rest of the grievance procedure, where references to who
should be present at meetings are "clear and unequivocal "
14 It was submitted that the facts of the case before me should
be dlstinguished from cases where the meetlng involved a
disciplinary response The case before me was said to involve a
situation where there might be a disciplinary response, but not
necessarlly so
15 It was submitted that it was not possible to create a
"partial substantive right 11
(
31
16 It was submitted that an interpretation such as the one
sought by the Union would dlscourage meetings that is, if it was
always necessary for an employee to have Union representation
17 Art 26 3 lS directory and procedural and has as its purpose
assuring, where certain matters arise that might requlre the
impositlon of discipline, that the affected employee is made
aware of the purpose of the meeting and of his/her right to Union
representation in advance of the meeting However, failure to
adhere to the requirement would not necessarily void any
subsequent discipline that is meted out
18 An examination of the facts demonstrates that the meeting
was not called for the purpose of "discussing a matter which
[might] result in dlscipllnary action," and hence was not one
envisaged by art 26 3, but was for the purpose of effectlng the
Grlevor's arrest in the Store Manager's office rather than in the
"open store, " so as to insure privacy, and also to take him into
custody, there being no obligation to hold such a meeting as is
referred to in art 26 3
19 Handing Exhibit 4 to the Grievor at the meeting was only
peripheral to the purpose of the meeting, which was to effect his
arrest and to enable him to be taken into pollce custody
l.
32
20 Where a meeting is held for a purpose other than IIdiscussing
a matter which may result in disciplinary action being takenll or
for combined purposes, where the issuance of a Notice of Intended
Discipline is peripheral to the main purpose, art 26 3 can only
be viewed as belng procedural
21 The word IIshall" as found in art 26 3 does not always
create a mandatory obligatlon
22 Art 26 3 can be interpreted as furnishing an option in
favour of the Grievor, but the question of undue delay, being
undefined, leaves the matter of calling in Union representation
in the hands of management
23 If I conclude that the provisions of art 26 3 confer a
substantive right on the Grievor, then it is necessary to examine
the facts to see if they fit within the provisions of that
artlcle It was submltted that on the facts before me I should
not flnd that there was a meeting for the purpose of discussing a
matter which might result in disciplinary action being taken
This was said to be reinforced by the statement in Exhlblt 4
IIThis is not a disciplinary response II
24 If I find that the meeting of June 13 was one called for the
purpose of discussing a matter which might result in discipllnary
action being taken, then the action then taken by the Employer
(
33
was grieved by Exhibit 2 on June 20th, and that grievance relates
to the suspension effected by Exhibit 4 A "technical" fallure
to comply with the requirements of art 26 3 in connection with
the meeting of June 13, 1994 cannot affect the valldity of the
subsequent discharge of the Grievor In Exhibit 6 The
"technlcal" failure only affected the suspension, which was a
separate issue that was grieved as such
25 If I find that the suspension meted out in Exhibit 4 was the
kind of "disciplinary action" envisaged by art 26 -:l and was void
-'
ab initio, then the Grievor received "all wages, benefits and
senlority lost " The dlscharge meted out by Exhiblt 6 was an
entirely separate matter unrelated to the meeting of June 13th
26 If I flnd that the discharge of the Grievor, meted out in
Exhibit 6, is a matter that flows directly from the meetlng of
June 13th, then any breach of art 26 3 had been waived and can
no longer be pursued
27 If I find that art 26 3 is applicable to the facts of thls
case, then Mr O'Toole and/or the Grievor knew or ought to have
known as early as the Notice of Intended Discipline that the
meeting of June 13 would involve a dlscussion of matters which
might result in the Grievor's being disciplined It was
submitted that either or both of them were aware of the
investlgation and of the videotaped eVldence It was submitted
(
34
that the Grievor had a duty to raise the provislons of art 26 3
when he was told about the events that were being lnvestlgated
and it was evident that discipline might follow The Grlevor
should have raised the provislons of art 26 3 when Exhlbit 2 was
filed and later when Exhibit 3 was filed, and at the latest by
August 8, 1994 when the Union waived the right to go through the
further stages of the grievance procedure and agreed to proceed
directly to the Grievance Settlement Board (Exhibit 8)
28 Reference was made to Alcan Wire and Cable, an unreported
case decided by the majority of a board chaired by S A Tacon on
July 20, 1989
29 The provision of the collective agreement in the Alcan case
consldered by the board was
25 07 Where a counselling or disciplinary meetlng
is to take place between a supervlsor and a bargainlng
unit employee and such meeting shall result in a
written disciplinary notation, then such meeting shall,
where practicable, and if the employee so requests,
take place in the presence of a Union steward
30 The union in Alcan argued that the employer failed to comply
with the procedural steps required in order to properly termlnate
the grievor, and hence the grievor should be reinstated "in
consequence of this procedural defect "
