HomeMy WebLinkAbout1996-0099REALE97_01_21
OwrARIO EMPLOYES DE LA COURONNE
CROWN EMPLOYEES DE L'ONTARIO
1111 GRIEVANCE COMMISSION DE
SETTLEMENT ,
REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST, SUiTE 2100, TORONTO ON M5G 1Z8 TELEPHONE/TELEPHONE (416) 326-1388
180, RUE DUNDAS OUEST. BUREAU 2100, TORONTO (ON) M5G 1Z8 FACSiMiLE/TELECOPiE (416) 326-1396
GSB # 99/96, 606/96
OPSEU # 96C434, 96F196
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Reale)
Grievor
- and -
The Crown in Right of ontario
(Ministry of the Solicitor General &
Correctional Services)
Employer
BEFORE N Dissanayake Vice-Chairperson
FOR THE M Bevan
GRIEVOR Grievance Officer
ontario Public Service Employees Union
FOR THE A Gulbinski
EMPLOYER Grievance Administration Officer
Ministry of the Solicitor General &
Correctional Services
HEARING December 6, 1996
January 6, 1997
---.-..-
2
DECISION
This is a grievance filed on February 13, 1996 by Mr Marc
Reale alleging that he was unjustly suspended without pay In
order to put this grievance in context, it is necessary to review
the factual background which is not in dispute in any material way
The grievor was employed as a corrections officer at the
Hamilton Wentworth Detention Centre (HWDC) with over 6 years of
service On May 4, 1995, Ms Marion Jones, Acting Deputy
Superintendent (operations) of the HWDC, had occasion to interview
an inmate about an unrelated matter During the interview the
inmate made certain allegations against the grievor and another
corrections officer Ms Jones made her superiors aware of the
allegations which related to inappropriate sexual behaviour with
female inmates At the request of the employer, the ontario
Provincial Police (OPP) commenced an investigation sometime later
in May On December 15, 1995, the OPP charged the grievor with 3
counts of sexual assault and 5 counts of breach of trust He was
arrested and remanded in custody On December 18, 1995 he was
granted bail at $ 10,000 with surety The judge imposed twelve
conditions of bail including the following
(1) "Have no communication directly or indirectly with
any employee or ex-employee of the Ministry of
Correctional Services except through his counselor his
agent excluding his union reps and Franko DiMarcantonio "
(2) "Have no contact directly with any inmate or exinmate
of the H W Detention Centre, Niagara Regional Detention
Centre or Guelph Correctional Centre " and
3
(3) "stay out of Hamilton except for court or to see
counsel "
On January 26, 1996 certain additional charges of a similar
nature were laid against the grievor The charges ultimately went
to trial before judge and jury and on October 10, 1996 the grievor
was acquitted on all of the charges
While the foregoing criminal justice process was underway, the
employer took certain actions against the grievor at the workplace
The day the grievor was first charged and arrested, December 15,
1995, Ms. Jones suspended the grievor for 5 working days by issuing
the following letter
Please be advised that under the authority delegated to
me by the Deputy Minister/Superintendent pursuant to
section 22(1) of the Public Service Act of Ontario, you
are suspended from duty without pay for five working days
effective this date, pending an investigation During
this period you are not to enter the building unless
authorization has been given by the Superintendent or
myself.
