HomeMy WebLinkAbout2001-0925.Patterson.03-12-01 Decision
Crown Employees Commission de ~~
Grievance Settlement reglement des griefs
Board des employes de la
Couronne
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GSB# 2001-0925 2001-0949
UNION# 01C606 01C621 01C622
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontano PublIc ServIce Employees Umon
(Patterson) Grievor
- and -
The Crown In RIght of Ontano
(Mimstry of PublIc Safety and Secunty) Employer
BEFORE Deborah LeIghton Vice-Chair
FOR THE UNION Mary MacKInnon
Barnster and SOlICItor
FOR THE EMPLOYER Chnstopher Jodhan
Counsel
Management Board Secretanat
HEARING October 29 2003
SubmIssIOn receIved November 3 2003
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DECISION
There are three gnevances before the board, two IndIVIdual gnevances of JulIe Patterson dated
July 3 2001 allegIng, inter alia, dISCnmInatIOn and harassment and a group gnevance dated
August 24 2001 allegIng dISCnmInatIOn of the female correctIOnal officers of the Sault St. Mane
JaIl ThIS prelImInary decIsIOn addresses the employer's motIOn argued at the first day Into the
heanng of thIS matter whIch, essentIally seeks an order from the board lImItIng the scope of the
eVIdence, partIcularly requITIng the board to exclude eVIdence on allegatIOns whIch are older
than one year before the gnevance was filed or before July 2000 The umon opposes the motIOn
to restnct the scope of the eVIdence and takes the posItIOn that eVIdence on all the partIculars
gOIng back as far as 1987 should be permItted to be tendered to the board.
The partIes agreed to the folloWIng facts for the purposes of the motIOn
1) The gnevors have each filed gnevances In the past related to vanous
Issues IncludIng gnevances wIth dISCnmInatIOn on theIr face
2) The gnevors raised theIr concerns both formally through gnevances
and Informally through dIscussIOns wIth vanous management officIals,
3) The gnevors were unsatIsfied wIth the actIOns of management In
regard to theIr complaInts and as such felt there was no pOInt In
bnngIng new concerns to management;
4) The gnevors were also concerned about the "code" among officers that
they should not "rat out" fellow officers
Counsel for the employer argued referrIng specIfically to partIculars provIded by the
umon that allegatIOns refernng back to IncIdents occurnng In 1987 and through to IncIdents
occurnng In 2000 were not tImely The essence of hIS argument was that the employer would be
preJudIced In respondIng to these allegatIOns and the preJudIce outweIghs the probatIve value of
such eVIdence Counsel also argued that some of the allegatIOns and the partIculars put forward
by the umon were not relevant to the pnmary Issue of whether or not the correctIOnal officers
had suffered dISCnmInatIOn or that there was a pattern of dISCnmInatIOn In the Sault St. Mane
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JaIl FInally counsel argued that eVIdence regardIng allegatIons subsequent to the filIng of the
gnevance, should not be permItted at the heanng Into thIS matter Counsel relIed on OPSEU
(Ross) and The Crown in Right of Ontario (Ministry of Solicitor General and Correctional
Services) (2003)GSB# 2690/96 et al (HerlIch) Religious Hospitallers of Hotel Dieu of St.
Joseph of the Diocese of London and ONA. (Curtis) (1995) 47 L AC 4th 84 (Watters)
Ontario Liquor Board Employee s Union (Koonings Fronel) and The Crown and Right of
Ontario (Liquor Control Board of Ontario) GSB# 3483/92 et al (Stewart)
In summary counsel for the umon argued that the board should exerCIse ItS dIscretIOn to
admIt eVIdence of allegatIOns of dISCnmInatIOn datIng back to 1987 Counsel argued that the
onus IS on the complaInants to prove dISCnmInatIOn and that It would preJudIce the IndIVIduals
not to hear all the eVIdence In thIS case Counsel argued further that the partIes before me agreed
In theIr collectIve agreement that vIctIms of sexual harassment may be more preJudIced than the
employer specIfically proVIdIng that tIme lImIts do not apply as set out In ArtIcle 222 1
provIded the complaInt IS made wIthIn a reasonable tIme She noted that employees often
hesItate to file gnevances In such cases and that the code among coworkers In correctIOns not to
"rat" out fellow officers acts as a deterrent to filIng complaInts Counsel argued further that the
tImelIness of the eVIdence must be subJect to a reasonableness test not a calendar Further
counsel argued that there was no eVIdence of actual preJudIce, that eVIdence had been destroyed
or IndIVIduals were deceased. GIven the absence of actual eVIdence of preJudIce the balance
favours the gnevors Counsel also argued that the employer had waived the nght to obJect to the
"age" of the allegatIOns by not raiSIng the Issue at the stage two or earlIer Counsel relIed on
OP SEU (Chan) and Crown in Right of Ontario (Ministry of Education) GSB# 1990/90
2269/90 OPSEU (Ross) and CrolJ,n in Right of Ontario (Ministry of the Solicitor General and
Correctional Services) GSB#2690/96 et al Hotel Dieu Grace Hospital and ONA. (Bennett) 62
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L.AC (4th) 164 Canada Post and CUP W (Racky) (unreported, 1997) (PIcher) City of
Toronto and CUPE (Local 79) (Hayden) (unreported, 1996) (DevlIn)
DECISION
HavIng carefully consIdered the submIssIOn of the partIes I have concluded that the