31 Reference was made to the statement of the majorlty of the
board, at p 11 of Alcan
(
35
In the instant case the board views the questlon
of a procedural defect as one which may properly be
raised at the hearing for the first tlme only on the
basis that, if that argument is ultimately successful,
the relief granted should not predate the point at
which the question was first ralsed To hold
otherwise, would result in substantial prejudice to the
company Prior to the hearing, the company was unaware
that question was in issue Yet, it is the company
which mlght well be financially liable by way of a
compensation order for that entire period To so limit
the remedy, however, would adequately address the lssue
of prejudice (Emphasis in original)
32 Reliance was also had on the statement of the majority of
the board at pp 12-13 of Alcan
The board must next consider the language of
Article 25 07 to determine whether that article
confers, as the union contends, a substantive right to
the presence of a steward in the circumstances of this
case so that the absence of the steward renders the
subsequent termination void
The relevant portion of Article 25 07 lS worth
repeating here" then such meeting shall, where
practlcable, and if the employee so requests, take
place in the presence of a union steward" The board
notes that the practicability of a union steward's
attending was not in issue
The phrase "and if the employee so requests" must
be given meaning and that meaning is clear - an
employee request is a precondition to the
representational right QUlte simply, the right lS not
absolute nor can it be said that the language confers
an obllgation on the company to brlng the "optlon" to
the employee's attention prior to, or at the
commencement of, the meeting see Weston Bakeries
Llmited (Chatham, Ont.) (unreported, September 26,
1988) (MacDowell) and the cases cited thereln While
it lS conceivable that there may arise circumstances
wherein those words should not be given effect if, for
example, the company were to be estopped from relYlng
on that precondition, that is not the case herein The
grievor had his thirty day appraisal in February and
knew the nature of the meeting scheduled for March 30
At the February meeting, his performance was reviewed
and his deficiencles discussed Most tellingly, the
grievor knew that ''If he didn't pull up his socks, he
36
would not last " It cannot be said that the grievor
could not have anticipated a possible outcome of the
March meeting would be his termination There lS no
dispute that the grievor did not request the presence
of a union steward at the meeting The board has no
authority to amend the collective agreement to modify
language from a precondition which has not been
satisfied to an absolute right to representation or an
affirmative obligation on the company to inform the
grievor of the wording of Article 25 07 or his option
to request a union representation at the meetlng
Thus, the board rejects the union's posltion on the
first preliminary motion
33 Reliance was also had on Pharma Plus Drug Marts Limited, an
unreported case decided by N B Satterfleld on December 20, 1993
In the Pharma Plus case, the grievor was terminated for breach of
a company rule
Every sale must be registered and a receipt given to
the customer Fallure to register sales will result in
termlnation
34 One of the issues raised in the case involved art 31 01 (a)
Where an employee is to be interviewed by the Company
or Security regarding discipline or dismissal, the
employee may request the Union Steward or another
bargaining unlt employee to be present to observe the
discusslon and such request shall be granted
35 The alleged breach of art 31 was said by the union ln
Pharma Plus to void the discipline imposed ab initio
36 At P 8 of Pharma Plus, the arbitrator stated
With respect to clause 31 01 (a) , whether the
clause falls within that group of clauses WhlCh
arbitrators have said creates substantive rights, or
whether it falls within the group which are procedural
only and therefore directory, I find that there has
been no breach of clause 31 01 (a) of the collective
agreement The grievor is a steward and was aware of
\
37
his collective agreement right to the kind of
representation described in clause 31 01(a) The
meaning of the phrase" the employee may request
" is clear in the context of the clause If an
employee wants the benefit of the representatlon
described, it is a precondition to that right that the
employee asks to be represented by a Unlon steward or
another bargaining unit employee The right to that
representation is not absolute because of that
precondition
37 Reference was also made to The Steel Company of Canada
(Rayner) , an unreported decision dated August 29, 1990, where the
grlevor had been discharged by a registered letter dated August
10, 1987, and where, at the outset of the hearing, union counsel
indicated that there was a preliminary objection claimlng that
the dlscharge was null and void because the employer had failed
to follow art 9 11 of the collective agreement
38 Art 9 11 of the Steel Company agreement is as follows
9 11 - No employee other than a probationary employee
shall be discharged without first being glven seven (7)
days notice except in cases of serious misconduct, when
discharge shall be effectlve immedlately An employee
who is being notified of his/her discharge may elect to
have a departmental Chief Steward or Steward present
In the event that a departmental Chief Steward or
Steward is not present at the time the employee lS