A meeting to discuss the following allegations has been
scheduled for Tuesday, December 19, 1995 10 00 hours at
WeIland Probation and Parole Office, 2nd Floor, 9 Burgar
Street, WeIland
1 That you did engage in sexual advances/acts against
Ministry clients while employed as a Correctional Officer
at the Hamilton-Wentworth Detention Centre
2 That you breached the trust afforded to you in your
position as a Correctional Officer
3 That you breached Ministry policy by your involvement
with inmates and relatives of inmates while employed as
an employee of the Ministry of the Solicitor General and
Correctional Services
4
4 That you were absent from your post and in other
areas of the Institution without authorization, contrary
to Ministry policy
5 That you supplied contraband to inmates while on duty
as a Correctional Officer
As this meeting may result in disciplinary action, you
may have an employee representative of your choice
present You are further advised that, should you choose
not to attend, the allegations will be heard in your
absence
This suspension was continued for 5 further working days by
the following letter dated December 18, 1995 issued by Ms Cathy
Morris, Deputy Superintendent Services
Pursuant to the letter dated December 15, 1995 signed by
Ms M Jones, Deputy Superintendent (A) , I am advising you
that, by mutual consent, the meeting scheduled for
December 19, 1995 at 10 00 hours in WeIland P&P Office is
cancelled
I am further advising you that you will continue to be
suspended without pay pursuant to section 22(1) of the
Public Service Act for another period of up to five (5)
days pending further investigation This suspension
period will be in effect up to December 31, 1995
We will advise you further regarding this matter
The grievor's suspension without pay was further extended by
three 20 day periods by the following letters issued by Ms Pauline
Radley, Regional Director, which were dated December 28, 1995,
February 7, 1996 and March 7, 1996 respectively
Pursuant to the letter dated December 18, 1995 to you
signed by Ms C Morris, Deputy Superintendent, Services,
Hamilton Wentworth Detention Centre, please be advised
that as Regional Director, Western Region, I am hereby
suspending you without pay for a further 20 working days
commencing January 1, 1996 This suspension period will
be in effect up to February 10, 1996
5
Pursuant to my letter dated December 28, 1995, please be
advised that I am hereby suspending you without pay for
a further 20 working days This suspension period will
be in effect up to March 8, 1996
Pursuant to my letter dated December 28, 1995, please be
advised that I am hereby suspending you without pay for
a further 20 working days This suspension will be in
effect up to April 9, 1996
It is clear that in this manner, the grievor's suspension
without pay which commenced on December 15, 1995 was continued
uninterrupted until April 9, 1996 for a total of 70 working days
At the expiration of the grievor's last period of suspension
wi thout pay, he was dismissed effective April 10, 1996 by the
following letter dated April 10, 1996 issued by the Superintendent
of the HWDC, Ms Diane Doherty
This correspondence is written pursuant to a letter dated
March 7th, 1996 from Regional Director Ms P Radley
authorizing the continued suspension for 20 working days
without pay effective until April 9th, 1996
This letter will serve as official notice that, effective
immediately, you are being dismissed for cause pursuant
to section 22 (3) of the Public Service Act This
decision is based on your conduct being incompatible with
your position as a Peace Officer and for matters related
to serious breaches of trust You have the right to
grieve this decision in accordance with provisions of the
Collective Agreement
You are requested to make the necessary arrangements
through your employee representative to return all issued
Ministry clothing/property, including your Ministry I D
card, keys, uniform and Standing Orders, at the earliest
opportunity to Mr J Boychuk, Staff Training Officer
I
6
The grievor had filed the instant grievance on February 13,
1996 FOllowing his dismissal, he filed a further grievance
alleging dismissal without cause
Following the grievor's acquittal, the union and the employer
reached a settlement whereby it was agreed that all discipline
imposed on the grievor stemming from the charges in question would
be rescinded The grievor was reinstated in his job, and
compensated for all lost wages from the date of dismissal April 10,
1995 to the date of reinstatement That for all intents and
purposes settled the grievor's discharge grievance However, the
employer has continued to refuse to compensate him for the period
of suspension - December 15, 1995 to April 9, 1996 - which preceded
his dismissal In the instant grievance the union seeks an order
that the grievor be fully compensated for lost wages and benefits
during that period
The employer's defence is two-fold Firstly, it is submitted
that the suspensions were a valid exercise of the authority
conferred by S 22(1) of the Public Service Act In the
alternative, it is contended that there was just cause for the
suspensions
7
The Authoritv under Section 22(1) of the Public Service Act to
suspend without pay.
