HomeMy WebLinkAbout1996-1662VILLELLA97_02_25
ONTARIO EMPLOYfs DE LA COURONNE
CROWN EMPLOYEES DE L'ONTARIO
1111 GRIEVANCE COMMISSION DE
SEITLEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST, SUITE 2100, TORONTO ON MSG 1za TELEPHONEffELEPHONE (418) 32~-1388
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GSB # 1662/96
OPSEU # 96A311-414
IN THE HATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Villella)
Grievor
- and -
The Crown in Right of Ontario
(Ministry of the Solitior General &
Correctional services)
Employer
BEFORE G. H. McKechnie vice-Chairperson
FOR THE S. Wahl
GRIEVOR Counsel
Koskie & Minsky
Barristers & Solicitors
FOR THE D. Costen
EMPLOYER Counsel
Legal Services Branch
Management Board Secretariat
HEARING December 16, 20, 1996
Mr J Villella was discharged effective September 5, 1996 by letter dated
September 4, 1996 Prior to proceeding to hear the merits of Mr Villella's
discharge grievance, the Union raised three preliminary objections The issues
were, simply stated (1) there was an improper exercise of delegated authority,
thus voiding the discharge, (2) Mr Villella was discharged while he was on an
approved parental leave of absence and this is improper, (3) the Employer issued a
Record of Employment, however, when Mr Villella filed his claim for
unemployment insurance, the Employer did not elaborate upon the reason for the
discharge which invited a finding by the Unemployment Insurance Commission that
Mr Villella was not discharged by reason of misconduct; thus, the Union's position
is that this finding binds me
ISSUE OF DELEGATED AUTHORITY
The Union argues that the delegation of authority to discharge an employee is both
insufficient and improper As a result, the Vanier Centre for Women, the Employer,
did not have the authority to discharge Mr Villella The letter of discharge was
signed by Loretta Eley, Superintendent of the Vanier Centre, and in that letter she
states as follows
" it is my decision to dismiss you from employment for cause, consistent
with provisions of the Public Service Act, Section 22 (3), effective
September 5, 1996 II (p 3)
The Ministry submitted an affidavit of Gordon Jamison who is responsible for the
storage and maintenance of original documents for the proper functioning of the
ministries of the provincial government Attached to Mr Jamison's affidavit is
delegation of authority documentation pursuant to the Public Service Act In those
documents, there is a statement by Robert W Runciman, Solicitor General and
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Minister of Correctional Services consenting to the delegation of "powers and
duties" by the Deputy Solicitor General and Deputy Minister of Correctional
Services, "to any public servant or class thereof in the ministry" This was signed
by Mr Runciman and dated the 27th day of September, 1995 Elaine M Todres,
Deputy Solicitor General and Deputy Minister of Correctional Services signed the
appropnate section of that document, thus delegating her powers and duties under
the Public Service Act to various public servants, authorizing them to exercise
authorities as set out within the delegation document and revokmg pnor
delegations of authority However, Ms Todres did not date her section of the
delegation of authority document The Union argues that the omission of the date
nullifies the delegation of authority and thus prevents the Employer from
discharging Mr Villella
With respect to discharge, the delegation document states
"Delegated official may dismiss a public servant for cause Delegated official
shall consult with their supervisor, H R consultant and/or their personnel
administrator before advising the employee of a decision "
The delegated authority applies to four levels and it was agreed between the
parties that the Superintendent of the Vanier Centre is a level three delegation
Also within the delegation documents reference is made to the Public Service Act
and in particular section "23 (3), Dismissal for Cause" The Union argues that
there is no Section 23 (3) of the Public Service Act and as a result the delegation
document is null and void The power to dismiss for cause in the Public Service
Act is Section 22 (3) and that refers to the power of a Deputy Minister, which
must be properly delegated
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Regulation 168/96 which is made under the Public Service Act states as follows
(4) If a deputy minister dismisses a public servant under subsection 22 (3) of
the Act, the deputy minister shall,
(a) give the public servant written notice of the dismissal and of the
reasons for it,
(b) give written notice of the dismissal to the Commission, and
(c) inform the public servant of his or her right to submit a grievance
under part V
The Union argues that these are mandatory directions and states that the written
notice of the dismissal occurred because reasons were contained in the dismissal
letter However, there is no evidence that written notice was given to the
Commission or that the public servant was informed of the right to submit a
grievance It is the Union's argument that these are conditions precedent to the
exercise of the delegated power The Union referred to an earlier regulation,
Regulation 977 which provided for a hearing if a public servant was dismissed
This was replaced by the current Regulation 168/96 (supra) and the Union argues
that there is no evidence before me to demonstrate that the conditions precedent in
the new Regulation have been satisfied
As authority for its position, the Union referred to Re Putnoki and Public Service
Grievance Board 7 0 R (2d) 621 (1975) The Union also referred to Re OPSEU
