HomeMy WebLinkAbout2016-2892.Akintunde.18-05-01 DecisionCrown Employees Grievance Settlement
Board
Suite 600
180 Dundas St. West
Toronto, Ontario M5G 1Z8
Tel. (416) 326-1388
Fax (416) 326-1396
Commission de
règlement des griefs
des employés de la
Couronne
Bureau 600
180, rue Dundas Ouest
Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
Téléc. : (416) 326-1396
GSB# 2016-2892
UNION# 2017-0234-0033
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Akintunde) Union
- and -
The Crown in Right of Ontario
(Ministry of Community Safety and Correctional Services) Employer
BEFORE
M. V. Watters
Arbitrator
FOR THE UNION
Tim Hannigan
Ryder Wright Blair & Holmes LLP
Counsel
FOR THE EMPLOYER Daria Vodova
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING April 18, 2018
-2-
DECISION
[1] This proceeding was conducted pursuant to the Mediation/Arbitration Procedure
set out in article 22.16 of the collective agreement. At the hearing, counsel for the parties
agreed to extend the time period for the provision of this Decision.
[2] The grievor, Alexander Akintunde, is a Correctional Officer at the Maplehurst
Correctional Centre. His date of hire is August 12, 1996. He filed the following grievance
on February 21, 2017:
“……………………………………………………………………………
The Employer has violated the Collective Bargaining Agreement
including but not limited to articles 2, 3, 6; and the Ontario Human
Rights Code. The Employer’s systemic discrimination and
harassment has prevented my career development and opportunities
for advancement.
SETTLEMENT DESIRED:
1. Full Redress including but not limited to:
2. Developmental opportunities;
3. Damages;
4. Any Remedies the Arbitrator deems appropriate.
…………………………………………………………………………”
It is apparent that the grievor wishes to progress into a Sergeant’s position and that he
believes his career advancement has been stymied by racial discrimination on the part of
the Employer.
[3] The grievor prepared a fifteen (15) page document outlining the particulars relating
to his grievance. This document was filed as an exhibit without any of the attachments
referenced therein. I was informed that the attachments, at present, total in excess of
-3-
two hundred and sixty (260) pages and include Occurrence Reports, prior grievances and
a Workplace Discrimination and Harassment Complaint. Apparently, a search is being
conducted for other attachments that have yet to be located. I note from a reading of the
particulars that they include mention of the following matters: the grievor serving as an
acting Operational Manager in the period September 13, 2010 to September 25, 2011;
his unsuccessful applications for permanent Operational Manager positions in job
competitions held in February, 2011 and September, 2012; and numerous incidents and
events which occurred between 2011 and 2014.
[4] At the hearing, counsel for the Employer asked for the issuance of an Order to
restrict the scope of evidence. More specifically, she requested that the Union not be
permitted to lead evidence of any incidents or events which occurred more than three (3)
years prior to the filing of the instant grievance. Simply stated, counsel asked for the
application of, what is now referred to as, the “three (3) year rule”. Counsel for the Union,
in response, submitted that, in the circumstances of this case, the Union should be
allowed to adduce evidence with respect to all matters mentioned in the grievor’s
statement of particulars.
[5] The following authorities were filed by the parties relating to the application of the
three (3) year rule: OPSEU (Calder) and The Crown in Right of Ontario (Ministry of
Community Safety and Correctional Services), GSB No. 2015-1868 et al. (Wacyk);
OPSEU (Patterson) and The Crown in Right of Ontario (Ministry of Public Safety and
Security), GSB Nos. 2001-0925, 2001-0949 (Leighton); OPSEU (Dubuc) and The Crown
in Right of Ontario (Ministry of Community Safety and Correctional Services), GSB No.