section 22(1) provides
22 -(1) A deputy minister may, pending an investigation,
suspend from employment any public servant in his or her
ministry for such period as the regulations prescribe,
and during any such period of suspension may withhold the
salary of the public servant
sections 13(1) and 13(2) of the Regulations under the Public
Service Act read"
13 -1 (1) Where the deputy minister suspends a pUblic
servant from employment pending an investigation, the
period of suspension shall not exceed twenty working
days
(2) Despite subsection (1), where in the opinion of
the deputy minister, an additional period of time is
required to complete the investigation, the deputy
minister may renew the period of suspension for not more
than twenty working days in each case for such additional
periods as are considered necessary
The parties disagree in several respects as to whether the
suspensions without pay imposed on the grievor meet the
requirements of section 22(1) In addition, it is the union's
position that even if they did, that does not relieve the employer
from the requirement to prove "just cause" for penalizing the
grievor by denying him his pay
The union submits that S 22(1) contemplates an investigation
by the employer Ms Jones, during her testimony was of the view
8
that since the legislation does not specify any particular type of
investigation, but merely states pending "an investigation", any
pending investigation entitled the employer to suspend an employee
under S 22(1) Under cross-examination she took the position that
an investigation by Revenue Canada of an employee's tax declaration
or an investigation by the College of Nurses into the professional
conduct of a nurse employed in the OPS, would fit within the
provision The Board strongly disagrees The authority to suspend
under S 22(1) pending an investigation is a specific and peculiar
power conferred on the employer for a specific purpose This is a
recognition that the employee's presence in the workplace during an
investigation may have a negative impact on the operations and also
tend to hinder the employer's investigation section 13(1) of the
regulations limits the suspension to twenty working days. section
13(2) permits an extension of the suspension for further periods of
20 days each, but only if "an additional period of time is required
to complete the investigation" and for additional periods "as are
considered necessary" The legislation thus contemplates that if
the employer elects to suspend an employee pursuant to S 22(1),
the investigation will proceed and be completed in an expeditious
manner If someone other than the employer is carrying out the
investigation, that person or body would not be subject to S 22(1)
or the regulations The employer would not have any control over
the speed with which it is carried out Furthermore, it is the
employer that must decide whether further and additional periods of
suspension are required and/or necessary It is hard to imagine
9
the legislation contemplating that the employer will make these
judgements, when the investigation is being conducted by a third
party over whom the employer had no control Therefore, the Board
agrees with the union that section 22(1) contemplates an
investigation undertaken by the employer The Board adopts the
statement of Vice-Chair Samuels in Re Miller, 2613/87 at p 9 that
"In order to justify a suspension under Section 22(1) of the Public
Service Act, a Deputy Minister has to launch an investigation, and
the suspension can only be for as long as is legitimately and
reasonably needed to carry out the investigation "
The next issue, therefore, is whether the employer did an
investigation during the grievor's period of suspension The
Superintendent of the HWDC, Ms Doherty attempted to have the Board
believe that in addition to the opp investigation, a parallel
internal investigation was undertaken by the employer The Board
does not find that evidence to be credible While Ms Doherty
depicted Ms Jones' role as that of an investigator and testified
that Ms Jones was instructed to investigate the allegations
against the grievor and report to her, all of the other evidence
contradicts that position Ms Jones, clearly and unhesitatingly
testified that her role was not that of an investigator Her role
was simply to liaise with the opp investigators and to facilitate
their needs such as arrange for employee and inmate interviews and
provide Ministry documents such as work schedules, logs and
incarceration records, as requested by the opp She was
10
categorical that she did not interview any employee or inmate and
that she did not initiate any action on her own She clearly
testified that she did not see herself as an investigator and
denied that Ms Doherty had instructed her to investigate Ms
Jones made no notes or records of any involvement she may have had
in an investigation No written report of any findings were ever
created by her Furthermore, during the testimony it was evident
that Ms. Jones had little awareness as to the details of the
specific allegations made against the griev.or The Board has no
hesitation concluding that apart from the opp investigation, no
other investigation was conducted by the employer
The employer made the alternate argument that in any event the
investigation conducted by the opp was in fact an internal
investigation by the employer This assertion was based on the
fact that the OPP and the Correctional Services were under the same
Ministry Indeed counsel argued that an opp investigation of an
employee in any Ministry, would qualify as an investigation by the
employer because the OPP and the all the ministries are part of the
same ontario Government The Board does not agree that the OPP
investigation into the alleged criminal conduct of the grievor, is
an investigation by the employer for purposes of S 22(1) of the
Public Service Act. It is true that the OPP and the correctional
services are within the same Ministry of Solicitor General and
Correctional Services Thus in a technical or corporate sense they
are part of the same entity However, because of that corporate
11
link, an investigation by the opp does not become an internal
investigation by the Ministry It is common knowledge that the opp
