HomeMy WebLinkAbout1997-0598.Miceli.01-06-12 Interim Decision
~M~ om~o EMPLOYES DE L4 COURONNE
_Wi ii~~;~~T DE L "ONTARIO
COMMISSION DE
REGLEMENT
"l1li--11'" BOARD DES GRIEFS
Ontario
180 DUNDAS STREET WEST SUITE 600 TORONTO ON M5G 128 TELEPHONEITELEPHONE. (416) 326-1388
180 RUE DUNDAS OUEST BUREAU 600 TORONTO (ON) M5G 128 FA CSIMI LEITELECOPI E. (416) 326-1396
GSB#0598/97, #0863/97
UNION# 97B629, 970930
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Miceli)
Grievor
-and-
The Crown In Right of Ontario
(The Ministry of Transportation)
Employer
BEFORE Eva E Marszewskl Vice-Chair
FOR THE GRIEVOR Nelson Roland, Counsel
Barnster & Solicitor
FOR THE EMPLOYER Joe Cocker, Counsel
Management Board Secretariat, March 29, 1999
Len Hatzls, Counsel,
Management Board Secretariat, April 12, 13, and May 2, 2000
HEARING March 29, 1999, April 12, 2000, April 13, 2000 and May 2, 2000
INTERIM DECISION
The parties have requested a written ruling with respect to objections by Union
Counsel to questions put by Employer Counsel to his witness after the close of the Union's
case The objections to the questions were based on a Browne and Dunn argument. The
issues raised by the Grievor and the facts pertinent to the determination of the Brown & Dunn
issue may be briefly summarized as follows
The Grievor, Bob Miceli, held an Automotive Technician II, Mechanic 2
position in the Ministry's garage in Sault Ste Marie, Ontario, when he received a Surplus
Notice dated July 24, 1997 and was laid off He has alleged that the Employer failed to re-call
him to work pursuant to Article 206 of the Collective Agreement, that a competition for
Transportation Enforcement Officer in Sault Ste Marie was flawed, that the Ministry violated
Article 24 of the Collective Agreement by not granting the him the requested training for
Transportation Enforcement Officer III, that an independent contractor was hired to do work
that should have been assigned to him and finally that the Ministry failed to comply with labour
legislation by failing to provide him with a "Record of Employment" Certificate within the
required time limits The Grievor sought the following relief" that this Board declare that the
competition for Transportation Enforcement Officer was flawed and that he, the Grievor, ought
to be declared the successful candidate, that he be given the training opportunity which had
first been approved and then denied Moreover, the Grievor sought a declaration that he ought
to have been recalled to the Automotive Technician II, Mechanic 2 position in Sault Ste Marie
and that the Employer ought pay to the Grievor all the monies that were paid to the contractor
who was hired to do his work, and finally, a declaration that he should have been given his
"Record of Employment" Certificate
2
The Employer took the position that the Grievor's lay-off was due to the
Ministry's privatization and downsizing initiatives, that there was no position into which the
Grievor could have been recalled It was asserted that in July, 1996, there was a Ministry,
province-wide, consolidation of garages and warehouses The Employer' Surplus Notice was
dated July 24, 1996 and gave the Grievor seven days to consider the options set out by the
employer While most employees chose the payment option, Mr Miceli chose option #2 The
relevant portions of the Ministry's letter read as follows
As a result of workforce reductions in the Ministry of Transportation, your position
of Automotive Technician II, Mechanic 2, will be declared surplus on July 31, 1996
and your last date of work will be January 30, 1997 Effective July 31, 1996 this
letter provides you with notice of lay-off as required by Article 24 2 1 of the
Collective Agreement.