notifled of hls/here [sic] dlscharge, the Company will
notify the Chief Steward of all immediate dlscharges or
notice of discharge given to employee in his/her
department, excepting probationary employees, with
[sic] forty-eight (48 ) hours after such discharge or
notice of discharge has been effected Grlevances
relatlng to notice of discharge or discharge may be
initiated at Step No 2 of the Grievance Procedure and
may be appealed dlrectly to Step No 3
39 At pp 4-5, the board stated
\
38
The first part requires 7 days notice of discharge
(probationary employees apart) except in cases of
serious misconduct The part has no bearing on the
objection before us and can, at this point, be
disregarded although for completeness it should be
noted that in an earlier award, Re Stelco 18 LAC
( 3d) 353 (Kennedy) this language was held to be
directory and procedural and lack of notice dld not
render the discharge a nullity
The second part, and the part relied on by the
Union, permits an employee who is being notlfied of his
discharge to have a Union Steward present
The third part requires the Company to notify,
within 48 hours, the Chief Steward of all immediate
discharges or notice of discharge (save probationary
employees) "in the event that a departmental Chief
Steward of Steward is not present at the time the
employee is notified of his/her dlscharge" (emphasis
added in Stelco)
The latter two parts of Article 9 11 were
canvassed in an earlier award between the parties
(McLaren, January 1984) but that case does little to
assist the Board However, it does note that there is
no obligation on the Company to put an employee to an
election to have a Union representative present
The gist of the Union objection is that the
Company had to have a meeting with the grlevor and that
the grievor had to have an opportunity to elect to have
Union representation present Mr Smlth said that the
right to an election would be meaningless if there was
not an implied right to a discharge meeting He also
suggested that the grievor's refusal to attend the
Company's premises in possible violation of hlS ball
order was reasonable We agree with the latter
submission but not the former
40 At pp 5-6 of the Steel Company case the board concluded
Implicit, indeed a cornerstone, in the Union's
argument is that there must be a meeting before
discharge can be effective although Mr Smith conceded
that there may be very unusual Clrcumstances where a
meeting cannot be held However, in the normal case a
meeting must be held and the employee glven his
electlon He relied on the leading case of Re Mllnes
Fuel Oil 29 LAC ( 2d) 428 (Brown) where the agreement
required that an employee to be dlscharged "shall be
(
39
removed from his work station and taken to an office"
where he could elect to have Union representation
This case was followed in Re Clarke Institute 20 LAC
(3d) 193 (Knopf), Re Corp. of the City of Toronto 24
LAC (3d) 115 (Joliffe), Re St. Joseph Hospital 28
LAC (3d) 408, and Re Automotive Industries
(unreported, Rahim, 1988)
Although the Mllnes Fuel case appears correctly
declded on the language of that collective agreement,
the other decisions may be doubtful to the extent that
the decisions do, or do not, determine a threshold
issue That issue is whether the agreement requires a
disciplinary meeting to be held In the Clarke
Institute case and the City of Toronto decision the
answer would appear that a meeting was required and
where a meeting is required, if the collective
agreement permits or requires Union representation,
failure to allow such representation may render the
discharge a nullity However, we must first decide
whether a meeting is required under the terms of this
Collective Agreement If there is no need for a
meeting, the election of Union representation is not ln
issue and the discharge cannot be challenged solely on
the basis of Article 9 11
In Re Cambridge Towel 66 0 R (2d) 793 the
Dlvisional Court sounded a cautionary note ln
overextending the reasonlng such as was found in Mllnes
Fuels and declarlng discharges a nullity because of
failure to comply with all notification or notice
provlsions of the Collective Agreement It lS trite to
say that a Board should not stand on procedural
technicalities and fail to hear the merits of the
dispute unless the Collective Agreement makes it clear
that any procedure set out therein must be followed as
a conditlon precedent to the action in dispute no
matter which side raises the technicality However, ln
this case, we do not believe that there has been even a
technlcal violation of Artlcle 9 11
41 In the Steel Company case, although the grievor had been
requested to attend at the plant for an interview before he was
discharged, no such interview meetlng took place for reasons
which are not materlal here
(
40
42 After stating that the union could only succeed if the board
found that art 9 11 required a discharge meeting, the board
stated, at p 7
If no such meeting is required, there has been no
violation in the instant case As previously stated
nowhere ln Article 9 11 is there an express statement
that a meeting be held This lack of expression is
contrasted with the language used for notice of
discharge to the employee, i e , "No employee shall be
discharged without 7 days notice" and for notiflcation
to the Chief Steward "the Company will notify the chief
steward within 48 hours" Indeed, the very wordlng
of the Article contemplates that there may be
discharges where there is no steward present This
lack of stewardship could result from either the
employee electing not to have Union representation or