is in the business of investigating alleged violations of the
Criminal Code no matter where it occurs within the Province of
ontario Its investigations are not confined to alleged offenses
within the Ministry of Solicitor General and Correctional Services
or the Ontario Public Service If deemed appropriate, the OPP will
investigate any alleged offence within ontario The employer did
not and was not in a position to demand that the OPP investigate
the allegations against the grievor That was a decision the opp
made in accordance with its own policies and priorities More
importantly, the employer was not in a position to instruct the OPP
as to what investigations were to be done and when they were to be
done. The employer was not in control of the OPP investigation
The evidence indicates that the OPP made its own judgements in
these matters just as it would in any other case There is nothing
in the evidence to suggest that the OPP treated this investigation
any differently than any other investigation it undertakes in the
province or that it gave this investigation any special priority
because it involved an employee of the Ministry The rationale
behind the need for an investigation by the employer as a condition
of utilizing S 22 (1) is that the employer must remain in control
over the investigation, particularly with regard to the expedition
with which it is carried out This is a recognition that the
employer's right to carry out the investigation unimpeded by the
grievor's presence in the workplace, must be balanced with the fact
-
12
that an employee, who has not been found guilty of any wrong-doing,
has his income withheld for the duration of the investigation
Where the employer is not in control, there is no way of enforcing
the expedition of the process contemplated by the legislation
Thus in Re Fish, 634/83 (springate) at p 13 the Board said
"Presumably this authority [under S 22(1)] is given to a Deputy
Minister because in some instances it is inappropriate to allow an
employee to remain in his position while allegations against him
are being investigated" and added "A suspension that was initially
justified may cease to be so if the investigation is not pursued
with due diligence "
For all of the above reasons, the Board concludes that the
suspension of the grievor from December 15, 1995 to April 9, 1996
was not imposed pending an investigation as contemplated by S
22(1) of the Public Service Act, and therefore was not a proper
exercise of the authority under that provision
In view of that result, it is not necessary for the Board to
consider the union's alternate position that even if the
suspensions were a proper exercise of the power under S 22(1) the
employer was obliged to prove just cause to deny pay
13
Suspension for Just Cause
The Board next turns to the employer's alternate argument that
even if the suspension in question was not justified under S 22(1)
of the Act, the employer had just cause for the suspension
The employer did not attempt to prove just cause in the form
of some culpable conduct on the part of the grievor, which would
have justified the suspension It did not attempt to prove the
allegations of sexual assault and breach of trust, eventhough two
members of management testified that despite the acquittal by the
jury, personally they believed that the grievor was guilty of at
least some of the alleged offenses In the initial letter of
suspension dated December 15, 1995 the employer made a number of
allegations against the grievor of breaching Ministry policy by his
involvement with inmates and relatives of inmates, by being absent
from the post and in other areas of the institution without
authorization and by supplying contraband to inmates There was no
evidence whether these allegations were ever investigated. In any
event, the employer did not attempt to prove these allegations
before the Board However, the employer did argue that there was
just cause in several other forms
The employer submitted that the bail conditions imposed on the
grievor, specially the 3 conditions mentioned above at p 2-3 of
this award, left the employer with no choice but to suspend the
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14
grievor, because the bail conditions rendered the grievor
"unavailable for work" That was said to constitute "just cause"
This position is not substantiated by the evidence Three
witnesses testified on behalf of the employer The Superintendent
Ms Doherty when asked why the grievor was suspended answered
"because of the investigation by Ms Jones" When asked in cross-
examination whether the grievor would have remained at work if not
for the bail conditions she did not say that the bail conditions
prevented the employer from continuing to employ the grievor, or
that but for the bail conditions he would not have been suspended
Instead she replied that she had not given it much thought, and
went on "may be in a non-correctional role I don't know" She
stated that she did not know why Ms Radley felt it was necessary
to suspend the grievor for 3 subsequent 20 day periods Ms Radley
did not testify
Ms Marion Jones, issued the initial 5 day suspension At no
time during her testimony did she state that the bail conditions
had anything to do with those suspensions When her own counsel
showed her the initial letter of suspension and asked why she
issued it, she replied "On December 15 Mr Reale was arrested in my
office and charged I was not in my office at the time I was
outside Then I suspended him This is the letter I gave "
15
Mr Barry Thomas, Senior Human Resources Consultant with the
Ministry, signed two of the letters of suspension on behalf of Ms
Radley When asked what input he had into the decision to issue
those letters, he replied "MY input was that given the nature of
the bail conditions I felt strongly that the employee was not
available for work" Under cross-examination Mr Thomas took the
position that since the grievor was ultimately exonerated by the
verdict of the jury, the employer would normally have been obliged
to compensate the grievor for lost wages and benefits for the
period of suspension However, he stated that the employer did not
have to compensate the grievor in this case because the existence
of the bail conditions made the grievor "unavailable for work".