Upon review of your employment record you have the following options
* * *
2) You may remain on notice for a period of six months and continue to be
considered for assignment to a vacancy, if one becomes available If you
are not assigned to a vacancy before your lay-off on January 30, 1997, you
will have recall rights for 24 months from that date, if you leave your
termination pay with the ministry in trust. You may also broaden your
geographic parameters beyond 40 km and specify the locations to which
you will relocate No relocation expenses will be provided
AND
3) If you choose to remain on notice, you may be eligible to displace another
employee In order for us to identify a less senior employee for you to
displace, you must complete the attached form and return it to us within
three working days You will be advised no later than August 7, 1996, if
you are able to exercise displacement rights
* * *
I urge you to review Article 24 and Appendix 14 of the OPSEU Collective
Agreement before you make your decision An entitlements package is attached
for your information Please contact your Human Resources Consultant Kent
Broughton, if you have any questions
Once you have elected your option please forward a signed copy of this letter to
your Human Resources Consultant. If you do not respond by 430 pm July 31,
1996, you will be deemed to have chosen to remain on notice, as outlined in
paragraph two above
3
He did not apply for the Mechanic position in Wawa, as that would have taken
him out of the 40 Km range from Sault Ste Marie with the consequence that he would not
have been able to apply for a position in Sault Ste Marie He chose to remain in Sault Ste
Marie and was therefore the only mechanic left there with recall rights except for one mechanic
senior to the Grievor who was not surplused and retained the only mechanic job left in Sault
Ste Marie Sometime within the month, a position of Transportation Enforcement Officer II
came open in Sault Ste Marie The position was not posted at the time and the Grievor
decided that he wanted to be eligible for the job He discussed the option with Mr Kent
Broughton, the Human Resources Consultant who had been designated by the Ministry as the
H R person directly responsible for the downsizing process in Sault Ste Marie Mr Broughton
advised the Grievor to enroll in a Law Enforcement course at Sioux College The Grievor took
this advice and completed a basic Law Enforcement course in December, 1996
The Grievor also met with the District Engineer for Sault Ste Marie, Bob Van
Veen, the Ministry's senior management person Subsequent to the meeting with Van Veen,
the Grievor confirmed by letter dated September 16, 1996, his request to receive the
developmental training for the position of Transportation Enforcement Officer II He copied the
letter to Broughton Although the letter was misdirected, it eventually reached Van Veen By
letter dated September 25, Mr Van Veen approved the Grievor's request for the Drivers and
Vehicles training beginning November 4, 1996 and extending to the end of the Grievor's notice
period Van Veen also approved a training period for the week of October 7th for the purpose
of familiarizing the Grievor with the Drivers & Vehicles operations The Grievor had also met
with the District Manager of Drivers and Vehicles at which time he determined that there was
no one else in that department that wanted training
4
On October 7, the Grievor went on the developmental training assignment at the
Heyden weigh scales outside of Sault Ste Marie to become familiarized as an enforcement
officer The following day, they went another 100 km to Sprague, Ontario, about 150 Km east
of Sault Ste Marie About ten minutes after the Grievor arrived at the work location and
commenced his job shadowing assignment, around 4 or 5 pm, Mr Harrington called the job
site Supervisor and advised him that the Grievor's training request had been denied The
Grievor was to return to Sault Ste Marie immediately Harrington told the Grievor that the
order came from his Supervisor in Thunder Bay
Understandably, the Grievor was very upset. Upon his return to Sault Ste
Marie, on October 9, he called Broughton in Thunder Bay The latter apparently knew nothing
of the change of direction and thought that Van Veen was in Toronto The Grievor testified
that Broughton advised him not to grieve Acting on that advice, the Grievor decided not to
grieve and instead thought that he could get to the bottom of the situation himself Eventually,
the Grievor discovered that the training was cancelled by Linda Jackson, the Regional
Manager of Drivers and Vehicles
Upon the conclusion of the Union's case, the Employer first called Mr
Ainsworth, the shop foreman in Sault Ste Marie, and then called Mr Kent Broughton from the
Ministry's Human Resources Department. During Broughton's Examination-in-Chief, Counsel
for the Employer asked him whether or not he could recall meeting with the Grievor with
respect to the issue of the training exercise which was terminated on October 9, 1996
Broughton answered that he had received a phone call from the Grievor
5
At that point, Union Counsel objected to the question on the grounds that it was
intended to contradict the Grievor with respect to his evidence that Mr Broughton had advised
him not to grieve the cancellation of his developmental training He took the position that if