2015-1330 (Herlich); OPSEU (Patterson) and The Crown in Right of Ontario (Ministry of
-4-
Children and Youth Services), GSB No. 1989-1546 et al. (Abramsky); OPSEU (Lavoie et
al.) and The Crown in Right of Ontario (Ministry of Community Safety and Correctional
Services), GSB Nos. 2012-2206, 2012-2965 (Sheehan); OPSEU (O’Brien) and The
Crown in Right of Ontario (Ministry of Community Safety and Correctional Services), GSB
No. 2003-1881 (Leighton); Hotel-Dieu Grace Hospital and Ontario Nurses’ Association
(Bennett Grievance) (1997), 62 L.A.C. (4th) 164 (Picher); OPSEU (Dale et al.) and The
Crown in Right of Ontario (Ministry of Health and Long-Term Care), GSB Nos. 0783-00,
1314-00, 0883-01 (Abramsky); OPSEU (Bilardo) and The Crown in Right of Ontario
(Ministry of Labour), GSB No. 2012-2049 et al. (Herlich); OPSEU (Lunan) and The Crown
in Right of Ontario (Ministry of Labour), GSB No. 2013-0513 et al. (Leighton).
[6] A concise statement of the three (3) year rule is found in the following passage
from the Lunan Decision:
“[8] The Board has held that a grievor alleging harassment and
discrimination can be permitted to adduce evidence over a
period of three years before the date of the grievance. See
Patterson (Leighton) and Patterson (Abramsky)
…..Evidence of events up to three years before the
grievance should allow the union sufficient opportunity to
prove a pattern of harassment and not be so long ago as to
be difficult to defend. However, the Board has also held that
it is not a rigid rule. It is a guideline: the Board must
consider each case on its facts. See O’Brien, (Leighton) …..
Thus it could be fair to the parties to extend the three years
or shorten the period.”
[7] It is clear from a reading of the authorities that the three (3) year rule is intended
to strike a fair balance between the interests of both parties. More specifically, the
ability of the Union to establish an alleged pattern of improper conduct must be weighed
against the Employer’s right to effectively defend itself against dated accusations. In
-5-
deciding whether, and how, to apply the rule, the Board has considered the following
matters:
i) whether the grievor was aware of the right to challenge or grieve
the earlier events which the Union seeks to rely on;
ii) whether the hearing would be unduly protracted by the
application of the rule, as a result of the need to present and
consider voluminous evidence relating to the past events; and
iii) whether extending the period of arbitral review would raise
concerns from both an equitable and procedural standpoint.
[8] The authorities also confirm that the three (3) year rule is simply a point of
departure, and is not an inflexible rule to be mechanically applied in all cases. It has been
described as a “rule of thumb”. By way of example, the three (3) year period was
extended in both O’Brien and Lunan, as described below.
[9] In O’Brien, the grievances were filed in 2003 and 2009. With respect to the latter
grievance, the Board permitted the Union to present evidence back to 2000 based on the
“unique circumstances” of the case. In that instance, the grievor had been out of the
workplace and in receipt of LTIP since 2001. The Vice-Chair concluded that, as a result,
there would not be a need for the presentation of voluminous evidence with respect to
events which occurred within the extended period. I note that the extension granted was
expressly stated to be “subject to a finding of actual prejudice if the employer can prove
it during the hearing” (page 8).
[10] In Lunan, the grievor filed seven (7) grievances between December, 2012 and
October, 2013 alleging harassment and discrimination on the part of the Employer. The
Vice-Chair, in substance, applied the three (3) year rule subject to a limited exception due
to “special circumstances”. In this regard, she permitted the Union to lead evidence with
-6-
respect to a single and specific incident in 2004 involving an exchange between the
grievor and a co-worker. The Vice-Chair observed that the Employer did not argue that
such an extension would create “actual prejudice”. I note that she made the following
comment on the evidence that might be adduced as a consequence of the extension:
“Whether this evidence is relevant or necessary is a decision better made during the
hearing” (page 5). The final substantive paragraph of the Decision reads:
“[10] I am also of the view that evidence of approximately three
years before the first grievance dated December 7, 2012
should suffice to give the union a fair opportunity to prove
harassment and discrimination. By approximate I mean that
the three years should not be “to the day”, especially if there
is an important event that occurred just beyond the three
years. The precise line is better determined during the
hearing”.