However, at the same time Mr Thomas testified that even if the
bail conditions had not been imposed, it would have made no
difference and that the employer would still have suspended the
grievor without pay because of the seriousness of the charges He
said that once the charges were laid, he did not at any time
consider whether it was possible to continue the grievor's
employment
The Board is convinced that the bail conditions were not in
fact a consideration for the grievor's suspension There is no
evidence to suggest that it in fact played any role in the ultimate
decision The suspension was commenced by the letter dated
December 15, 195 Each subsequent letter (set out above) in
continuing the suspension refers to the previous letter Therefore
16
all of the letters ultimately refer back to the initial letter It
is significant to note that the letter of December 15, 1995 clearly
states that the suspension was "pursuant to section 22(1) of the
Public Service Act, pending an investigation " None of the
subsequent letters change that grounds to suggest that the
suspension was now in the exercise of the employer's management
right to suspend without pay for cause
If there is any doubt about the fallacy of the employer's
argument, that is removed by examining the timing of the employer's
initial letter of suspension and of the imposition of the bail
conditions The evidence is that the employer made the decision to
suspend the grievor without pay on December 14, 1995, as soon as it
found out that the opp would be charging the grievor the following
day The letter of suspension was issued and the suspension became
effective on December 15, 1995 It is undisputed that the bail
conditions did not come into existence until December 18, 1995
Thus at the time the suspension without pay was commenced, the
employer could not have known what bail conditions, if any, would
be imposed on the grievor It is simply not possible that the bail
conditions could have been a consideration in the employer's
decision to remove the grievor from the workplace None of the
subsequent letters indicate that the grounds or reasons for the
suspension had changed since the suspension commenced The Board
is of the view, that if the employer intended to change the grounds
from a suspension pending an investigation under the authority of
17
under S. 22(1) of the Public Service Act, to a suspension for just
cause based on the grievor's unavailability for work, it had an
obligation to state that If that had been done, the grievor could
have, if he so wished, attempted to have the conditions of bail
amended to allow his employment to continue Contrary to the
employer's argument, it is not, in the Board's view, reasonable to
expect the grievor to go to the effort and expense of attempting to
have the bail conditions amended, when the letters of suspension
clearly state that the suspension was imposed, not because of the
grievor's unavailability but because of the pending investigation
In those circumstances, there is no reason for the grievor to
believe that amending the bail conditions would make any
difference In any event, it should not come as a surprise that
the Board would expect any employer purporting to discipline an
employer for cause to inform the employee of the grounds relied
upon as cause An employer is not entitled to raise grounds
constituting just cause for the first time at arbitration
For those reasons, the Board finds that the bail conditions
did not constitute just cause for the suspension imposed on the
grievor
The employer further submits that there was just cause for the
grievor's suspension in that his presence in the workplace pending
the investigation had a serious negative impact on the workplace,
and particularly on its workforce This reliance on just cause was
18
also raised for the first time at arbitration The letters of
suspensions directly or indirectly do not indicate that the
employer was relying on anything other than the authority to
suspend under S. 22 (1) of the Public Service Act
What is beyond dispute today is that absent some overriding
statutory authority or specific provision in the collective
agreement to the contrary, an employer has the onus of satisfying
a board of arbitration that just cause existed for the imposition
of any discipline At the same time, arbitrators have recognized
that under certain circumstances an employer may have just cause to
suspend an employee without pay pending the outcome of criminal
charges, even if ultimately the employee is exonerated of any
wrong-doing The seminal case on this issue is Re Phillips Cables
Ltd. , (1974) 5 LAC ( 2d) 274 (Adams)
At pp 274-275, the arbitrator described the competing
interests that must be balanced
The question is a most difficult one because
arbitrators are asked to choose between two very
legitimate but conflicting interests
One interest is that of the company to operate its
activities in an efficient and orderly way An employee
charged with a serious crime, particularly if that crime
is alleged to have been committed against the company,
can be qualitatively distinguished from other employees
His existence in the work force can cause real hardships
to both the employer and other employees For example,
a man charged with rape and assault causing bodily harm
might encounter difficulties in dealing with a company's
customers or its employees The customers and employees
may prefer not to deal with the man until his status has
19
been determined by the Courts and this may have serious
economic consequences for the employer
Consider the fOllowing analogy. Suppose an employee
exhibits all the symptoms of a rare and very contagious
tropical disease and it takes months to assess whether he
has actually contracted it Should his fellow employees
bear the risks of contagion until the scientific fact is
determined? And should the employer economically support
this employee if one concludes that he should be taken
out of the work force pending an official determination?