Broughton's evidence was intended to contradict the Grievor on material facts, then such a
contradiction should have been put to the Grievor by Counsel for the Employer when the
Grievor was still on the stand and had the opportunity to speak to the issues arising from the
questions put to him in cross-examination and then again on re-examination Moreover, there
had been no manifest notice given to the Grievor while he had been on the stand that his
testimony on this issue would be contradicted or impeached by the Employer's evidence It
was submitted that the defect could not be cured by calling the Grievor to give evidence in
reply because that would force the Grievor to split his case Counsel for the Union relied upon
the decision of the English Court of Appeal in Browne v Dunn (1894) The Reports 67 (Lord
Herschell) Union Counsel submitted that the credibility of a witness cannot be impeached
after that witnesses' testimony is concluded if the material facts which are to be relied upon in
the impeachment argument were not put to the witness, giving the witness full opportunity to
explain In addition, the Union also relied upon the following cases in making its submissions
on this issue Re Laidlaw Waste Systems Ltd. (St. Catharines) and Canadian Union of Public
Employees, Local 1045 (1993) 37 L.A C (4th) 146 (Whitehead), Re the Crown in Right of
Ontario (Ministry of Transportation and Communications) and Ontario Public Service
Employees Union, Grievance of Taraschuk (1985) 19 L.A C (3d) 161(Delisle), and Avenue /I
Community Program Service and 0 P S E U, Grievance of David Rawson, (Unreported
Decision, March 18, 1996) (Simmons)
Counsel for the Employer countered that there is no absolute Browne v Dunn
rule, that this Board has the discretion to determine whether or not it ought to allow Counsel to
put the challenged questions to the witness Subsequently, the Union would still have the right
6
to call reply evidence if necessary Moreover, it was submitted that if the Grievor was aware,
or if there was "a reasonable basis for concluding that the veracity of the evidence would be
challenged subsequently in the proceeding", then the Grievor would not be taken by surprise
The issues raised by Counsel for the Employer must have come out in Steps 1 and 2 of the
Grievance procedure and could not be taking the Grievor by surprise Counsel submitted that
a case by case analysis was required to determine what was appropriate in each and every
case In Counsel's submission, there were three options available to the Board allow the
Grievor to be re-called to testify (but not in reply), allow the Union to decide whether or not to
recall the Grievor in reply, and allow all of the questions in any event and have the answers
weighed at the end of the case in determining the outcome of the case The Employer relied
upon the following cases in making its submissions Palmer v the Queen, (1979) 106 0 L.R
(3d) P 212 , (McFarlane, J.A.), Machado v Berlet et al (1986) 57 a R (2d) 207 (Ewaschuk,
J), [1986] a J No 1195 (also rep 32 0 L.R (4th) 634, R v Verney (M) (1993) 67 a.A C 279
(1993) (Mr Justice Finlayson), Hurd et al and Hewitt et al (1994) 20 a R (3d) P 639 (Mr
Justice Griffiths), Re the Donwood Institute and Ontario Public Services Employees Union,
Local 541, (1996) 56 L.A.C (4th) P 1 (Ian Springate), Green v Canada (Treasury Board) [1997]
F C J No 964 File No T-1710-96 (Cullen J), Green v Canada (Treasury Board) [2000] F C J
No 379 File No A-542-97 (Robertson J )
Union Counsel agreed that while the Browne v Dunn rule is not absolute, the
permissible exceptions are those spelled out by the two judges Lord Herschell and Lord
Morris, and subsequently interpreted by case law submitted Consequently, it was submitted
that I am required to exercise my discretion judicially and consistently with the caselaw With
respect to the question of whether or not the Grievor was taken by surprise, it was submitted
that there was no evidence in this hearing with respect to the challenge of the Grievor's version
of his conversation with Broughton, nor was there any evidence concerning what transpired
7
during the Grievance procedure, and properly so, since all discussions entered into during the
grievance procedure are confidential and therefore not admissible in evidence
The context for the decision in Browne v Dunn is a battle between neighbours in
The Vale in Hampstead, England in 1891 One resident, Mr James Loxham Browne, had
taken out two summonses, one against Mr Benjamin Paine for assault, and the second against
Mrs Hoch for abusive language The two summonses were to be dealt with in court on
August 5, 1891 On August 4, 1891, the defendant Paine, the defendant Hoch's husband,
along with seven others signed a retainer authorizing a lawyer, Mr Cecil W Dunn, to appear in
court on their behalf the next day, August 5, 1891, for a summons and order that Browne
" has continuously for many months past, both by acts and words, seriously
annoyed us, and each of us, and other residents in the Vale aforesaid, whereby
he has endeavoured to provoke a breach or breaches of the public peace or
whereby a breach or breaches of the public peace has been in danger of being
committed"
On August 5th, prior to the commencement of the proceedings against Paine and Hoch, and the
cross-summons by Paine, Dunn mentioned his application to the magistrates who suggested
that Dunn's application be postponed until after the Paine and Hoch matters had been dealt