(P Gibson) and the Ministry of Correctional Services - GSB Decision 634/84 (1985)
as authority for the requirement that the Deputy Minister had to date her delegation
of authority The parties before the Grievance Settlement Board are always aware
of the Public Service Act and in particular Section 22 (3) and as a result, it is the
Union's contention that Ms Todres made a fatal error when she failed to date her
delegation of authority
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4
The Union also referred to Re Clark et al and Peterborough Utilities Commission et
al , Municipal Electrical Association et al , Interveners 24 0 R (3d) 7 (1995) In
that case, the Municipal Utility was permitted to require a security deposit from
customers and if a customer failed to pay that deposit, power could be disrupted
The Union argued that the Court found that this was a quasi-judicial power of
decision and argues that in the instant case, just cause is clearly a quasI-judicial
power of decision It is the Union's view that Ms Todres' failure to sign the
delegation of authority, and failure to provide any guidance with respect to just
cause in the form of guidelines, meant that the delegation of authority was null and
void
The Ministry argues that this technical defect should not stand in the way of an
inquiry into the merits of the discharge of Mr Villella In the Putnoki case (supra),
the Ministry argues that there was no Collective Agreement and the difficulty
concerned the hearing that was required under the Public Service Act In the
Putnoki case the court found that "Any defect in the hearing under s 31 (2) is
cured by the hearing before the Board" (p 635) The Board referred to was the
Public Service Grievance Board It is the Ministry's argument that in the instant
grievance, there is nothing in the Public Service Act, or in the Collective
Agreement, which requires the Employer to present its case prior to coming before
the Grievance Settlement Board (GSB) The Ministry distinguishes the instant
situation from Re Clark (supra) in which the Peterborough Utilities Commission did
not grant the proper delegation of authority, but in addition there was no right to
appeal to a tribunal such as in the present case with the Grievance Settlement
Board The Ministry referred to Adams and the Ministry of Correctional Services,
GSB file 140/77 (1978) in which the Chair, Professor G Adams commented on the
Union's objection, on technical grounds, which was raised after the evidence was
heard Although Counsel for the Union in the instant case raised its objections at
the outset, the Ministry argues that one can read into the Adams case that there is
5
a presumption of procedural regularity and the onus should be on the Union to
show that there has been noncompliance
The Ministry argues that acceptance of the Union's position that there was not the
proper authority would result in the Employer returning the employee to work,
correcting any procedural defect and then proceeding with the merits Although
this would solve the technical issue with respect to Mr Villella's discharge, it
makes no difference to the merits of the discharge It is the Ministry's argument
that a substantive right has not been violated and referred to Re Cambridge Towel
Corp and Amalgamated Clothing and Textile Workers Union et al 66 0 R (2d)
793 (1988) in which the Court overturned a Board of Arbitration award, which held
that a notification clause provided a substantive right
In reply, the Union argued that the Ministry had not addressed the major Issue
which is the proper delegation of authority for the exercise of quasi-judicial powers
It is the Union's position that the Superintendent at the Vanier Centre has not been
given guidelines by the Deputy Minister and as a result, the exercise of the power
of dismissal has been incorrect
Counsel for the Ministry also referred to Re Harry S Ferguson and Ministry of
Industry and Tourism, GSB file 35/76 (1977) in which the old procedure for
discharge was canvassed The issue, simply stated, was whether Section 31 of
the regulations of the Public Service Act which required a hearing convened by the
Deputy Minister, was in conflict with Article 30 of the Collective Agreement, which
provided for grievance and arbitration The Chair in that case Indicated that the
regulations provided a "pre-trial procedure before a review of the matter took place
by third party adjudication " (p 34) The union argued that the Ferguson case
proceeded because there were defects in the Public Service Act hearing procedure
and the question of whether there was a conflict between the Act and the
grievance process The Chair found that a Collective Agreement would prevail in
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regard to any conflict The Ministry argues that the Collective Agreement has a full
process and, as a result, it is that process that should govern
After a review of the arguments and jurisprudence submitted by both parties, I
come to the conclusion that the Union's preliminary objection fails There IS no
question that the delegation document is not dated by Ms Todres That is
evidence of sloppy administration, however, it is not, in my respectful opinion, fatal
to proceeding to hear the merits of the discharge grievance It is clear that the
Solicitor General signed and dated the appropriate delegation of authority and it
also clear that Ms Todres signed her delegation The Union argued that without
the dated delegation of authority and guidelines, the discharge of any public
servant, not simply Mr Villella, would be null and void With respect, I disagree
In Re Clark (supra) the issue was the appropriate forum for someone to contest the
