HomeMy WebLinkAbout2016-2421.Jackson et al.17-08-15 Decision
Crown Employees
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Commission de
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GSB#2016-2421
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Association of Management, Administrative and
Professional Crown Employees of Ontario
(Jackson et al) Association
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The Crown in Right of Ontario
(Ministry of Finance) Employer
BEFORE Nimal Dissanayake Arbitrator
FOR THE
ASSOCIATION
Kelly Doctor
Goldblatt Partners LLP
Counsel
FOR THE EMPLOYER Omar Shahab
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING August 2, 2017
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Decision
[1] Four employees at the Financial Services Commission of Ontario (“FSCO”),
Christopher Jackson, Salvatore Maietta, Anna Teskey and Nick Vescio filed a
group dispute on January 24, 2017. The Board was advised that Ms. Teskey’s
dispute had subsequently been resolved.
[2] When the dispute as it related to the three remaining complainants came before
the Board, the parties requested that the Board determine two preliminary
motions by the Association. However, following some discussion, the parties
advised that the motion relating to production had been resolved. That left for
determination a motion for bifurcation of the proceeding. The facts material are
not controversial and were presented through the opening statements and
documents. In this decision, only the evidence that is relevant to the bifurcation
issue will be reviewed.
[3] The complainants had been employed as mediators at the Dispute Resolution
Branch of FSCO. Their mediator position was classified at level 6. In November
2014 legislation was enacted, which resulted in the gradual winding down of the
FSCO Dispute Resolution Branch, and the removal of the mediation function
from FSCO. Mediator positions at FSCO became surplus. The complainants
received notice of layoff dated April 14, 2016, advising that their positions are
declared surplus effective April 14, 2016, with a layoff date of October 14, 2016.
The letter also included information about options available to the complainants,
including the option of identifying vacant positions for targeted direct assignment
under article 27.8.
[4] Article 27.8.1 provides:
An employee who has received notice of lay-off in accordance with this Article
shall be assigned to a vacant position during his or her notice period provided
that:
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(a) The employee identifies the vacancy in accordance with Article 27.8.3,
and indicates that he/she has received notice of layoff and is eligible for
targeted direct assignment; and
(b) the employee meets the entry level qualifications for the position; and
(c) the vacancy is at the same level of the employee’s home position or
any lower levels;
(d) there is no other AMAPCEO unit employee who has a greater length
of continuous service and who is eligible for targeted direct assignment to
the vacancy pursuant to this Article.
[5] Each complainant identified a vacancy that had been posted for one position of
mediator at the Office of the Independent Police Review Director, Ministry of the
Attorney General, for targeted direct assignment. (Hereinafter “targeted
position”). It is not in dispute that the targeted position was also classified at
level 6, that Mr. Jackson was the most senior of the complainants, and that there
were no other bargaining unit employees with greater seniority who were eligible
for targeted direct assignment to the targeted position.
[6] The competition for the targeted position closed in September 2016.
Subsequently on October 13, 2016, Ms. Tina Liu, Program Advisor, Transition &
Security Office, HR Program Management Branch HR Service Delivery Division,
Ontario Shared Services, Ministry of Government and Consumer Services,
wrote to Mr. Michael Fernandez, the hiring manager for the targeted position,
stating, “The following employees who have been assessed as entry level
qualified is (sic) being referred to your vacancy through the TDA process”. Ms.
Liu attached relevant documentation for the four employees she was referring
for targeted direct assignment, and requested that Mr. Fernandez provide
information including the contact information for the Branch contact person for
the start date, location of position, and name and contact information of the
Reporting Manager, “…if you agree that the employees are entry-level qualified
for the position”. The three complainants were among the four employees
referred by Ms. Liu for targeted direct assignment.
[7] The documentary evidence indicates that Mr. Fernandez also received a
package, including 6 selection criteria for the vacant position. He was required,
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inter alia, to provide no later than October 17, 2016, an assessment rationale for
each employee assessed as not meeting the entry-level qualifications for the
position. It suffices to record that Mr. Fernandez responded, finding that all four
employees referred for targeted direct assignment did not meet the entry-level
qualifications for the vacant mediator position.