The employer argues that he did not cause this misfortune
and therefore he should not be forced to share in it
That is one interest-the employer's
The other compelling and conflicting interest is
that of the innocent employee An employee charged with
a crime (or subject to the risk of having contracted a
very harmful disease) has an interest in maintaining his
source of livelihood until his status has been accurately
and fairly determined Moreover, the employee who is not
convicted of the crime (or found not to be subject to the
disease) can, with hindsight, point to this fact - the
fact that, empirically speaking, he was not a risk to his
fellow employees or the company He can claim that he
was mistakenly branded as a potential criminal or medical
risk Therefore, because he is completely innocent and
free of any wrong doing, he argues that the company must
bear the risk of his innocence if it wants to suspend
him
At p 276, the arbitrator went on to state
Because of the innocent employee's compelling
interest in maintaining his livelihood, should an
employer not have to adduce evidence justifying why the
employee cannot continue to work in spite of the charge
looming over his head? Are customers likely to be
affected? Can he not be closely supervised? will fellow
employees justifiably object to his presence? What are
the circumstances surrounding this charge? Could the man
be transferred to some less responsible job for the
interim? Why must the company await the outcome of the
criminal proceedings? Is important evidence only at the
disposal of the police? Would immediate disciplinary
action be premature and prejudice the individual's
criminal trial All of these factors appear very
relevant to us, and a review of the reasoning of other
boards of arbitration does not suggest otherwise
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At P 280 the arbitrator observed
This board accepts the fact that an employer's needs
may have to prevail over an employee's interest but only
if some substantial business reason is present Because
both interests are worthy of protection, it is only by
restricting the employer's interest to that which is
clearly essential that one can rationally and equitably
choose it over an innocent employee's claim to income
continuity
Following an extensive review of the case law, at pp 282-284,
the arbitrator setout the following four principles that should
govern
In the first place, the board accepts the general
principle that in some circumstances a company can
suspend an employee charged with a criminal offence
pending its outcome in the criminal courts The
presumption of innocence has its purpose and relevance
grounded in the substantive area of criminal law. It is
not a doctrine that can be unqualifiedly transported to
the context of labour relations Many situations can be
envisaged where a work-related criminal charge against an
employee will substantially undermine his effectiveness
in the work environment. And in these same circumstances
it may not be fair to impose any financial obligation
upon an employer whether the employee eventually either
escapes the charges or does not
Secondly, while recognizing this interest of an
employer, the board is also conscious of the competing
interests of the innocent employee who is tragically and
mistakenly the victim of a criminal charge To await the
outcome of a criminal charge in the Courts without
benefit of employment in the interim can often render a
subsequent acquittal quite meaningless
Thirdly, the board believes that this interest of
the innocent employee is the basis to the principle that
the company must not have played a substantial role in
the investigation leading to the criminal charge If it
has, it presumably possesses sufficient evidence to
discharge the employee immediately without waiting for
the determination of the criminal Courts In choosing
not to do this, it has subjected the employee to an
unnecessary f inancial penalty and must therefore
compensate him when that process fails to convict
21
Finally, it is this same employee interest which
requires that the existence of the criminal charges must
reasonably give rise to a legitimate fear for the safety
of other employees, or of property, or of substantial
adverse effects upon business It is not enough that the
charges be sufficiently work-related so that if proven
they will support the discharge of the employee This
cannot be the test because the charges have not yet been
proven The employee cannot be treated as if he-has
committed the offence Rather, he is labouring under the
risk of his guilt, and so may be his employer and fellow
employees Accordingly, the company must establish that
this risk of guilt presents a substantial and immediate
hardship to itself or to its workers, and that this
hardship cannot practicably be met by anything other than
the suspension of the employee This requirement
accommodates situations where workers or customers refuse
justifiably to deal with the employee, or where he cannot
be transferred or watched more closely pending an
official determination of his status
To meet this requirement the company will have to
investigate the criminal charges to the best of its
abilities in order to assess the extent of this risk of
conviction and thereby assess what can be reasonably done
in the circumstances Therefore, to this degree, the
board agrees with Mr Fitzpatrick's suggestion that an
employer has an obligation to investigate the charge
The substantial business detriment can only be
established by assessing the risks of conviction, and
this assessment requires an investigation into the
circumstances surrounding the charge
How do those principles apply to the facts facing the board?