Utilities Commission's decision In that case, the only forum was the Court,
whereas in the instant case, the Collective Agreement contains a complete
grievance and arbitration procedure and a full exploration of evidence and argument
can be made in that forum Guidelines which were an issue, and absent, in the
Clark case are present in the instant situation because the guideline is "just cause"
It is well established in the arbitration jurisprudence what the parameters of just
cause are, and as a result, further guidelines would not be needed
I also find that the designation of section 23 (3) instead of 22 (3) is a typographical
error This is not fatal to the delegation of authority It is clear from the
documentation that the Ministry was referring to the appropnate section of the
Public Service Act
The Union also argued that the "comments" contained in the delegation of
authority documents, that any delegated official must consult with the Supervisor,
H R Consultant and/or Personnel Administrator, had not been done, or at least no
eVidence had been submitted that these items had been completed The delegation
7
documents that were submitted show the statements in a comments section and
do not appear to have the force of a statutory requirement However, even if I am
mistaken, the fact that the Ministry did not provide evidence that such actions had
been undertaken, does not mean that the actions were not undertaken I agree
with the Ministry that the onus in this preliminary objection rests with the Union to
demonstrate that actions had not been taken In Re Adams (supra), there is a
presumption of procedural regularity and I agree that unless there is a
demonstration of irregularity, the presumption is one of procedural regularity
In Re Putnoki, the issue was whether a hearing process had to be completed as a
conditIOn precedent to a hearing by the Public Service Grievance Board (p 625)
The Court concluded, as already noted (supra), that defects could be cured by the
Board (p 635) In the instant case, the technical or procedural defect of Ms
Todres can be cured by the full hearing at the GSB The Issue of a technical defect
versus substantive right was canvassed in Re Cambridge (supra) and the instant
case is similar in that the failure to enter a date is a technical defect
As a result, I find on the matter of the proper delegation of authority that, although
the Deputy Minister was careless when she failed to enter a date, nonetheless this
does not make the discharge of Mr Villella void ab initio Any procedural
irregularity of this type can be cured by the holding of a hearing and that is
precisely what the Collective Agreement and the grievance and arbitration
procedure within that Collective Agreement are designed to do As a result the
first preliminary objection of the Union IS dismissed
8
DISMISSAL WHILE ON APPROVED PARENTAL LEAVE
The Union raised a preliminary objection that the Employer was prevented from
discharging Mr Villella while he was on an approved parental leave The parties
agreed that Mr Villella submitted a leave of absence request dated May 28, 1996
There IS some dispute with respect to when the leave was to commence On the
form that Mr Villella submitted, the date "June 3/96" has a line drawn through it
and above that is found "June 10/96" Regardless of when the leave was to start,
it IS clear from the document submitted that Mr Villella was given an approved
leave A letter dated August 26, 1996 and signed by J Lindsay, Deputy
Superintendent, states that. "Your parental leave was to commence June 10,
1996 " Mr Villella was then informed of some meetings that were to be held
concerning incidents upon which the discharge was based For the preliminary
objection these meetings are not important, except that they indicate that meetings
to diSCUSS the allegations of the Employer were scheduled while Mr Villella was on
parental leave
The issue IS whether the Employer was prohibited from discharging Mr Villella
while he was on an approved parental leave
The Union argued that Article 51 6 of the Collective Agreement is operative That
article states as follows
51 6 An employee returning from a leave of absence under Articles 51 1 or 51 4
to the ministry in which he or she was employed immediately prior to such
leave, shall be assigned to the position he or she most recently held, if it still
exists, or to a comparable position, if it does not, and continue to be paid at
the step in the salary range that he or she would have attained had he or she
worked during the leave of absence
9
The Union also argues that the Employment Standards Act prohibits the Employer
from terminating Mr Villella while he is on an approved leave Section 43 (1)
states as follows
The employer of an employee who has taken pregnancy leave or parental
leave shall reinstate the employee when the leave ends to the position the
employee most recently held with the employer, if it still exists, or to a
comparable position, if it does not
The Union also argues that Section 44 of the Employment Standards Act clearly
prohibits the Employer from discharging Mr Villella while on an approved leave
That section states as follows
44 An employer shall not intimidate, discipline, suspend, layoff, dismiss or
impose a penalty on an employee because the employee is or will become
eligible to take, intends to take or takes pregnancy leave or parental leave
The Union argues that Bill 49, an Act to Improve the Employment Standards Act,
specifically Section 64 5 gives jurisdiction to an arbitrator to apply the Employment
Standards Act
In support of its arguments, the Union referred to Re 169809 Canada Ltd v