[8] On October 24, 2016, Ms. Liu responded to Mr. Fernandez, stating “We have
reviewed the assessment rationale and have some concerns with the content.”
She reviewed in some detail the skills, knowledge and experience of each of the
four employees as listed in the documentation, and stated, inter alia, “Based on
the information provided above outlining why we believe the employees are
entry level qualified, please re-evaluate the employees’ information package and
reconsider your assessment.” Ms. Liu also wrote:
If you continue to assess the employees as Not Qualified, please note
that in the event of a dispute regarding this assessment, you may be
required to provide additional information outlining why the employee was
deemed not qualified for the position. Please provide a signed and dated
copy of the TDA Referral Outcome Sheet and revised assessment
rationales.
[9] The following day, October 25, 2016, Mr. Fernandez informed that he had been
advised “by the Chief Operations Officer, Michael Mamo, in conjunction with the
decision of the Independent Policy Review Director, Gerry McNeilly, to notify you
that we are cancelling the mediator competition. There have been some recent
developments that they advise to keep the position open and available once it is
confirmed what the agency’s operational needs are for this position”. Mr.
Fernandez listed a number of external and internal activities, which would
impact on the operational needs.
[10] Since June 2015, the targeted position had been filled by an individual, MC, who
had been seconded to the position from her home position which was at the
MCP level. Through renewals, she was still in the position at the time of the
instant hearing. She was provided third party notice by the Association, but did
not attend the hearing. The Board was advised that subsequently complainants
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Maietta and Vescio were matched to positions classified lower at level 5 and
were working in those positions. However, complainant Jackson remained
without a job as of the date of the hearing.
[11] On the merits of the group dispute, the parties have joined two issues.
(1) The Association alleges that the cancellation of the competition for the
targeted mediator position was a bad faith exercise of management rights by the
employer, which circumvented the collective agreement rights of the
complainants to targeted direct assignment under article 27.8. The employer
denies that allegation and asserts that the competition was cancelled at an early
stage for operational reasons, and was a legitimate and bona fide exercise of
management rights.
(2) The Association asserts that based on the skills, knowledge and experience
of the complainants disclosed by the information in their submission, and the six
selection criteria, they clearly met the entry level qualifications for the targeted
mediator position. The Employer disagrees. It asserts that the mediation the
complainants performed relating to disputes between individuals and insurers
had to do with financial issues. It was very different from the mediation duties in
the targeted position in the context of civilian police review. Moreover the
targeted position also performed other duties such as preparation of reviews and
audits, and duties relating to community outreach.
[12] The Association motion that the Board bifurcate the proceeding and initially hear
and determine the dispute relating to the cancellation of the job competition.
Association counsel pointed out that if the Board concludes that the cancellation
of the competition was a legitimate exercise of the employer’s management
rights, that would result in the dismissal of the group dispute. There would be no
need for the Board to determine the second issue as to whether the
complainants met the entry level qualifications for the position.
[13] Association counsel submitted that the primary considerations in determining the
motion for bifurcation are fairness and efficiency. She argued that the criteria of
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efficiency favours bifurcation in this case. She submitted that on the issue of
entry level qualifications, each of the three complainants would be testifying
about his skills, knowledge and experience in relation to each of the six selection
criteria. She estimated that each complainant would be testifying on those
issues over one to two days. Including time for submissions, that issue would
consume at least six hearing days. If the Board concludes that the employee’s
decision to cancel the competition was not a violation, all of that would be a
waste.
[14] The employer opposed bifurcation. Counsel submitted that if the motion is
upheld, the Chief Operations Officer, Mr. Michael Mamo, would be required to
testify twice, once on the issue of the competition cancellation, and again on the
entry level qualification issue. That would be unfair to the witness. It would also
be inefficient because there would be duplication of the same evidence, since
there would be significant overlap in the evidence going to the two issues.
[15] Counsel argued also that bifurcation would result in delay. The Board would
hear the evidence and submissions on the cancellation issue and reserve. It
would then need time to issue its decision, before turning to the entry level
qualifications issue. It would be much more expeditious to hear evidence and
submissions on both issues at one hearing, and have one decision from the
Board.
[16] Employer counsel submitted that Mr. Mamo’s testimony on the entry level
qualification issue would not be lengthy. He also did not expect the testimony of
the complainants on that issue to be as lengthy as Association counsel
anticipates.