umon's Waiver argument cannot succeed. The employer was not provIded wIth partIculars untIl
2003 and there was no eVIdence provIded to the board that they had knowledge that the gnevors
Intended to make complaInts about alleged dISCnmInatIOn gOIng back to as early 1987
I am of the VIew that thIS motIOn IS essentIally about the scope of the eVIdence In a case
allegIng dISCnmInatIOn agaInst female correctIOns officers The employer wants the eVIdence
lImIted to allegatIOns dunng the penod of one year pnor to the date of the gnevances The umon
wants to be able to put eVIdence In that dates back to 1987
The reasomng In the Hotel-Dieu Grace Hospital case IS helpful ArbItrator PIcher said,
consIdenng the scope of eVIdence In a case allegIng racIal dISCnmInatIOn "that It IS Important In
thIS case to stnke a fair balance between the concerns of both partIes" (supra) In that case the
umon wIshed to adduce eVIdence datIng back to the gnevor' s hIre date or some SIX years before
the gnevance was filed. ArbItrator PIcher noted that thIS was not a case where the gnevor was
unaware of her nghts or wIthout a reasonable basIs to conclude that she was allegedly the vIctIm
of dISCnmInatIOn. In the case before me documents submItted to the board IndIcate that Ms
Patterson was well aware of her nghts to file gnevances of alleged dISCnmInatIOn as she dId so
In 1991 1992, 1993 and 1994 The agreed statement of facts IndIcates that all of the gnevors
have prevIOusly filed gnevances allegIng dISCnmInatIOn and they raised the Issues Informally
wIth management. There was no explanatIOn or eVIdence provIded for why the gnevors waited
so long to gneve except that they were concerned about "rattIng" on theIr fellow officers ThIS IS
not persuasIve gIven the agreed statement of facts IndIcates that they all dId complaIn at earlIer
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tImes both by gneVIng and complaInIng Informally to management. Thus, lIke the gnevor In
Hotel-Dieu Grace Hospital they were aware of theIr nght to gneve and had a reasonable basIs to
conclude that they had been allegedly vIctIms of dISCnmInatIOn well before July 2001
The board In Hotel-Dieu Grace Hospital stated that It had concerns about allowIng
eVIdence of a full SIX years because of the volume of eVIdence The concerns were eqUItable and
procedural However the board also recogmzed the umon's need In such a case to show the
pattern of dISCnmInatIOn.
I must stnke a fair balance between the employer's and the umon's respectIve Interests
GIven the gnevors were aware of theIr nghts, and In the absence of any eVIdence to JustIfy the
extreme delay In gneVIng the events dunng the penod of 1987 to 1996 I have no dIfficulty In
decIdIng that, In thIS partIcular case, the allegatIOns relatIng back to 1987 through to 1996 are
sImply too old. The more dIfficult questIOn IS where to draw the lIne between 1996 and 2000
Both partIes descnbed thIS case as one allegIng a pOIsoned workplace I am therefore cogmzant
of the umon's need to present eVIdence to support a pattern of dISCnmInatIOn. The Hotel-Dieu
Grace Hospital case allowed eVIdence datIng back three years After reVIeWIng other cases put
before me by the umon It IS clear that the Gnevance Settlement Board has allowed eVIdence
datIng back three years, where the allegatIOns related to racIal harassment. In OPSEU (Chan)
supra Vice-chair DIssanayake held that the "board has a wIde latItude to hear and consIder any
eVIdence whIch It consIders relevant" and he cIted vIce-chair Kennedy In Re Taylor-Baptist GSB
163/87 as follows
Once the gnevance IS properly before us wIthIn the procedures laid down In
the collectIve agreement, the appropnate scope of eVIdence IS governed by the
normal pnncIples dealIng wIth the admIssIbIlIty of eVIdence and ItS relevance
to the Issues to be arbItrated. In the context of labour relatIOns, matters cannot
and ought not to be determIned In a vacuum, and past events are customanly
covered In the eVIdence In order to place a partIcular IncIdent that IS the
subJ ect matter of a gnevance Into ItS proper context In the lIght of the on-
gOIng employment relatIOnshIp It IS Immatenal that those past events can no
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longer form the basIs of a gnevance due to the tIme lImIt provIsIOns of the
collectIve agreement.
It IS clear that the gnevances are properly before me and the only Issue IS the scope of the
eVIdence Thus In balancIng the Interests of the umon to prove ItS case of an alleged pOIsoned
work place and the employer's nght to defend Itself I have decIded that the umon may put
eVIdence In regardIng IncIdents of alleged dISCnmInatIOn as may be relevant datIng back to
August 1998 - a penod of three years before the gnevances were filed.
With regard to the employer's request to lImIt eVIdence on allegatIOns that It argues IS not
relevant, I am not In a posItIOn to decIde thIS In a prelImInary award. Without the context of the
eVIdence, a rulIng here IS premature LIkeWIse, It IS premature to make a decIsIOn on allegatIOns
(supra) anSIng after the gnevances As ArbItrator Watters stated In Hotel Dieu (St. Joseph) the
gUIdIng pnncIple In post-gnevance eVIdence IS whether the eVIdence IS relevant. I am not In a
posItIOn to make a rulIng on thIS now
Dated at Toronto thIS 18t day of December 2003
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