with The outcome of all of these proceedings was that Browne was required to keep the
peace
Subsequently, Browne discovered the contents of the retainer document and
brought a libel and defamation action against Dunn alleging that the retainer of Dunn was a
sham and motivated by Dunn's personal animosity towards Browne At the trial, one of the
signatories of the retainer, Mrs Cooke, (who was also a daughter of another one of the
signatories) testified on behalf of Browne All the other signatories of the retainer, except Mr
King who was not called, testified against Browne All witnesses except Mr McCombie and
Hoch were cross-examined, but only as to the merits of the various quarrels they had with
8
Browne McCombie and Hoch were not cross-examined at all No one was cross-examined
with respect to the circumstances surrounding the signing of the retainer of Dunn The jury
found a verdict for Browne and assessed damages at 20L. Dunn successfully appealed to the
Court of Appeal Browne then appealed to the House of Lords but was unsuccessful
The lead decision of the House of Lords was written by Lord Herschell, L.C
The relevant portions of the Browne v Dunn decision written by Lord Herschell read follows
Now, my Lords, I cannot help saying that it seems to me to be absolutely essential
to the proper conduct of a cause, where it is intended to suggest that a witness is
not speaking the truth on a particular point, to direct his attention to the fact by
some questions put in cross-examination showing that that imputation is intended
to be made, and not to take his evidence and pass it by as a matter altogether
unchallenged, and then, when it is impossible for him to explain, as perhaps he
might have been able to do if such questions had been put to him, the
circumstances which it is suggested indicate that the story he tells ought not to be
believed, to argue that he is a witness unworthy of credit. My Lords, I have always
understood that if you intend to impeach a witness you are bound whilst he is in
the box, to give him an opportunity of making explanation which is open to him;
and, as it seems to me that not only a rule of professional practice in the conduct
of a case, but is essential to fair play and fair dealing with witnesses [Italics
added] Sometimes reflections have been made upon excessive cross-
examination of witnesses, and it has been complained of as undue, but it seems to
me that a cross-examination of a witness which errs in the direction of excess may
be far more fair to him than to leave him without cross-examination, and
afterwards to suggest that he is not a witness of truth, I mean upon a point on
which it is not otherwise perfectly clear that he has had full notice beforehand that
there is an intention to impeach the credibility of the store which he is telling
Lord Halsbury also commented (at page 76) on the question of the significance
of a failure to cross-examine a witness
To my mind nothing would be more absolutely unjust than not to cross-examine
witnesses upon evidence which they have given, so as to give them notice, and to
give them an opportunity of explanation, and an opportunity very often to defend
their own character, and, not having given them such an opportunity, to ask the
jury afterwards to disbelieve what they have said, although not one question has
been directed either to their credit or to the accuracy of the facts they have
deposed to
9
However, Lord Herschell described one situation where his rule might not apply
This situation has, in subsequent case law, been described as the first exception to the rule in
Browne v Dunn
Of course I do not deny for a moment that there are cases in which that notice has
been so distinctly and unmistakably given, and the point upon which he is to be
impeached, is so manifest, that it is not necessary to waste time in putting
questions to him upon it. [italics added] All I am saying is that it will not do to
impeach the credibility of a witness upon a matter on which he has not had any
opportunity of giving an explanation by reason of there having been no suggestion
whatever in the course of the case that his story is not accepted
If Lord Herschell set out the rule and the first exception, Lord Morris added (at p 79) the
second exception to the rule
My Lords, there is another point upon which I would wish to guard myself, namely,
with respect to laying down any hard-and-fast rule as regards cross-examining a
witness as a necessary preliminary to impeaching his credit. I n this case, I am
clearly of opinion that the witnesses, having given their testimony, and not having
been cross-examined, having deposed to a state of facts which is quite
reconcilable with the rest of the case, and with the fact of the retainer having been
given, it was impossible for the plaintiff to ask the jury at the trial, and it is
impossible for him to ask any legal tribunal, to say that those witnesses are not to
be credited But I can quite understand a case in which a story told by a witness
may have been so incredible and romancing a character that the most effective
cross-examination would be to ask him to leave the box [italics added] I therefore
wish it to be understood that I would not concur in ruling that it was necessary, in
order to impeach a witness's credit, that you should take him through the story
which he had told, giving him notice by the questions that you impeached his
credit.