[17] Finally, employer counsel submits that any potential efficiency to be gained by
bifurcation is speculative. Efficiency would result only if the Board holds in
favour of the employer on the cancellation issue. If the Association’s position on
that is upheld, inefficiency and delay would result.
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[18] The employer relied on the following authorities: Re OPSEU and the Ministry of
Government & Consumer Services, GSB File No: 2015-2664 (Dissanayake); Re
Loyalist College of Applied Arts and Technology (2003) 122 L.A.C. (4th) 155
(Knopf); Re Cargill Foods, (2009) 185 L.A.C. (4th) 167 (Marcotte); Re Toronto
Star Newspapers Ltd. (2000) 60 C.L.A.S. 384 (Dissanayake).
[19] In Re OPSEU and the Ministry of Government and Consumer Services (supra)
at paragraphs 27 and 28 the Board stated as follows:
[27] S. 48(1) of the Crown Employees Collective Bargaining Act provides that
the Board “Shall determine its own practice and procedure, but shall give
full opportunity to the parties to any proceeding to present their evidence
and to make submissions”. In exercising this statutory power in relation
to the issue of bifurcation, the Board is required to take into account
practical considerations such as economy of time, resources and
expenses. However, those considerations must be subject to the
statutory obligation to give to the parties, the full opportunity to present
their evidence and submissions. There has to be a balancing of
considerations of savings and efficiency on the one hand, and fairness
on the other hand.
[28] In Re East and L.C.B.O., (2005) 142 L.A.C. (4th) 442 (Dissanayake), the
Board reviewed the case law, including the following statement by Vice-
Chair Harris in Re Stewart (supra) at para.8:
In deciding whether to bifurcate proceedings the Board seeks to
maximize efficiency in the hearing process. If the early resolution
of an issue may be dispositive of the matters before it, then
bifurcation is a useful procedural tool, provided there is no
unfairness to any party in following such a procedure.
[20] The Board reviewed the jurisprudence and wrote at para.35:
[35] In applying the principles relating to bifurcation that emerge from the
authorities, I first note that the instant case is distinguishable from most
of the authorities cited, in one significant respect. In those cases, the
consideration was whether the decision on a preliminary issue to be
bifurcated would be dispositive of, or render irrelevant, the merits of the
grievance. In the instant case, the employer’s proposed no prima facie
case motion is not a “preliminary” issue in that sense. The union has
challenged the employer’s decision in a number of ways. Some are
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based on a claimed right to PRB under the provisions of the collective
agreement – the “contractual claims”, as counsel called it. The employer
has conceded that one such claim, based on Appendix 11 to the
collective agreement would survive its no prima facie case motion. In
addition the union has challenged the employer’s decision based on the
equitable doctrine of estoppel and the prohibition of discrimination in the
collective agreement and the Human Rights Code. It is agreed that the
estoppel and discrimination allegations would also survive a decision
upholding the employer’s motion. The employer’s attempt is to hive off
some of the claims of the union and hear them first.
[21] The Board found that in the particular circumstances of that case bifurcation
would result in unfairness to the union and would be a denial of natural justice.
It also found that the evidence is intertwined with all of the claims asserted by
the union. Therefore, there would be duplication of evidence and no efficiency
to be gained. The employer’s motion for bifurcation was denied.
[22] In Re Loyalist College of Applied Arts & Technology, (supra) the Board
concluded in relation to bifurcation of an alleged breach of a last chance
agreement and an allegation relating to improper use of the employer’s
computer, “there would not be any “efficiencies” created, and any efficiencies
would result only if the union loses on the first aspect of the case”. The Board
concluded that “it would appear to be too great a risk to potentially delay the
process on the chance that some efficiency may be created.” (See, para. 11).
[23] In Re Cargill Foods (supra), a motion to bifurcate a preliminary issue alleging
that discipline was void ab initio due to failure to provide union representation at
a disciplinary meeting, and the issue of just cause for the discipline was denied
on the grounds that a number of witnesses would have to testify twice, and that
it would be impractical and unnecessarily stressful on the witnesses.