because there has been no discharge meeting Both
possibilities exist under the present language
However, there is no language that mandates a meetlng
(Emphasis in orlginal)
43 The final submission made on behalf of the Employer was that
even if it failed in all of the above submissions, and the
discharge lS declared to be vOld ab initio, there is nothlng to
prevent the Employer from properly repeating the exercise and
relsSUlng "appropriate discipline " It was submltted that
requiring such a procedure did not "make a lot of sense in thlS
kind of case " See, Board of Governors of the Riverdale Hospital
(1983), 11 LAC 267 (Brandt)
44 At pp 277-8 of the Riverdale Hospital case, the board
stated
In reaching my conclusion I am mindful of the fact that
this award does little more than compensate the grievor
and reinstate him as a probationary employee wlthout
any right to grieve in the event that the hospltal
(
41
should, upon this award, set out to accomplish the
termination of the grievor in accordance with the
requirements of art 13 02(a)
45 Reference was also made to VS Services Ltd. , Vending
Services (1990) , 17 LAC (4th) 339 (Brandt) That case dealt
with the question, apparently one that had not been dealt with in
the arbitral jurisprudence, whether or not, once it has been
determined by a board of arbitration that a purported discharge
was null and void for failure to comply with a provision in the
collective agreement requlring union representation on the
imposition of discipline, an employer can, in the absence of any
new and different ground for discharge, discharge the employee
again in full compliance with the provisions requiring union
representation
46 After finding that his earller Riverdale Hospital case (at
p 334) lndicated "by implication at least, that there may be
circumstances ln which it is quite proper for an employer to
correct lts earlier errors and act again on the basis of the same
events as had earlier motlvated lt to act," the board concluded
that this was a case where the employer should be permitted to
properly carry out the requirements of the collective agreement
and terminate the employee
Argument in reply made on behalf of the Union
42
1 The meeting of June 13, 1994 was not just for the purpose of
facilltating the arrest of the Grievor If that were the
lntention, Sergeant Crockford could have been furnished with an
offlce or with the home address of the Grievor, and it was
unnecessary for anyone associated with the Employer to be in
attendance The Employer did not choose to do that, but lnstead
brought the Grievor into the Manager's office at his home store
and related (through the Manager) the details of an offence that
clearly could be the subject of discipline, in the presence of
two investigators for the Employer as well as Sergeant Crockford
of the Orillia Police detachment
2 When the parties negotiated art 26 3, they envlsaged a
situation where, if the Employer chose to have such a meeting as
lS there described, the employee involved had certain rights to
be informed in advance of the meetlng of its purpose and of hlS
right to Union representation
3 It was submitted that there was a discussion in WhlCh Mr
Holmes informed the Grievor that he had been observed involved in
lmproper cashierlng procedures on May 4, 1994 and asked him for
an explanation to justify his observed behavlour Because of the
way the Employer to chose to conduct the meeting, it represented
one where dlscipllnary action mlght be taken against the Grlevor,
whether or not it had another purpose
\
43
4 Although Exhibit 4 states that lt is not disclplinary in
nature, this does not matter because art 26 3 refers to "a
matter which may result in disciplinary action " The matter, in
this case, might, and, in fact did, result in disciplinary action
being taken against the Grievor
5 Reference was made to Weetabix of Canada (Mfg. ) Ltd.
(1987) , 30 LAC ( 3 rd ) 444 (Draper) , where the language of the
agreement was said to be similar to that of art 26 3
9 09 An employee when called to a meeting with
Management, where disciplinary action may result, shall
have the right to have a Steward or Union official ln
attendance, however said employee shall also have the
right to waive the necessity of the attendance of such
Steward or Union officlal
6 The arbitrator in the Weetabix case found, at p 448, that
art 9 09 was mandatory and conferred a substantive rlght and
that the company's failure to comply wlth the artlcle rendered
the dlscharge of the Grievor void ab initio
7 In response to the Employer's argument that lf there was a
meeting wlthin the meaning of art 26 3 it was not dlsclpllnary
in nature and only related to a suspension pending further
investigation, it was submitted that the discharge of the Grlevor
that followed was the natural result of what had taken place at
the meeting and was talnted by the violation of the Grlevor's
rights under art 26 3 The fact that there were no further
meetings demonstrated that the Employer did not need to have a
(
44
further meetlng to obtain information That information was
already within its knowledge on June 13, 1994
8 Because the provisions of art 26 3 are substantive in
nature, an allegation that the Grievor's rights under that
article had been violated can be raised to the date of the
hearing
D1Scussion and Decision
1 The Union, having raised the issue as to whether art 26 3
had been violated, has the burden of proving that that was the
case
2 Because there was no written agreed statement of facts, it
was necessary for me to review my notes to see whether there was