After a very careful examination, the Board has concluded that even
if the employer was entitled to raise these grounds of just cause
for the first time at arbittation, it does not meet the
requirements set out in Re Phillips Cables
Firstly, although the employer did not playa substantial role
in the opp investigation which commenced in May 1995 and led to the
laying of criminal charges on December 15, 1995, one of the 2 opp
22
investigators, detective constable Ms June Dobson conceded under
cross-examination that by December 15, 1995 when the grievor was
charged, the Police was confident that it had sufficient evidence
to obtain convictions on the charges laid against the grievor She
admitted that the opp would not charge anyone unless it had that
confidence She testified that at the time the charges were laid,
there was enough evidence which gave the Police "reasonable and
probable grounds" to believe that it could prove that the grievor
sexually assaulted the complainants She also specifically stated
that at the time she informed the employer that the Police believed
that it had enough evidence to obtain convictions on the charges
If the opp felt that the available evidence was sufficient to
obtain a conviction on the charges laid by proving the offenses
beyond reasonable doubt, that should also have been adequate to
convince the employer that there was sufficient evidence at that
point to dismiss the grievor Nevertheless, there is no evidence
to indicate that the employer made any attempt to obtain that
available information Instead it appears that the employer chose
to sit back and await the outcome of the criminal trial Having
chosen not to pursue the information that it knew was readily
available which would have enabled it to dismiss the grievor at
that point, (to paraphrase the language in Phillips Cables) the
employer subjected the grievor to an unnecessary financial penalty
and must therefore compensate him when the criminal process fails
to convict In the circumstances, the important interest of the
23
grievor, who after all was not found guilty of any wrong-doing at
the time, of continued employment and income, obligated the
employer to pursue the available information and decide the
grievor's employment status with expedition
Mr Thomas testified that at the end of January 1996, Ms
Radley received a copy of the crown brief prepared by the OPP, and
that in turn copies were provided to himself and Superintendent
Doherty. He testified that in discussion between Ms Radley, Ms
Doherty and himself, it was decided that the information contained
in the crown brief warranted the dismissal of the grievor without
waiting further for the outcome of the criminal trial. There is no
evidence whatsoever as to how the employer came upon the crown
brief Detective Dobson testified that she did not provide the
employer with a copy Furthermore, Mr Thomas did not testify as
to what specific information came to the employer's attention
through the crown brief, which was not previously available to it
The decision to discharge the grievor was made by Ms Doherty,
the Superintendent Throughout her testimony she did not even
mention the crown brief She certainly did not say that the crown
brief had anything to do with her decision to discharge the
grievor On the contrary, Ms Doherty testified that Ms Rodley
informed her that she had received certain information which
warranted the grievor's discharge She said that Ms Radley
informed her that she could not divulge the source of that
-~
24
information, and that she took Ms Doherty's word without
questioning her and dismissed the grievor
The most significant reason why the employer's claim of just
cause to suspend without pay pending criminal charges must fail is
the final principle enunciated in Re Phillips Cables As the Board
stated there, "the company must establish that this risk of guilt
presents a substantial and immediate hardship to itself or to its
workers and that this hardship cannot practicablY be met bv
anythinq other than the suspension of the employee." The Board
then went on to describe how an employer must establish this
To meet this requirement the company will have to
investigate the criminal charges to the best of its
abilities in order to assess the extent of this risk of
conviction and thereby assess what can be reasonably done
in the circumstances The substantial business
detriment can only be established by assessing the risks
of confliction, and this assessment requires an
investigation into the circumstances surrounding the
charges
There is absolutely no evidence that the employer made any
investigation at all into the circumstances surrounding the charges
against the grievor It made no assessment of the risk of
conviction or whether there were any alternatives to the suspension
of the grievor The Board refers back to the passage at p 276 of
the Phillips Cables award (see p 19 supra) There is no evidence
to suggest that the employer ever turned its mind to any of the