Ontario (Ministry of Labour) 16 C C E L.(2d) 16 (1993) in which an employer
claimed that he did not know the law In that case, an employee had asked for,
and was granted, parental leave from June 1991 to September 1991 The
employer, concerned about that employee's productivity hired a replacement
employee in May to begin in June The employee was then given his leave and on
his return to work was terminated At paragraph seven of the decision, the referee
stated "The employer's position is that the act of termination was merely delayed,
10
but was not caused by the employee's parental leave" The referee concluded that
the particular employee In fact had no job even as he was requesting parental
leave" (para 11) The referee found that the employer should have allowed the
employee to return to the same or comparable position and then decide if the
employee was unsatisfactory prior to termination
The Union also referred to Re Medical Arts Dispensary of Ottawa (1990), a
decision of the Ontario Ministry of Labour, Office of Adjudication in 1992 In that
case the Medical Arts Dispensary terminated an employee's employment during her
pregnancy leave The referee found that the employer had breached both Section
43 and Section 44 of the Employment Standards Act The referee concluded, at
page seven of the decision, that the employer had violated Section 43 when it did
not reinstate the employee to the same or comparable position, if the same position
did not exist
The Union also referred to Re Corporation of the City of Brampton and
Amalgamated Transit Union, Local 1573 (1978) 19 L.A C (2d) 236 (Shime) In
that case, the arbitrator found that the employer was correct to suspend a grievor,
but was required to pay the grievor for the statutory holiday which occurred during
the suspension (p 240)
The Union argues that the issue is the difference between what could be called the
"causation school" and "statutory reason school" in the matter of interpreting
Section 44 of the Employment Standards Act It is the Union's view that the
"statutory reason school" is appropriate and that Section 44 (supra), specifically
the word "because", means that an employer is prohibited from discharging an
employee when that employee is on an approved parental leave
The Ministry argues that the "causation school" is the appropriate manner of
interpretation of Section 44 In the Ministry's view, a review of the Employment
11
Standards Act will demonstrate that the word "because" is put in the section to
prevent an employer from taking action for the reason that an employee has
become involved in parental leave whether it has been taken or whether there is an
intent to take such leave In addition, the Ministry refers to the collective
agreement in the instant case in which there is no prohibition in that document
restricting the Employer's right to discharge or discipline while an employee is on
an approved leave
The Ministry referred to a decision of an Office of Adjudication referee in the matter
of Ontario Blue Cross and the Ministry of Labour and C Fletcher (decision dated
August 18, 1995, File # ES68/93-358) In that case the employer did not wait
until the end of a parental leave to terminate the employee and the claimant argued
that Section 43 of the Employment Standards Act gave her an absolute right to
return to her position At page 28 of the decision the referee states as follows
"In my view the question boils down to this - is it open to the Employer to
effect a bona fides termination of an employee who has taken a pregnancy
or parental leave or is the right to reinstatement absolute as argued by the
Claimant such that the Employer must reinstate for an indeterminate period
even where it had established that the employee would have been
terminated had the leave not occurred? For the reasons set out below I do
not believe that the language of Part XI goes so far In my view the scheme
taken as a whole is meant to limit the economic consequences of childbirth
and adoption by creating a mandatory right to a leave and then
reinstatement to the former position etc The scheme does not create an
absolute right to a job for everyone who is taken leave under the part "
In that case, the Medical Arts decision is reviewed and the referee disagrees with
those persons who interpret the Medical Arts case as supporting an absolute right
of reinstatement
12
At page 30-31 in the Ontario Blue Cross case, Referee Muir states
"While I am not in agreement with certain of the comments of the Referee
regarding the obligation of an employer to create a position for a returning
employee, I also do not read the decision as entirely precluding the
possibility of a bona fide termination I agree that the decision of an
employer to terminate an employee in close proximity to a leave must be
subject to intense scrutiny because, to put it squarely, the requirements of
these provisions are onerous for employers and it will often be the case that
an employer will find It convenient and or more efficient to operate without
the returning employee This IS precisely the mischief that these sections
were intended to avoid It does not follow from that nor do I take the
Referee to be saying that the Employer's right to manage the workplace had
been nullified "
Referee Muir goes on to relate the absurd position that could result if an employee
took part in "egregious misconduct" and the employer would have to reinstate the
employee simply because a leave was taken (p 33) The Ministry also referred to
an Office of Adjudication decision, File ES68/93-66 between 241 Pizza limited and
Ministry of Labour, a decision of Referee Alter, dated September 21, 1993 In that
case, Referee Alter states