a difference between the versions of the facts as presented by
the parties
3 It is not unusual for parties to argue motlons such as the
one before me without eliciting Vlva voce eVldence, but to argue
on the basis of agreed facts, either in writlng or as presented
to the board orally In this case the later was done After Ms
Mltchell had reviewed the facts from the Unlon's perspectlve, Mr
Drma j , while stating that he agreed with most of those facts,
(
45
indicated that he took issue with some of them and presented
facts that he believed had not been fully dealt with by Ms
Mitchell, which additional facts she did not dispute
4 In his opening statement, Mr Drmaj stated that there was an
investigation concerning certain shortages from cash in Store 175
in Orillia where the Grievor worked Mr Porter, the District
Manager, was said to have had discussions with LCBO security
representatives, and a decision was made to engage in certain
investigation procedures surveillance of the Grievor, including
surveillance through the use of video cameras It was as a
result of the implementation of these investigation procedures
that the Grievor was said to be implicated - on May 4, 1994 - ln
a breach of the Employer's cashiering procedures, which breach
Mr Drma j identlfied as being both a "disciplinable event and
also [as representlng] criminal activity "
5 Mr Drmaj stated that the criminal activity represented the
"possibillty of theft" having occurred Mr Porter was said to
have been lnformed about the result of the vldeo surveillance and
that the LCBO security personnel wished to proceed to recelve
advice from the police as to whether criminal charges "could or
should be lald" because of what the Grievor was said to have
done
(
46
6 According to Mr Drmaj's version of the evidence, the
question of discipline was said to have been placed ln abeyance
when, on June 10th, Mr Porter was glven the information
relating to the investigation, above referred to
7 Mr Drmaj's version of what took place was that on June 10th
Mr Porter had told Mr Holmes, the Store Manager, that he was to
attend on Monday June 13, 1994 with the LCBO investigators at the
Orillia pollce station to view the videotapes of the Grievor and
be present while a determination was made as to whether criminal
charges should be laid and "how this was to be done " Mr Holmes
was also said to have been told by Mr Porter that there would be
a letter for the Grievor in Mr Porter's office in Barrie
(Exhlbit 4), which Mr Holmes was to pick-up and deliver to the
Grlevor on June 13th
8 Mr Holmes is supposed to have attended on Sgt Crockford at
the police statlon in Orillia on the morning of June 13, along
with the two LCBO investigators, at which tlme Sgt Crockford
revlewed the videotape and the details of the investigatlon
Sergeant Crockford then informed Mr Holmes and the investlgators
that there was sufficient evidence to lay charges agalnst the
Grievor It was then decided to return to the store ln order to
confront and arrest the Grievor
l
47
9 Mr Drmaj stated that there was a dispute between hlmself
and Ms Mitchell as to exactly what had taken place at the
"meeting" on June 13, 1994
10 Mr Drmaj stated that he did not agree with Ms Mitchell's
description of what had taken place at the meeting that a
discussion with respect to matters relevant to the "Notice of
Intended Discipline" occurred first, with the "flow" of the
meeting then proceeding to the charging of the Grievor wlth the
offence of theft under $1000 00 and his arrest He raised, but
did not pursue, the question as to whether the Grievor's arrest
took place first
11 Mr Drmaj stated position was that immedlately before
anything else happened at the June 13 meeting the Grievor was
told who the other persons at the meeting were, the purpose of
their presence, was then given the letter of June 10, 1994
(Exhlbit 4), and was then escorted to the police station by
Sgt Crockford, charged and placed under arrest
12 I note that Mr Drmaj , when he said that the Grievor was
lnformed of the "purpose" of the meeting, did not elaborate on
what the Grievor was exactly told about the "purpose "
13 Ms Mitchell stated that after the persons in the manager's
offlce were seated on June 13, 1994, Mr Holmes gave the Grievor
(
48
Exhibit 4 The Grievor was then said to have been asked by Mr
Holmes "What were you dOlng on May 4th?" and Mr Drma j did not
deny that this statement was made Nor did he deny the statement
attributed to the Grievor in response to the question That he
did not know what he was doing on that day and could not recall
if he was at work at that time Mr Holmes was then said to have
advised the Grlevor that he was observed engaged in improper
cashiering procedures, in that he was observed taking cash from
the drawer and was asked if he had any explanatlon for his
actions The Grievor is then said to have responded that he did
not know what he was doing, and that he might have been making
change for himself
14 Sergeant Crockford is then supposed to have asked the
Grievor if that was his statement, and the Grlevor is supposed to
have replied that he was not making a statement, and it was at
thlS time that Sergeant Crockford took over the meetlng and
arrested the Grievor For the purposes of this case I find that
there lS no particular significance in the Grievor's response
that he was not making a statement
15 I note that Mr Drma J did not say that he was disagreeing
wlth the recitation of the facts as given by Ms Mitchell but
stated that he wished to add some additional facts and reorder
