HomeMy WebLinkAbout1996-0570GIANNOU97_05_08
ONTARIO 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 jZ8 TELEPHONE/TELEPHONE (418) 328-1388
180, RUE DUNDAS OUEST, BUREAU 2100, TORONTO (ON) M5G 1Z8 FACSIMILE/TELECOPIE (418) 328-1398
GSB # 570/96
OPSEU # 96D619
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Giannou)
Grievor
- and -
the Crown in Right of Ontario
(Management Board Secretariat)
Employer
BEFORE D.J.D Leighton Vice-Chair
FOR THE N Luczay
GRIEVOR Grievance Officer
Ontario Public Service Employees Union
FOR THE L Marvy
EMPLOYER Counsel
Legal Services Branch
Management Board Secretariat
HEARING December 11, 1996
INTRODUCTION
Ms Anna Giannou was working as an office products clerk at the Office
Administration 6 level, Management Board Secretariat, when she received a surplus
notice on August 16, 1995 with a layoff date of February 16, 1996 Her position along
with eight others in the Branch was declared surplus in accordance with Section 22(4)
of the Public Service Act (the Act) The notice of surplus provides in part
The government is implementing a series of strong measures to control
the size of the public debt The Secretariat like other ministries is
reviewing its areas of business to determine those that might be
downsized or eliminated to meet the government s savings target
planned for this fiscal year
Divisional Support Branch is one of several areas within Management
Board Secretariat which will be impacted as a result of these reviews
The resulting change in business direction has caused us to declare
your position of Office Products Clerk at the Office Administration 6 level,
surplus to the government's needs, effective August 16, 1995 This is not
a reflection on your performance or that of your colleagues
On September 6, 1995 Ms Giannou informed her employer that she was resigning
from the Ontario Public Service and taking II option A" which entitled her to the
following' $3,000 education fee, two weeks salary for each year's service to a
maximum of 12 weeks, and one week's salary for each year of service On April 29,
1996 she filed a grievance with the Grievance Settlement Board (the Board) claiming
unfair layoff and requesting reinstatement.
At the outset of the hearing into this matter, Counsel for the Employer, Mr
Marvy, raised two preliminary motions to dismiss the grievance as inarbitrable 1) the
grievance was not timely filed, and 2) the Board has no jurisdiction to review a Section
22(4) release from employment when the union has not alleged any bad faith by the
Employer
Evidence was presented for the timeliness motion. However both parties
agreed to put the timeliness motion aside until the Board ruled on the preliminary
jurisdictional motion.
2
.-- Counsel for the Employer argued that this Board has no general jurisdiction to
review a release from employment under Section 22(4) of the Act He argued that for
the Board to take jurisdiction the release must be contested and the union must allege
bad faith. Mr Marvy gave notice to the Union that he would raise this motion at the
hearing and asked for particulars of the grievance which alleges only "unfair layoff
Particulars were not provided, but it is clear that the grievance is based on the
Grievor's understanding that someone else or others are doing her job Counsel for
the Employer argued that for the purposes of this motion the Board could take it that
100% of her job had been dispersed although, in reality, Counsel argued that it is
approximately 65% In order for this Board to take jurisdiction and review this release
there must be an allegation of bad faith. Although Counsel asked for particulars,
there has been no particulars alleging that the Employer acted in bad faith in making
the decision to release the Grievor, nor has there been an allegation of a breach of
the collective agreement.
Counsel for the Union agreed that Section 22(4) of the Act applied in this case
Mr Luczay argued that the Grievor's duties have not disappeared, therefore
management's exercise of its powers under Section 22(4) was not proper Thus it was
a dismissal for cause Counsel argued further that the Grievor s duties have not
disappeared although the surplus letter noted that the position was going to be
abolished. He argued that the issue then is whether or not the facts will show if the
position was rightly abolished. By proceeding to hearing on the merits it will be
shown that the exercise of management rights by the Employer was unreasonable
Addressing the issue of providing particulars, Mr Luczay stated that the nature
of the grievance was presented at stage 2, and therefore particulars were provided
then. Counsel argued that the bad faith may be the misrepresentation that the job
had disappeared The Union conceded that they have the onus to prove that the
release was not bonafide Counsel argued that the only bonafide release under
: Section 22(4) is for a shortage of funds, or that the position is eliminated. Further it is
bad faith to misrepresent that the position is no longer needed when the work is still
being done
3
In reply, Counsel for the Employer argued that the position had been abolished
and the letter informing the Grievor of her release evidences the position was
abolished. Counsel argues that it is immaterial that some or part of her duties are
being continued. The fact is that the position has been abolished. Counsel argued
that Union Counsel was equating abolishing the position with abolishing the duties
which is not necessarily so
DECISION
Having carefully considered the submissions of the parties, I have decided to
dismiss the grievance There is no dispute between the parties that a release from
employment pursuant to Section 22(4) of the Act is not generally reviewable by the
Board.