"I find that by the inclusion of the word "because" in the new section, the
Employee has only to demonstrate some causal connection between her
pregnancy and her termination for the Employer to be in violation of the new
section" (p 4)
The reference to "new section" indicates the change in the Employment Standards
Act In that case, the referee found the employer had acted contrary to Section 44
and that the release of the employee was caused bv her pregnancy (emphasis
mine)
13
The Ministry also referred to an Office of Adjudication decision, File ES67/-93-46
between Helene Goulet and Uniglobe Tri-Pro Travel Ltd and the Ministry of Labour,
a decision of Referee Alter dated June 18, 1993 On page five of the decision, the
referee states as follows
"I do not believe there is any reason why an individual on parental leave
ought not to have each and every benefit, salary increase, or perquisite that
other employees receive I find that the comments of Dixon C J must be
taken to extend the meaning of Section 44 not only to prevent employers
from certain enumerated actions, but also to compel employers to treat
individuals on parental leave exactly the same way as other employees "
The Ministry argues that it would be a charade to reinstate Mr Villella wait and
then discharge him again This runs counter to sensible labour relations The
Ministry referred to Re Corporation of the City of Brampton (supra) in which the
Arbitrator upheld the discipline but ordered the employee to be reimbursed for the
statutory holiday that fell within the leave period The Ministry suggests that, that
technique is available to me at the end of the instant case
The Union argues in reply that in the Ontario Blue Cross case (supra) the referee
found that there was an absolute right At page 33 the referee states as follows
"Absent any language in the Act indicating the contrary it is undoubtedly the
case that upon the completion of the leave and reinstatement an employer
can deal with the employee as it would any other employee including
dispensing discipline, lay-off, or the termination of that employee II
After reviewing the jurisprudence submitted, and legal argument, I come to the
conclusion that the Union's objection must fail The appropriate section of the
Employment Standards Act is Section 44 and the construction of Section 44, in my
respectful opinion indicates a causation In other words, simply because an
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employee intends to take or takes a parental leave, the Employer is precluded from
Imposing any dismissal or such other actions prohibited by Section 44 I agree
; - with Referee Muir in the Ontano Blue Cross case (supra) that terminations in close
proximity to a leave must undergo close scrutiny However Referee Muir does not
indicate that an employer is prohibited from terminating an employee for cause
The Union argued that Referee Muir's comments indicate that there was an
absolute right However, at page 40 of the decision the referee states that the
language of Section 43, " does not protect an employee in their employment
either before or after a pregnancy leave" The referee goes on to state " Thus
even if the employer is entirely precluded from instituting a bone (sic) fide
termination during the leave there is nothing preventing a proper termination with
notice after the leave has terminated unless it was made for a reason prohibited by
Section 44" (p 40) That statement gives credence to the causation school of
interpretation of Section 44 In my respectful opinion the reason for discharge,
specifically, cannot be "because" an employee takes a parental leave The referee
goes on to state as follows
"Having concluded that there was no violation of the Act in the termination
itself the question then arises whether an employer who decides to termin9te
while a leave is underway must wait until the leave has ended and the
employee is reinstated It is a troublesome issue and one that I am not
inclined to answer except to the extent that is necessary to decide this
matter I am inclined to the view that the right to reinstatement is an
absolute one in the sense that an employer's rights with respect to an
individual are suspended during the leave, that is the employer must
reinstate and then exercise their rights at that time However in the instance
where the employee has committed some egregious act of misconduct it
makes little sense to require the employer and equally the employee wait for
the charade to run its course "(pp 40-41)
The referee goes on to state that it is his view, " the employer's rights to manage
during a leave are suspended" (p 41)
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However, the referee also states at page 41
..,- "If it is possible to violate section 43 by a termination during a leave I find
that it was a technical violation only and one that attracts no liability and
damages"
I take from the case law submitted that, firstly, the right to terminate during a leave
IS not prohibited by Section 44 and the reason for that is the meaning given to the
word "because" is one of causality Secondly, I find that the decision of Referee
Muir in the Ontario Blue Cross case, while apparently contradictory at points,
nonetheless comes to the conclusion that it would be a charade to suspend any
discipline or discharge for an egregious act of misconduct until the end of a leave
of absence That this could be a technical violation is a reasonable approach and I
adopt the Ministry's argument in the instant case when it stated that if there is
compensation required during the period of the leave, even if just cause is found
for discharge, then that can be settled at a later point.