some of the events to show that they had taken place in a
dlfferent order
(
49
16 I am satlsfled that the meeting had a dual purpose to
arrest the Grievor and "for the purpose of discussing a matter
WhlCh [might] result in discipllnary actlon being taken agalnst"
him It was unnecessary to hold a meeting in the Store Manager's
office just to arrest the Grievor or to have present the Manager
and the two LCBO investlgators Questions related to a purely
crlminal investigation could have been asked by Sergeant
Crockford without anyone else being present The Grievor could
have been arrested at his home or taken to the police station and
there placed under arrest without the further involvement of Mr
Holmes or the two LCBO investigators The questions that Mr
Holmes put to the Grievor were more consistent wlth his lnterest
in securing information related to the Grievor's breach of the
Employer's cashiering procedures and to facilitate the process
leading to the lmposistlon of discipllne Whatever other purpose
the meeting may have had, as conducted by Mr Holmes it also
became a meeting to discuss "a matter which may result in
dlsciplinary action being taken" against the Grievor If the
meeting only was concerned with confronting the Grievor wlth
respect to his commission of a criminal offence, it would be
expected that only Sgt Crockford would be ln attendance and ln
complete control of the meeting The evidence was otherwlse, and
I am satisfied that the meeting had two purposes one related to
an employment offence that could lead to dlsclpline, the other
belng related to the commission of a criminal offence
(
50
17 Although there is nothing in the collective agreement that
requlres the Employer to hold a meeting "for the purpose of
discussing a matter which [might] result in disciplinary actlon"
against an employee, once such a meeting is held it must be held
in compliance with the provisions of art 26 3 See The Steel
Company of Canada case, above, at pp 7-8
This conclusion does not render the second part of the
Article nugatory If a meeting is convened, and if the
employee is denied Union representation after electing to
have representation, the rationale of Re Milnes Fuel could
operate
Surely, the purpose of this part of the Article is two-fold
flrst, it informs the Union of the discharge but that object
is again achieved by the thlrd part of the Artlcle Second,
lt ensures that the employee, on the spur of the moment,
does not make a statement that may inculpates hlm or her
However, if there is no meeting, there is no need to protect
against inculpatory against inculpatory statements
In conclusion then we believe that Article 9 11, or at least
that part relied on by the Unlon has no application if no
dlscharge meeting is held and that Article 9 11 does not
require such a meeting as a condition precedent to
dlscharge If a meeting is held and the employee denied
representation, Re Milnes Fuel may then apply
18 Although lt is necessary to pay close attention to the
wordlng of the particular provisions of the article said to have
been violated so as to lead to the concluSlon that the disclpllne
lmposed is vOld ab initio, I am satisfied that art 26 3
represents a substantlve and not procedural requirement in
accordance wlth the llne of cases followlng Mllnes Fuel Oil Ltd.
( above)
(
51
19 In the Alcan case, because the clear language of the
agreement created no such obligation, the arbitrator found, at p
12, that the article in question did not to confer "an obllgation
on the company to bring the 'option' to the employee's attention
prior to or at the commencement of the meeting "
20 In the Pharma Plus case, the board, at p 8, held that it
did not matter whether the article in question created
substantive rights or fell within "the group which are procedural
only and therefore directory," because it was "a precondition to
that the right that the employee asks to be represented by a
union steward or other bargaining unit employee "
21 In the Steel Company of Canada case, there was, as in this
case, no requirement that the Employer hold a meetlng in that
case to deal with the discharge of the employee At p 7, the
board stated
if no such meeting is requlred, there has been no
violation in the instant case
But, as was noted above, the situation is different when a
meeting is held and the subject matter of the meetlng falls
within the provisions of the article In the Steel Company case,
no meeting was held, and there was " no need to protect agalnst
lnculpatory statements " (At pp 7 - 8)
22 Art 26 3 creates a substantlve rlght which can only be
waived by the employee involved That rlght lS to make the
(
52
affected employee " aware of the purpose of the meeting and
hls/her right to Union representation in advance of the meeting "
The Grlevor never walved his rlghts Even if Mr O'Toole was
able to do so, I cannot find this to have been the case In any
even t , I cannot find that Mr O'Toole had sufficient information
about which employee was involved or of the exact nature of the
matter being investigated to be able to make an informed
declsion
In the Riverdale Hospital case, above referred to, the board
referred to the following article (13 02(a)) found in the
collectlve agreement
An employee may be discharged or suspended only for
just cause When an employee is discharged or
suspended he shall be glven the reason in the presence
of a representative of the Union Such employee and
the Union shall be advlsed promptly in writing of the
reason for such discharge or suspension
23 The board stated at p 275-6