22(4) A deputy minister may release from employment in accordance
with the regulations any public servant where he or she considers it
necessary by reason of shortage of work or funds or the abolition of a
position or other material change in organization.
However, if there is an allegation that the release was not bonafide, or was a
disguised dismissal, this Board has the jurisdiction to review the grievance as held in
Leslie, 80/77 (Adams)
The Union conceded in argument that they have the onus to prove that the
release was not bonafide However, the Union has not made any allegations of bad
faith. The Union submits that some of Ms Giannou s job is still being done, and
nothing more As Counsel for the Employer argued, even if this Board was to take it
that 100% of the Grievor's job was reallocated to others, that is not evidence of bad
faith. Further, there was no allegation that there was a hidden agenda or any bad
faith with regard to the Grievor as an individual. There was nothing to suggest that
Ms Giannou was anything but an excellent employee Her surplus letter made it
clear that she should not take her release from employment as a reflection on her
performance, and noted that it was no reflection on any of her colleagues who were
4
-- also surplused at the same time in the Divisional Support Branch of the Management
Board Secretariat.
Cases cited by Union Counsel were of no assistance It is clear that this Board
has taken jurisdiction over grievances, where surplused employees grieved their
release pursuant to Section 22(4) of the Act In Babb et a1., 1173/88 (Wilson) the
grievors' work had been transferred from one ministry to another branch within
government The Board held that the work was transferred to a new ministry and the
grievors were entitled to move with the work. This is not the case before me Because
of the widespread government cutbacks and general downsizing the Grievor s job
was eliminated along with eight others The work of the branch was reorganized.
There is nothing to suggest any bad faith in the decision to reorganize and eliminate
the Grievor's position. Further, the union made no claim that the collective agreement
had been breached - specifically that Art. 24 was not applied properly
In Garrison 1229/94 (Kaplan), where an unclassified employee grieved that he
was denied a promotion, the Board held that the grievance was not arbitrable unless
the union alleged that the employer acted in bad faith. Vice-chairperson Kaplan
dismissed the grievance on the preliminary motion of the employer because there
was no basis to conclude that the allegations of bad faith were any more than that -
allegations The substance of what was allegedly unfair, even if proven, would not
amount to bad faith. The Board noted in conclusion.
In the normal course of events, claims of this kind should be made in
advance of the hearing and should be accompanied by detailed
particulars which would establish, if proved, bad faith in the running of
the competition or in its result
The issue of alleging bad faith with some particularity was addressed by the
Public Service Grievance Board in Handlarski 0027/92, when a management
employee claimed that his release pursuant to Section 22(4) of the Act was made in
bad faith. Mr Handlarski argued that because some of his job, accounting policy,
was still being done by the employer, his release was not valid. The Board in
Handlarski held that even if the grievor s allegations had been prov 3n, they did not
5
- amount to bad faith. The Employer's Counsel in this case requested particulars well
before the hearing and put the Grievor on notice that without particulars of bad faith
he would seek dismissal. Since no particulars of bad faith were alleged, the Board
dismissed the grievance
Likewise in the case before me, Counsel for the Employer requested particulars
in writing, in advance of the hearing He put Union Counsel on notice that without
particulars he would seek dismissal of the grievance No particulars have been
provided except that the Grievor believes parts of her job are being continued at the
Branch. Union Counsel has argued that by providing a hearing on the merits it will be
shown that the exercise of management rights here was unreasonable, but he does
not allege why or suggest what evidence he would call to prove bad faith. Counsel
argued that bad faith could be the misrepresentation that the job had disappeared -
when it has not But the Union does not dispute that the position has been eliminated
only that some functions of the position remain. Thus without some detailed
particulars, which would establish, if proved, bad faith in the decision to release the
Grievor, the grievance must be dismissed.
Dated in Toronto this J {.<., day of /1/:] / , 1997
I
-~._- \
~
r ~ /"
- ~./
. <-." \ '-'- ~c; C-""Cu~
" / - .
--~ ---- I /
./
D J I5 Leighton, Vice-Chair
6