As a result, the Union's preliminary objection on the matter of termination during
an approved leave is dismissed
UNEMPLOYMENT INSURANCE COMPENSATION ISSUE
The issue is the conduct of the Employer in the matter of Unemployment Insurance
and a finding made by Human Resources Development Canada The factual
situation is straightforward Mr Villella initiated his claim for Unemployment
Insurance and the Employer issued the Record of Employment which stated that
the reason for the termination of employment was "discharge for cause" An
Insurance agent with Human Resources Development Canada, B Drebot,
attempted to contact the Vanier Centre to get more detail about the reasons for
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Mr Villella's discharge The parties tabled a variety of documents indicating that
Human Resources Development Canada attempted, unsuccessfully, to discover
,,- more details and by letter dated November 5, 1996, B Drebot wrote to the
Ministry indicating that Mr Villella's claim had been approved and stated as
follows
"We have done this because based on the Unemployment Insurance Act, the
reasons for losing his/her employment does not constitute misconduct"
By letter dated November 22, 1996 the Ministry initiated an appeal of this decision
and stated that, "the employer did not have meaningful opportunity to respond to
a letter dated October 10, 1996 " The Union states that the Ministry and I, are
bound by the finding of the unemployment insurance agent whereas the Ministry
takes the position that the evidence of letters and requests are irrelevant since the
Unemployment Insurance decision process has not yet been finalized
The Union uses as basic support for its argument Re Rasanen v Rosemount
Instruments Limited (1994) 170 R (3d) 267 In that case the requirements for
issue estoppel are set forward The Rasanen and Rosemount case is a wrongful
dismissal case, however, the Union argues that the issue before me is one of issue
estoppel The requirements of issue estoppel are set out at page 278 as follows
" (1) that the same question has been decided, (2) that the judicial decision
which is said to create the estoppel was final, and (3) that the party to the
judicial decision or their privies were the same persons as the parties to the
proceedings in which the estoppel is raised or their privies"
Issue estoppel is used to prevent relitigating issues and to bring a finality to a
decision making process The Union argues that, in the instant case, the Ministry
IS unable to assert that there is any real difference between misconduct for
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unemployment insurance and lack of just cause for a discharge case As support
for thIS, the Union refers to Re Randhawa v Everest and Jennings Canadian Ltd
- (1996) 0 J No 2181 In that case, an employee's claim for unemployment
benefits was allowed and the company indicated that it was going to appeal this
decision The appeal was then heard before a three person board pursuant to the
Unemployment Insurance Act The Board found that the company's appeal failed
and that the employee was entitled to benefits The Court in that case came to the
conclusion that issue estoppel applied and that the company had an adequate
opportunity to present its case because a hearing was held
The Union argues in the instant case that, the type of decision that the
Unemployment Insurance Commission has made to provide Mr Villella with
benefits is comparable to that made by the Employer when it decided to discharge
him It is also comparable to the Employment Standards Act structure In the
Union's view, the situation with respect to Mr Villella is made more serious
because the Employer did not respond to the insurance agent's requests It is the
Union's view that the Employer ignored the Unemployment Insurance
Commission's requests and is now bound by the determination made by the
insurance agent
The Union argues that the Randhawa case (supra) overrules prior cases that took
the position that unemployment insurance procedures are different than those
required by grievance arbitration
The Ministry argues that Mr Villella was discharged on September 5, 1996 and
applied for unemployment insurance The Ministry then provided, appropriately, a
Record of Employment indicating that Mr Villella was discharged for cause and the
Ministry has not abandoned that position The unemployment insurance agent then
rendered his decision and the Ministry was notified with respect to Its right to
appeal There was no proceeding in front of the unemployment insurance agent, it
18
was simply a decision by that agent without information provided by the Employer
A hearing, If one is held, IS before a Board of Referees and that has not taken
place The Ministry argues that in the Randhawa case, the issue was before the
Board of Referees and it was then taken to the Court. That is not the situation in
the Instant case In the Rasanen case, the issue followed the Employment
