HomeMy WebLinkAboutP-2015-2530.Rancourt.17-06-06 Decision
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Commission des
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PSGB#P-2015-2530
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE OF ONTARIO ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Rancourt Complainant
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The Crown in Right of Ontario
(Ministry of Community Safety and Correctional Services) Employer
BEFORE Deborah J.D. Leighton Vice Chair
FOR THE
COMPLAINANT
John Yach
Yach & Associates
Counsel
FOR THE EMPLOYER Stewart McMahon
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING May 18, 2017
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Decision
[1] Mr. Andre Rancourt, was a sergeant at Ottawa Carlton Detention Centre (OCDC)
before the Ministry terminated his employment on October 13, 2015. Mr.
Rancourt filed a complaint with the Board on November 25, 2015, alleging that
the employer terminated his employment without just cause. This is an interim
decision on the motion of the employer to suppress the name of the employee
who reported certain information to senior management at OCDC, which led to
the investigation, which led to the complainant’s termination. The employee has
been referred to as ‘Officer Doe’ throughout the proceeding. The motion
proceeded with written submissions and oral argument on May 18, 2017. Two
days of the hearing have been held and on November 29, 2016, the occurrence
report of officer Doe was entered into evidence.
[2] Counsel for the employer argued that the name of officer Doe should be
confidential because, like a police informant and for the same reasons, his or her
identity should be protected. Alternatively, he argued that the disclosure of
wrongdoing provisions of the Public Service Act of Ontario, 2006, protects those
employees who report serious acts of wrongdoing by other public servants.
Counsel also cited the “code of silence” in Corrections, which acts to discourage
correctional officers from disclosing serious wrongdoing for fear of being labelled
a “rat” and the potential for the informant to suffer serious reprisal. Finally,
counsel argued that the only reason for putting forth the evidence of Officer Doe
was to explain what precipitated the employer’s investigation into the
complainant’s behaviour. Counsel for the employer submitted that since the
Ministry did not rely on the evidence of officer Doe, in deciding to discharge the
complainant, his or her name is not relevant.
[3] Counsel for the complainant argued that informant privilege has no application to
the case before me. He argued that police informant privilege cannot be applied
as an “informer privilege” to civil or administrative proceedings. Counsel argued
further that the disclosure of wrongdoing provisions in the PSA0 similarly have no
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application to the case. The board sets its own rules and procedures and is not
bound by the disclosure of wrongdoing provisions of PS0A. Counsel urged me to
find that as a matter of procedural fairness the employer is obliged to disclose the
identity of officer Doe. This is so particularly because of the evidence introduced
by the employer on the first full day of the hearing, that is, the occurrence report
written by officer Doe. Finally, counsel argued that the identity of officer Doe may
not be relevant to the employer’s case but it is to the complainant’s. The
complainant is entitled to disclosure of all relevant materials and the employer
has already entered a document written by officer Doe. Counsel wants to cross-
examine officer Doe on this document. Procedural fairness requires that he know
the identity of this individual.
[4] Having carefully considered the submissions of the parties I am persuaded that
procedural fairness requires that the employer provide the identity of officer Doe
to the complainant. As counsel for the employer stated, it is trite law that a vice
chair of the PSGB has broad authority over ordering disclosure. This authority
must be exercised in accord with procedural fairness and the principles of natural
justice. And procedural fairness requires that the identity of officer Doe be
revealed. The employer tendered an occurrence report written by officer Doe and
the complainant has a right to cross-examine this individual, should he choose to
do so.
[5] Consequently, the employer is hereby ordered to provide the name of officer Doe
to the complainant forthwith.
Dated at Toronto, Ontario this 6th day of June 2017.
Deborah J.D. Leighton, Vice-Chair