In 1979, the Supreme Court of Canada considered the Browne v Dunn rule in
their decision in a criminal appeal, Palmer v the Queen (Supra) In Palmer, Mcintyre endorsed
the Court of Appeal decision, written by McFarlane, J.A. on behalf of the Court, at p 229, as
follows
The second ground of appeal argued was that the trial Judge should have
found that the evidence of Douglas Palmer raised at least a reasonable doubt of
his guilt. With particular reference to the three occasions to which I have just
10
referred, it was said that Palmer's evidence was not shaken in cross-examination
and it is suggested he was not specifically questioned about one or two of them
Reference was made to Browne v Dunn (1894) The Reports 67, and to R v Hart
(1932), 23 Cr App R 202 I respectfully agree with the observation of Lord Morris
in the former case at p 79
"I therefore wish it to be understood that I would not concur in ruling
that it was necessary in order to impeach a witnesses' credit, that you
should take him through the story which he had told, giving him notice by
questions that you impeached his credit."
In my opinion, the effect to be given to the absence or brevity of cross-
examination depends upon the circumstances of each case There can be no
general or absolute rule It is a matter of weight to be decided by the tribunal of
fact, vide Sam v Canadian Pacific Limited (1976) 63 D L.R (3d) 294, and cases
cited there by Robertson, J.A , at pp 315-7 In the present case Douglas Palmer
was cross-examined extensively It seems to me the circumstances are such that
it must have been foreseen his credit would be attached if he testified to his
innocence In any event, this was made plain when he was cross-examined The
trial Judge gave a careful explanation of his acceptance of the story of Ford and
rejecting that of Douglas Palmer I cannot give effect to this ground of appeal
I am in full agreement with these words and I do not consider it necessary to add
to them save to emphasize that the finding against the credibility of Palmer was
made upon much more than the evidence of these three events It was based
upon a consideration of the whole of the evidence including the full examination
and cross-examination of Palmer I would dismiss the appeal
In 1985, in a decision of this Board in the case of Taraschuk, (Supra), chaired by
Delisle, the issue involved criticisms expressed in an appraisal letter which were not raised with
the employee during the relevant period and then subsequently were not raised during the
employee's cross-examination The relevant section of the award reads, at p 162, as follows
It is important to note that the Grievor was not cross-examined with respect to
any of his evidence Counsel for the Ministry sought to later have the
supervisor testify to instances when he had been critical of the Grievor This
was ruled objectionable [The decision then proceeds to quote the above
quoted passage from Lord Herschell's decision in Browne v Dunn]
In cases where evidence has been permitted with respect to matters that were
not put in cross-examination to the appropriate witnesses, it has been recognized that the party
that failed to cross-examine (as would have been required to according to the Browne v Dunn
11
rule) but is nevertheless permitted to adduce its own evidence on the same point gains an
advantage over the other party because it: "gains the advantage of further cross-examination
of the impeached witness" This is the recognized outcome in the decision in Machado v
Berlet (Supra) Where the Court stated, at page 209, as follows
Counsel for the plaintiff submits that the films cannot now be used to impeach
the plaintiff's testimony if the rule in Browne v Dunn has been breached
Undoubtedly, there is precedent to that effect: R v Jackson and Woods
(1974), 20 C C C (2d) 113 ant. H C J ) It seems to me, however, that the
more prevalent practice is to permit the impeaching evidence to be tendered
(R v Dyck, [1970] 2 C C C 283, 70 WW R 449, 8 C R N S 1919
(B C C.A )), subject to the right of the plaintiff to call reply evidence to explain
the impeaching evidence and subject to the right of adverse comment to the
jury by both plaintiff's counsel and the judge during address and charge I will
adopt that practice to this case I note, however, that opposing counsel gains
a further advantage by following this procedure He gains the advantage of
further cross-examination of the impeached witness
In the decision of Whitehead in Re Laidlaw (Supra), the arbitrator found that the
Browne v Dunn rule does not constitute a mere legal technicality but rather that its breach
constitutes a
fundamental defect in a cross-examination [The arbitrator found that] the rule
in Brown v Dunn is also settled law in the courts in Canada (Sopinka, Lederman