Standards Act process and there was a hearing pursuant to Section 50 of the
Employment Standards Act in effect at the time It is the Ministry's argument in
the instant case that it and Mr Villella are still at the officer or investigation stage
In the Employment Insurance Act (1996) there is still a Board of Reference and
Sections 48-53 set forth the claims process The Employer directs me to Section
49 (2) whIch states as follows
(2) The Commission shall give the benefit of the doubt to the claimant on the
Issue of whether any circumstances or conditions exist that have the effect
of disqualifying the claimant under section 30 or disentitling the claimant
under section 31, 32 or 33, if the evidence on each side of the issue is
equally balanced
Sections 114 to 123 of the Employment Insurance Act set forth the appeal process
indicating that there is an appeal to a Board of Referees and a further appeal can be
made to an Umpire In the Ministry's view, this process has not yet been started
and the Ministry argues that finality is only at the Umpire stage In Re Randhawa,
the Ministry argues that the Board of Reference made a determination of whether
the employee quit but in the instant case the situation has not progressed that far
The Ministry argues that the GSB has ruled on the Union's issue and I should defer
to the findings in those cases In Re OPSEU (Leeder) and Ministry of Health, GSB
deCision dated January 15, 1996 File 2498/93, 164/94, 296/94) the issue was
identIcal to that put before me - there had been a prior determination by a Board of
Referees pursuant to the Unemployment Insurance Act (p 1) In that case, the
19
employer did not appeal to the Board of Referees within the required time period
and also did not present any evidence Beginning at page 14 of that decision the
GSB reviews the criteria for issue estoppel At page 15, the GSB concluded that
"Reinstatement, which Mr Leeder was seeking, was not a possible remedy in the
context of the Board of Referees" This case was heard prior to the decision of the
Court in Re Randhawa (supra) and the Union argues that it has been superseded
In a separate GSB decision, Re OLBEU (Mather) and Liquor Control Board of
Ontario, (1996) GSB file 2260/95, the GSB was presented with the same issue as
that before me In that case, a Board of Referees had concluded that Mr Mather
had been terminated as a result of his own misconduct and upheld the denial of
benefits The Liquor Control Board argued that the GSB had no jurisdiction to
determine the issue of cause because of the decision of the Board of Referees
under the Unemployment Insurance Act As in the Leeder case, the GSB reviewed
the criteria for issue estoppel and concluded that the Liquor Control Board's
objection must fail and that the case could be heard on its merits
The Ministry also argued that an early decision of the GSB by Mr Shime - E Blake
et al and Amalgamated Transit Union, a decision dated May, 1988, put forward
the proposition that the GSB is one entity and as a result each decision becomes a
decision of the Board and therefore I should be wary of overturning another panel's
view
Finally, the Ministry referred to Re OPSEU (White) and Ministry of Community and
Social Services, GSB decision dated October, 1996, GSB file 810/95 In that
case, the employer took the position that it should be allowed to rely on the
conviction of the grievor in the Criminal Court The Vice Chair concluded " the
Board does not consider it appropriate to defer to the finding of fact made by a
Jury" (p 29) The Ministry argues that the GSB is jealous of its own process and as
a result should not simply defer to another forum
20
The starting point for this decision rests with the cnteria for issue estoppel These
criteria were analyzed in great detail in both the Leeder and Mather cases (supra)
The Mather case was heard and decided following the Randhawa case (supra),
however, there is no reference to Randhawa and it is therefore not possible to
know whether or not that case was brought to the Chair's attention At page 13
in reviewing the Leeder case, the Vice Chair states as follows
"Although the board of referees in determining whether the employee
engaged in willful misconduct, made a determination that the employer had
reasonable cause to discharge the employee, I do not find that such a finding
is conclusive of the issue before this Board The board of referees was not
being asked whether the Employer had caused a discharge to the Grievor,
but whether the employee engaged in willful conduct. Therefore whether
the employer had reasonable cause to discharge the employee, may be a
significant factor in the decision of the board of referees, but it is not the
issue that it had to determine" (p 13)
I find that the analyses in the Mather case and the Leeder case are persuasive
The issue before me is not whether Mr Villella engaged in willful conduct which
led to his dismissal but, rather, whether or not the Employer had just cause to
discharge the Grievor and as pointed out in the Mather case, " to determine