questions set out therein On the contrary, the superintendent
readily admitted that she gave very little thought to the
25
possibility of continuing the grievor's employment, merely because
the charges themselves were serious
The employer has adduced little or no evidence to establish
that the grievor's presence in the workplace would have caused i~
a substantial and immediate hardship The only evidence on this
issue was adduced through Ms Jones, Acting Deputy Superintendent
operations. She was asked during examination-in-chief whether the
pending charqes had any impact on the workplace The question was
not whether the presence of the qrievor in the workplace while the
charges were pending had any impact on the work place In any
event, she replied "When this type of criminal charges are pending
it has a great impact on staff" When asked how, she replied "They
are always trying to establish a professional relationship with
inmates When there are allegations like this, it undermines all
staff We had shift briefings and de-briefings to discuss what was
occurring and to instruct how to handle any fallout from the
inmates " When asked "What fallout", Ms Jones replied "They heard
on the news about the charges They tend to make derogatory
comments to staff, but the staff still has to behave
professionally Also we told the staff that if inmates come
forward with new allegations they have to be reported and
investigated." In cross-examination, Ms Jones was asked whether
she had any knowledge of any specific impact affecting staff as a
result of the charges She replied that there was one staff
member, a friend of the grievor, who allegedly was "going around
26
asking questions" However she agreed that this individual was
investigated and exonerated That was the extent of the employer's
evidence as to adverse impact Even this evidence relates not to
the impact of the grievor's presence in the workplace, but the fact
that the charges existed In other words, the adverse impact
referred to by Ms Jones would have resulted by the mere existence
of the charges, whether or not the grievor was at work
In any event, the impact referred to by Ms Jones cannot
reasonably be described as "substantial and immediate hardship",
which would justify overriding an innocent employee's right to earn
a living. Whatever hardship existed, the employer has not
established that "this hardship cannot practicably be met by
anything other than the suspension of the employee II In fact, the
evidence does not indicate that the employer ever turned its mind
to the considerations referred to in Re Phillips Cables such as
whether the grievor could have continued to work in spite of the
charges looming over his head, whether he could be closely
supervised or whether his co-workers would have obj ected to his
presence On the contrary the Superintendent testified that she
gave little thought to the possibility of continuing to employ the
grievor simply because the charges themselves were serious
Is it reasonable for the Board to assume, or to take "judicial
notice" , in the absence of any evidence, that the grievor's
presence in the workplace while charges were pending would cause
---------
27
substantial hardship to the employer or the grievor's co-workers?
I do not think so As Phillips Cables makes it clear, it is
incumbent upon the employer to establish that after conducting an
investigation Two of the three management witnesses readily
conceded that it was not uncommon for inmates to make up a lot of
false allegations Presumably this would also be known to the
grievor's co-workers Therefore, it is just as possible that his
co-workers would have been very sympathetic and supportive of the
grievor in the face of the charges There is simply no evidence
that any co-worker had any concern about the grievor remaining in
the workplace Even if inmates made derogatory comments to staff,
as Ms Jones said they were prone to do, there is no reason to
believe that such action on the part of inmates would have led to
undue or insurmountable hardship on the employer or its staff
Such a relatively minor problem does not override the right to earn
a living by an employee, who has not been found guilty of any
wrong-doing
For those reasons, the Board must conclude that the employer
has failed to establish just cause for the suspension without pay
imposed on the grievor
Since both grounds relied upon by the employer in
justification of the suspension have failed the grievor must be
redressed The employer is directed to fully compensate the
grievor for lost wages and benefits during the period of suspension
28
from December 15, 1995 to the date of his discharge The Board
records the agreement of the parties that the grievor would be
compensated for 2-1/2 weeks of the five week period during which
there was a strike by the employees in the OPS
The Board remains seized with jurisdiction to deal with any
disputes the parties may have in implementing this award
Dated this 21st day of January 1997 at Hamilton, ontario
~~~~ke
Vice-Chairperson