and Bryant, cited above, at p 876), in the courts in Ontario (United Cigar Stores
Ltd v Buller & Hughes, cited above, at pp 147-8) and in the courts in other
provinces On the basis of the authorities referred to me, I also conclude that the
rule in Browne v Dunn is now a generally accepted principle of arbital
jurisprudence in Canada (Gorsky, Usprich and Brandt, at pp 10 - 46,
The arbitrator found that the Union did not give the witnesses
sufficient opportunity to provide any clarifications or explanations of their
evidence in light of the evidence the union intended to lead later
In the Re Laidlaw case, Mr Whitehead further considered the Union's argument
that he ought to exercise his statutory discretion to admit evidence in dispute even if the rule in
Browne v Dunn has been violated because
12
the evidence is "proper" pursuant to s 45(8 1), para 10 of the Labour Relations
Act and in order that the "real substance" of the dispute can be resolved
pursuant to s 45 (8), para 1 of the Act.
However, in that case, Counsel for the Employer argued that an expanded right
of reply would not cure the resulting prejudice to the employer's witnesses because the Union
would end up with two opportunities at cross-examination of the employer's witnesses, in effect
splitting the union's case The arbitrator found, at pp 158-159, that;
in this connection, in the normal course of an arbitration hearing, the
obligation to put a witness, and the party calling that witness, on notice in cross-
examination of the witness, that the evidence will be called to contradict evidence
given and therefore to challenge the witness's credibility and to give the witness an
opportunity to respond to that evidence, is a fundamental principle of fairness and
not a mere legal technicality
I find that counsel for the employer was entitled to assume that standard labour
arbitration practices and rules of evidence were in effect during the hearing
including the rule in Browne v Dunn I also find that the representative for the
union ought reasonably to have been aware of the high probability that an
arbitrator would enforce standard practices and rules including the rule in Browne
v Dunn Finally, I find that the employer would be prejudiced in the circumstances
if I admitted the evidence sought by the union contrary to this standard rule
I also agree with the submissions of counsel for the employer that a board of
arbitration should not exercise its powers pursuant to S 45 (8), para.1 of the Act to
address the "real substance" of the differences in circumstances where the effect of
addressing the real substance would be to deny a party or a witness a fair hearing
The Laidlaw decision has been followed in other cases, including by a decision
by Gordon Simmons in Avenue /I Community (Supra), provided at this hearing by Union
Counsel
In the case of R v Verney, (Supra) Mr Justice Finlayson found, at p 288,
(Justices McKinlay and Abella concurring), that the Browne v Dunn case does not create an
absolute rule but rather "is a rule of fairness that prevents the 'ambush' of a witness" Mr
Justice Finlayson's concluded as follows
[28] This admonition, based on a civil case, Browne v Dunn, [1894] 6 The Reports
27, was not warranted in this case Browne v Dunn is a rule of fairness that
13
prevents the "ambush" of a witness by not giving him an opportunity to state his
position with respect to later evidence which contradicts him on an essential
matter It is not, however, an absolute rule and counsel must not feel obliged to
slog through a witness's evidence-in-chief putting him on notice of every detail that
the defence does not accept. Defence counsel must be free to use his own
judgment about how to cross-examine a hostile witness Having the witness
repeat in cross-examination, everything he said in chief, is rarely the tactic of
choice For a fuller discussion on this point, see R v Palmer [1980] 1 S C R 759;
30 N R 81,50 C C C (3d) 193, at pp 209-210 C C C
In Hurd and Hewitt (Supra), Mr Justice Griffiths of the Ontario Court of Appeal
considered the application of the Browne v Dunn decision and the subsequent Supreme Court
of Canada decision in Palmer He appeared to apply the Morris exception in Browne v Dunn
to the facts of the case before him and he concluded, at p 652, as follows
My analysis of these authorities leads to the conclusion that there are no absolute
rules in Canada as to the questioning of witnesses at hearings or trials adjudicating
between parties The argument that a party puts after failing to ask obvious
questions of a witness may be so severely impaired as to be characterized as
incredible Yet, the evidence of a witness may be so obviously flawed that a
party's best interest lies in leaving that evidence to stand naked I n either event,