whether there was cause to discharge the grievor, and whether the dismissal
should be upheld, mitigated or revoked as must be considered under the Crown
Employees Collective Bargaining Act and the Labour Relations Act as
Incorporated" (pp 1 3-14)
With respect to the question of whether there was a prior final decision, Vice Chair
Kirkwood addressed this issue in the Mather case In Rasanen, the Employment
Standards Act's procedure was involved whereas in the instant case and in the
Mather case, it is the Unemployment Insurance Act or, as now named, the
Employment Insurance Act. In the instant case, I find the Ministry's argument
succeeds, that is, the process is not finished The Ministry has appealed the
21
Insurance Agent's decision and a Board of Referees will hear that appeal, however,
even that is not the final step since an Umpire can become involved
With respect to the question of whether or not the parties or their privies are
common to both proceedings, the analyses provided in both the leeder and the
Mather cases are instructive Before the Unemployment Insurance Commission the
Issue is whether or not Mr Villella is entitled to benefits and therefore whether the
Commission will pay benefits to an individual The case in front of the GSB is
whether or not Mr Villella was discharged for just cause The result could be to
uphold the discharge, or to impose a lesser penalty, or order full reinstatement with
or without compensation The parties are different In the Unemployment
Insurance situation, the parties are the Commission and Mr Villella with input from
the Employer In the case in front of the GSB, the parties are the Union and the
Employer and the Unemployment Insurance Commission has no part in that
process In the Unemployment Insurance case, the Employer has no interest in the
outcome because there is no liability and in the instant case, the Unemployment
Insurance Commission has no interest in the outcome because it bears no liability
In the Rasanen case the issue of legal consequences was addressed In my
respectful opinion, the legal consequences are very different between the
determination made by the Unemployment Insurance Commission and that made by
the GSB In the Randhawa case the Court concluded that the issue was similar in
law At paragraph 9 the Court states
"While the legal characterization of the issue to be addressed by the Board
of Referees is not identical to the issues raised by the pleadings here, it is
clearly similar in law Factually, it is identical, namely, did the plaintiff
voluntarily leave his job or did he misbehave in failing to notify his employer
for the reason of his absence?"
22
In Rasanen, Abella J A addressed this issue and indicated that different legal
consequences could flow from the same factual question In my respectful,
~
opinion, the factual questions are different As already pointed out, the issue in
front of the Unemployment Insurance Commission is one of willful conduct
whereas In front of the GSB the question is one of just cause for discharge To
determine if the question being put to the Unemployment Insurance Commission
and the GSB IS the same requires an analysis of the facts The Unemployment
Insurance CommIssion is attempting to determine whether or not the claimant
should be disqualified from benefits, " if the claimant lost any employment
because of their misconduct. "(S 30)( 1) Before the Unemployment Insurance
Commission the test is whether the claimant, in this case Mr Villella, engaged in
conduct which would disentitle him from benefits In the case in front of the GSB,
the question asked is whether or not the Employer violated the collective
agreement by failing to have just cause for the discharge of Mr Villella This
question is tied to the legal consequences flowing from a decision, and that makes
the disentanglement of the issues difficult Nonetheless the answer, in my
respectful opinion, can be stated quite simply Before the Unemployment
Insurance Commission the issue is simply whether or not Mr Villella is entitled to
benefits There is no issue of reinstatement, there is no issue of reinstatement
with some penalty, nor is there any issue with respect to the payment of wages
Even if misconduct is to be judged the same in both cases, the legal consequences
cannot be stated as simply one of semantics The GSB must decide if the
collective agreement has been breached and that is not the question being put to
the Unemployment Insurance Commission The Arbitrator, or the GSB, looks at
just cause whereas the Unemployment Insurance Commission looks at cause
These can be different and in my respectful opinion are different
As a result, I find that the criteria for issue estoppel are not present and the
Union's preliminary objection on this matter must fail
23
In conclusion, all three preliminary objections raised by the Union have been
rejected and the hearing can proceed on the merits on dates already scheduled
Dated at Toronto this ZSth day of February, 1997
"
~~-II~~
Graeme H McKechnie
Vice-charr