Since the rlght provided for in art 13 02 (a) is a
rlght which lS personal to the employee lt could be
waived by the employee
24 At P 276, the board stated that it was insufficlent that
the union representative had been advised that dlSClplinary
action was going to be taken and then to ask her to remain ln the
area ln the event that the grievor wished asslstance "The
fairer procedure would have been to ask the grievor, in the
presence of the steward, whether or not he wanted union
representation "
(
53
25 In thlS case, the Grievor was not made aware of the purpose
of the meeting at the outset, nor was he informed of his right to
Union representation
26 The right to Union representation lS not a mere formality
In drafting art 26 3, the parties had in mind the possibility
that through Union intervention the meeting might result in the
Employer taking actions different from those that might be taken
in circumstances where the employee had no Union representation
In the Riverdale Hospital case, above, the board stated, at p
278
The rights granted under art 13 02(a) to employees are
lmportant rights and represent an important feature of their
job security It cannot now be known whether or not, had
the employer complied with art 13 02(a) at the tlme that it
chose to terminate the grievor, the representatlons of the
union steward might have persuaded them to do otherwise
The action of the employer prevented the grievor from
enjoying the opportunity of havlng union representation at a
time when hlS employment was terminated The damage which
he suffered as a result of that actlon is, ln my oplnion,
damage for which he ought to be compensated
27 The fact that the Grievor was, by Exhibit 4, furnished with
an opportunity to submit a written statement by registered mail
explalning his actions with respect to the alleged improper
cashlering procedures on May 4, 1994 does not overcome the breach
of his rights under art 26 3 His rlghts had already been
breached by that tlme
28 There is a seamless connection between the meeting of June
13, 1994, the Grievor's being suspended on that date (Exhibit 4)
(
54
and his being terminated on June 23, 1994 (Exhlbit 6) It lS
artiflclal to arbitrarily divide the process whereby a meeting
was held on June 13 to discuss a matter which might result ln
disciplinary action being taken against the Grievor and the
events following which were inextricably associated with it That
lS, to state that the June 13 meeting was insufficiently related
to the discharge of June 23 in an endeavour to make the
suspension effected by Exhibit 4 the only action of the Employer
that was void ab initio The events of the meeting of June 13th,
the suspension imposed, and the discharge are so ineAtricably
linked so as to taint not only the suspension but the discharge
Cf Hickson-Lanqs ( above) at pp 338-90
29 It was not suggested that anyone at the meetlng of June 13,
1994 speciflcally told the Grievor that the meeting was being
held solely for the purpose of furthering a criminal
investigation and the laying of a criminal charge
30 Being substantive ln nature, it dld not matter that the
Employer was only notified of the Union's intention to raise the
violation of art 26 3 on May 25, 1995 Also, the origlnal
written grievance was "broad enough so as to encompass disclpline
which is improper with respect to the procedure followed as well
as the merits of the decision to terminate Alcan Wire and Cable
(above) at p 10 (Emphasls in origlnal) Subject to the Grievor
walving his substantive rights under art 26 3, my Jurlsdlction
(
55
is dependent on the Employer having complied with the provisions
of that article
31 There was no evidence that the Grievor walved his rights
under art 26 3, and it is difficult to see how he could have
done so lnasmuch as there was no evidence to show that he was
made aware of his rights under that article
32 I do not regard the filing of the grievance on June 20, 1994
(Exhibit 2) and the receipt by the Grievor of wages, beneflts
etc during his suspension as precluding the Union from relYlng
on the breach of art 26 3 in connection with the grievance flled
on June 28, 1994 (Exhibit 3) following his discharge Fallure by
the Employer to adhere to its obligations under the provlsions of
art 26 3 affected not only the suspenslon but the subsequent
discharge It lS the possible benefit to be derived from the
presence of Union representation in relatlon to any dlsclpline
that might be lmposed that lS protected by art 26 3 and not Just
the more immediate result of the meeting the suspension imposed
by Exhibit 4 In fact, as it appears that the Grievor was going
to be glven Exhibit 4 no matter what happened at the meeting, it
was the aftermath of the meeting the ultimate dlscharge of the
Grievor on June 23rd that was more closely linked to what
transplred at the meeting As has already been notd, it is
dlfflcult to believe that Mr Holmes would conduct an examinatlon
of the Grievor only for the purpose of furthering a criminal
(
56
investigation ln the presence of Sergeant Crockford It is more
probable that Mr Holmes asked quetions of the Grievor prlmarlly
for the purposes of the Employer to see if discipline should be
imposed, and Sergeant Crockford asked questions of the Grievor
for the purposes of the criminal investigation
33 Once the Employer held the meeting of June 13, which it was
not requlred to do, it was the ultimate penalty of discharge that
was directly related to that meeting And lt was the discharge
that was affected by the failure to honour the substantive right
of the Grlevor