the tribunal must assess the evidence and adjudicate upon the rights of the parties
as those rights appear from that evidence, and not the evidence minus that which
appears unfair to third parties
The Ontario Labour Board examined the application of the Browne v Dunn
principle in 1996 in the decision in Re The Donwood Institute, (Supra) (Ian Springate) The
Board did not prevent Counsel from asking certain questions on the basis of the Browne v
Dunn argument. In my opinion, it was implicit in the Board's decision that the questions were
permitted because the subject matter of the statement had been covered during the cross-
examination of the witness even though the statement itself had not been put to the witness
The relevant portions of the Board's decision read (on pages 2, 4, 7 respectively) as follows
This award addresses four objections raised by counsel for the Employer
respecting evidence given by the grievor Three of the objections were based on
the fact that statements made by the grievor about what she was told by Ms
Sabloff were not put to Ms Sabloff when she was being cross-examined The
other objection concerned a statement the grievor claimed was made to her by
14
Mr Larry Jelinek, an employee called as a witness by the Employer, which was
not put to Mr Jelinek when he was being cross-examined The arbitration board
made oral rulings with respect to two objections and reserved its rulings with
respect to the other two Counsel for the Employer asked that the oral rulings be
confirmed in writing
* * *
It is clear from the R v Palmer and Hurd v Hewitt cases that in Ontario
there is no absolute rule respecting the cross-examination of witnesses prior to
attacking their credibility Further, there is no absolute requirement that a tribunal
be fair to an individual witness Logically, however, there is a requirement that
parties to an arbitration proceeding be assured of a fair hearing Nothing in the
cases referred to above detracts from this requirement. Ms Sabloff was the
senior representative of the Employer at MAARS We believe it would be unfair
to the Employer to rely on a statement alleged to have been made by Ms Sabloff
which directly undermines the Employer's position if during her testimony Ms
Sabloff was not given an opportunity to address either the alleged statement itself
or the subject matter of the alleged statement.
* * *
We do not believe there is a legal requirement that each and every alleged
exchange between the grievor and Ms Sabloff that the grievor mentioned in her
evidence had to be put to Ms Sabloff Further it is not apparent at this point what
impact, if any, the alleged statement by Ms Sabloff might have in these
proceedings Given these considerations we propose to take the statement in as
evidence and leave it to the conclusion of the proceedings to decide what weight,
if any, to give to the statement, including the impact of the fact that the statement
was not put to Ms Sabloff
In Green v Canada, (Supra), Mr Justice Cullen reviewed the decision of an
adjudicator in a termination of employment case In that case, it was alleged by Counsel for
the terminated employee that the adjudicator had erred in allowing counsel for the employer, in
final submissions, to raise issues relating to the credibility of the employee's evidence which
had not been specifically challenged The Court decided, (commencing at p 3), as follows
This rule was violated, the applicant submits, because the adjudicator concluded
that the reason that the applicant left the Tower was not because he thought that it
was permissible to do so based on a previous authorization for a colleague, Mr
Lariviere, to do so Mr Lariviere had not been cross-examined on the evidence
that contradicted the applicant's evidence on this point. If counsel is considering
the impeachment of the credibility of a witness by calling independent evidence,
the witness must be confronted with this evidence while she or he is still in the
witness box. Thus, the adjudicator improperly relied on the contradictory evidence
in making her finding of credibility against the applicant.
15
* * *
The statute clearly provides that the adjudicator is not bound by the strict rules of
evidence such as are applied in courts of law
14 The standard of review regarding the adjudicator's approach to the evidence is
thus lower that that applied to a court.
15 The adjudicator allowed counsel to the employer, in closing submissions, to
raise issues of credibility on evidence not specifically challenged Counsel to
the applicant submits that the consideration of evidence that should have
excluded under the rule in Browne v Dunn led to the finding of credibility
against the applicant. Counsel further submits that this finding was the
fundamental reason why the adjudicator did not reinstate the applicant.