[24] In Re Toronto Star Newspapers Ltd. (supra), the arbitrator dismissed the union’s
motion for bifurcation of the issues of liability and remedy, concluding that “in
this particular case the issues of liability and remedy are so inextricably bound
together.” It was also stated, “One reason in favour of bifurcation is that if no
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liability is found, the evidence received on issues of remedy become moot. I am
satisfied that such “wasted” evidence, if any, in this case would be very minimal.
On the other hand, bifurcation will result in significant delay in the event liability
is found.” (para. 16)
[25] The case law clearly indicates that whether or not it is appropriate to bifurcate is
a decision to be made having regard to the particular circumstances of a given
case. This is not a case where the two issues by themselves are intertwined.
One issue is about the reason(s) for cancellation of a job competition that had
been posted. The second issue is about whether or not three individuals met
the entry level qualifications for that position. Employer counsel asserted that
Mr. Mamo would be testifying about the creation of the Office of the Independent
Police Review Director, its purpose and legislative mandate, and the duties and
responsibilities of mediators in that office. He stated that such evidence would
be relevant for both issues. On that basis he argued that if the issues are
bifurcated, there would be repetition of the same evidence. Mr. Mamo would be
required to adduce the same evidence twice. This would not only be wasteful, it
would be unfair to the witness. This potential for unfairness and inefficiency
would be avoided if all issues in the dispute are heard and determined at once.
[26] The Board is of the view that the inefficiencies anticipated by counsel do not
have to necessarily result from bifurcation in this case. Evidence tendered in the
first issue may be relied on by the parties and the Board, in relation to the
second issue. Under the Crown Employees Collective Bargaining Act the Board
has authority to determine that process to be appropriate in this case. Then the
witness would be required to testify in the second phase, only on issues relevant
to the second issue not adduced in the first phase. I am satisfied that with that
process in place any overlap in the evidence by Mr. Mamo between the two
issues in this case would be minimal. The documentary evidence seems to
indicate that the decision maker in relation to entry level qualifications was Mr.
Fernandez, the hiring manager, and not Mr. Mamo. Employer counsel did not
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suggest otherwise. Therefore, it is unlikely that Mr. Mamo would have
substantial testimony to offer about that decision itself.
[27] Arbitrators have considered the imposition of unnecessary stress on a witness
by requiring him/her to testify twice at the hearing as a factor favouring refusal of
bifurcation. See, Re Cargill Foods (supra). However, it is established in the
case law that there has to be a balancing of considerations of savings and
efficiency on the one hand, and fairness on the other. This is not a case about
theft of employer property, as Re Cargill Foods was. In cases such as theft,
physical or sexual assault, discrimination on prohibited grounds, harassment
etc., witnesses would be particularly subjected to stress, especially when under
cross-examination. This is not such a case. The evidence is about
management decisions on filling a vacant position and about employees’
qualifications vis-à-vis duties of a position. It is more appropriate to describe it
as one of inconvenience to the witness, rather than a matter of unfairness.
[28] If the proceeding is bifurcated, and the employer is successful on the first issue,
that would end this proceeding. However, that by itself is not a reason to not
bifurcate. An assessment must be made on what is more efficient overall in this
particular case. I agree with Association counsel’s reasoning that the dispute
about entry level qualifications would entail substantial testimony from each of
the three complainants. There would also be some detailed comparison of the
employees’ knowledge, skill and experience with the duties of the targeted
position, and about whether the employees’ skills are transferable. That would
require multiple days of hearing. All of that would be wasteful, if the dispute is
dismissed following the determination of the first issue.
[29] I am satisfied that the testimony relating to the issue of cancellation of the job
posting will not be very time consuming. Much of that evidence could be applied
to the second issue, to the extent it is relevant. On balance, I conclude that this
is an appropriate case for bifurcation.
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[30] On the next scheduled hearing dates, the Board will be receiving evidence and
submissions on the first issue. Whether or not it would be required to proceed to
hear the second issue would depend on the outcome of the first issue. If it does,
the evidence tendered on the first issue shall be applicable to the second issue.
The Board remains seized, and this proceeding will continue on the scheduled
dates.
Dated at Toronto, Ontario this 15th day of August 2017.
Nimal Dissanayake, Arbitrator