34 While there may be a certain futillty to this exerClse, in
that the Grlevor may again be discharged by the Employer, thlS
tlme following the requirements of the collectlve agreement, I
agree wlth what was said in the Riverdale Hospital and VS
Servlces Ltd. cases by Professor Brandt concerning a grlevor,
whose termlnation has been declared void ab lnitio because of a
failure to follow the requirements of an article to the same
effect as art 26 3, being subject to the possiblllty of belng
discharged for the same actions, however, in accordance with the
requirements of the collective agreement This is not a case
where I should not reinstate the Grievor, as was suggested by
counsel for the Employer Accordingly, lt lS my award that the
Union's objectlon is upheld, and I find the disciplinary action
taken by the Employer in discharging the Grievor on June 23, 1994
57
was void ab initio The Grievor will therefore be reinstated to
his former position with the Employer without loss of seniority
from that date he was dlscharged
30 I have a problem, however, with awarding the Grievor
benefits and compensation from the date of his being discharged
This is because of the failure of the TJnion, until May 25, 1995,
to alert the Employer of its intention to rely on the failure to
comply with art 26 3 as a basls for making an application at the
commencement of the hearing on June 5, 1995 to have the
discipline declared void ab initio It is one thing to find that
the claim was subsumed in the grievance See Alcan Wlre and
Cable, above, at p 10, and that it can therefore be raised at
the hearing It is quite another thing to say that relief should
always be related back to the time of the discharge Ibld. at
p 11
In the case of a grievance that that has proceeded through
the three stages of the grievance procedure, it would be expected
that the issue relating to the Employer's failure to comply with
the provlsions of art 26 3 would, at some point in the
procedure, have been raised by the Union In this case, in the
absence of prior notification by the Union, I find that the
Employer only knew of the lssue on May 25th Because it was not
lnformed of the issue before me untll that date, it was deprived
of the opportunity to consider its posltion in the llght of the
58
lmpllcations that were raised for the flrst time on May 25th If
lt had the opportunity to do so during the normal functlonlng of
the grlevance procedure, lt could have acknowledged its fallure
to comply wlth art 26 3 at minimal cost and then proceeded to
dlscharge the Grievor in compliance with the requirements of the
collectlve agreement, as Mr Drmaj suggested could be done In
raising this possibilty, I am not saying that such an action
would necessarily succeed
If the Union had promptly raised the issue at an earlier
point in time, as it should have, and the Employer had malntalned
its position, I would have had no problem with awardlng
compensation to the Grievor from the date of hlS discharge
However, ln the circumstances before me, it would be unfair to do
so, and I award compensatlon and beneflts only from the date of
notiflcation (May 25, 1995 )
I wlll retain jurisdictlon to deal with the issue of
compensation resultlng from this award, if the partles are unable
to agree on the amount payable
I would only add that counsel informed me that they had been
unable to flnd any GSB case that dealt wlth the issue before me,
and I wish to thank them for thelr thorough and and well
presented submissions, which I have endeavoured to respond to
I
\
59
Dated at Toronto this 15th day of August, 1995
. ~ ~ ~
M R ~r's~y-/ -L.'~ q
Vlce Chairperson
ONTARIO EMPLOYES DE LA COURONNE
CROWN EMPL OYEES DEL'ONTARIO
1111 GRIEVANCE COMMISSION DE
,
SETTLEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST SUITE 2100 TORONTO ONTARIO M5G lZ8 TELEPHONE/TELEPHONE (416) 326-1388
180 RUE DUNDAS OUEST BUREAU 2100 TORONTO (ONTARIO) M5G IZ8 FACSIMILE'TELECOPIE (416j 326-1396
August 23, 1995
AMENDMENT
RE 809/94 OLBEU (LaHay) and the Crown in Right of Ontario
(Liquor Control Board of ontario)
Please replace page 58 of the original decision with the revised
page 58
Yours truly, ~J'4'
'/ -/l-g /J .m,\ CfJ
'I
A, vt!v~
L stickland
Registrar
LS/dbg
Encl.
58
implications that were raised for the first time on May 25th If
it had the opportunity to do so during the normal functioning of
the grievance procedure, it could have acknowledged lts failure
to comply with art 26 3 at minimal cost and then proceeded to
discharge the Grievor in compliance with the requirements of the
collective agreement, as Mr Drmaj suggested could be done In
raising this possibilty, I am not saying that such an action
would necessarily succeed
If the Union had promptly raised the issue at an earlier
point in time, as it should have, and the Employer had maintained
its position, I would have had no problem with awarding
compensation to the Grievor from the date of his discharge
However, in the circumstances before me, it would be unfair to do
so, and I award compensation and benefits only from the date of
notification (May 25, 1995)
I will retain jurisdiction to deal with the issue of
compensation resulting from this award, if the parties are unable
to agree on the amount payable
I would only add that counsel informed me that they had been
unable to find any GSB case that dealt with the issue before me,
and I wish to thank them for their thorough and and well
presented submissions, which I have endeavoured to respond to
I
I
59
Dated at Toronto this 15th day of August, 1995
. ~ ~ L
M R ~r's~y _/ L'~ :;j-
Vice Chairperson