Counsel submits that the adjudicator cannot rely on evidence inadmissible in a
court of law in making a finding fundamental to her decision in the case
16 However, the credibility finding, though an important one, was not the sole
reason why the adjudicator did not reinstate the applicant. (emphasis added) It
is stated clearly in the adjudicator's reasons that also fundamental to her
decision was the breaking of the bond of trust between the applicant and the
employer, the gravity of the misdemeanour, as well as her assessment of the
applicant's appreciation of the gravity of his actions
17 Because the credibility finding was not at the heart of the adjudicator's
decision, I can find no authority to interfere with this aspect of the decision
Since the credibility finding was not the sole basis for the adjudicator's decision,
the Court chose not to interfere with the decision even though it appeared that the Court might
have come to a different determination with respect to the evidentiary Browne v Dunn issue
It is clear from the cases referred to by Counsel in this hearing that the Browne
v Dunn rule applies in Canada and more specifically in Ontario The Re Laidlaw decision
reviews in some detail the authorities in support of this conclusion Moreover, it is also clear
from the cases that the rule is not an absolute rule but rather that its application involves a
judicial exercise of discretion The cases also set out some parameters for the exercise of this
discretion and these may be summarized as follows
16
1 The Browne v Dunn rule prevents the subsequent calling of evidence with the
intention of impeaching a prior witness when there was no cross-examination of the prior
witness on any of the evidence relating to the issue (Lord Herschell in Browne v Dunn and
Finlayson J , in R v Verney),
2 The rule prevents the ambush of a prior witness by later evidence which
contradicts that witness on an essential matter where there was no cross-examination of the
prior witness on that essential matter; (Finlayson J , in R v Verney),
3 The rule prevents the calling of evidence to contradict a prior witness and
challenge that witness's credibility, where the prior witness was not allowed the opportunity to
respond to that evidence The rule is thus one of the fundamental requirements of a quasi-
judicial proceeding, namely, a requirement of natural justice and fairness (Whitehead, RE
Laidlaw) In this sense, it is a rule "essential to fair play and fair dealing with witnesses" (Lord
Herschell, L.C , in Browne v Dunn),
4 The rule does not require counsel to 'slog' through every detail of a case in
cross-examination (Finlayson J , in R v Verney),
5 The rule does not preclude the calling of evidence with respect to the
contents of a statement, which contents were dealt with in a prior cross-examination of the
witness (whose credibility is to be impeached), even though the entire actual statement was not
specifically put to the witness being cross-examined (Springate, in RE Donwood),
6 The rule does not preclude the calling of specific evidence which seeks to
challenge a prior witness' credibility if that witness' credibility was extensively challenged, albeit
not by the specific evidence in question but through other evidence (McFarlane, J.A. in Palmer
v the Queen),
7 The rule does not preclude the calling of subsequent evidence to impeach the
prior witness where the evidence of the prior witness was so obviously flawed, "so incredible
17
and romancing a character" that better judgement suggested it ought to have been left without
being cross-examined upon (Lord Morris, Browne v Dunn)
In the case before me, there was no indication given to the witness in his cross-
examination that his credibility was to be impeached by the employer's subsequent evidence
with respect to an essential matter; namely, the Grievor's failure to grieve the unexpected
termination of his training assignment. The notice to impeach must be clear and
unambiguous On the particular facts of this case, the situation cannot be fixed by allowing the
Grievor to testify in reply since that would force the Union, as it would have forced the
Employer in Re Laidlaw, to split its case and would force the Grievor to be subjected to two
sets of cross-examinations In conclusion, I find that the rule of Browne v Dunn applies to the
facts of this case I find that the Employer has not met its obligation to put the Grievor on
notice of the intended challenge to the veracity of his evidence relating to his discussions with
Mr Broughton In particular, I find that evidence relating to the Grievor's discussions with Mr
Broughton about the filing of a grievance with respect to the termination of the Grievor's
training assignment and the particulars of the Ministry's 'work to home' distance requirement
are inadmissible for all of the reasons set out above This hearing will continue on a date to be
scheduled by the Board
Dated at Toronto, this 12th day of June, 2001
~~~A:
Eva E Marszewski, Vice-Chair
18