[11] Finally, I note that this Board has previously determined that the exclusion of
otherwise relevant evidence, through a proper application of the three (3) year rule, does
not constitute a violation of the rules of natural justice.
[12] It is the Employer’s position that no reason exists to depart from the normal
application of the three (3) year rule. Counsel submitted that limiting evidence to the three
(3) year period prior to February 21, 2017 would provide the Union with a fair and sufficient
opportunity to establish the alleged pattern of discrimination and harassment. She argued
that to further extend the period, as requested by the Union, would prejudice the
Employer’s ability to defend itself for the following reasons: the Employer would have to
address untimely and dated events which, in some instances, occurred six (6) to seven
(7) years ago; the Employer might be unable to locate necessary witnesses and/or
relevant documents given the passage of time; and an extension beyond three (3) years
would likely lead to the introduction of voluminous evidence. It was counsel’s submission
-7-
that the particulars filed do not disclose the type of unique or special circumstances found
in the O’Brien and Lunan Decisions. Lastly, she suggested that the grievor was fully
aware of his right to complain about management misconduct. From her perspective, he
should have done so at the time of the earlier incidents, if he truly felt aggrieved by the
Employer’s actions.
[13] Counsel advised that she reserved the right to raise further preliminary objections
concerning post-grievance evidence and the jurisdiction of this Arbitrator to adjudicate
matters relating to the grievor’s failure to secure an excluded position shortly before the
filing of the instant grievance.
[14] In response, it is the Union’s position that it is necessary in this case to enlarge the
scope of permitted evidence beyond the three (3) year period prior to the filing of the
grievance. Counsel submitted that such an extension will allow the Union to better
establish a pattern of systemic discrimination and harassment and to show how it has
adversely impacted the grievor’s career advancement. Additionally, he argued that a
review of the 2012 job competition and the 2010 to 2011 acting assignment will
demonstrate how the Employer has dealt with the grievor in “like circumstances”. Counsel
asserted that for purposes of assessing the Employer’s motivation in this case, it will be
instructive to consider both how the Employer has administered job competitions in the
past and the actual experience of the grievor when in the acting position. Put another
way, such evidence will set the context for what led to the filing of the instant grievance.
Counsel advised that the evidence relating to the events outside of the three (3) year
period will not be voluminous but, instead, will be specific and succinct. He invited this
Arbitrator to adopt the flexible approach reflected in the O’Brien and Lunan Decisions.
-8-
[15] After considering the submissions of the parties, I have decided to make the Order
requested by the Employer. In my judgment, application of the three (3) year rule will
provide a fair and reasonable balance between the competing interests of the Union and
the Employer. I am satisfied that the Union will have sufficient scope to establish the
existence of the alleged pattern of systemic discrimination and harassment. Additionally,
I consider it unlikely that the Employer will be unduly prejudiced by having to address
incidents and events which occurred in the three (3) year period prior to the grievance.
From my reading of the particulars, I think that to accede to the Union’s request would
likely result in the receipt of voluminous evidence and that the hearing, as a consequence,
could be protracted. Such a result could very likely have a negative effect on the
Employer’s ability to defend itself against the allegations made by the grievor. The
particulars further suggest that the grievor was aware of his right to challenge or grieve
the actions complained of during the contested period.
[16] I have not been persuaded that unique or special circumstances exist here to
support a departure from the three (3) year rule. Unlike the situation in O’Brien, the
grievor was at work for the entire period of time. The extension in Lunan, on my reading,
was based on the specific facts of that case, which are distinguishable from the
circumstances of the present grievance. I do agree with the comment by the Vice-Chair
in Lunan as to the approximate nature of the three (3) year period.
[17] During the course of submissions, I was advised that the grievor filed a grievance
in July, 2014 and that the matter proceeded to a mediation-arbitration hearing at the
Grievance Settlement Board. Apparently, the grievance was dismissed, but the Employer
was required to pay a small monetary amount as compensation for a breach of the
-9-
grievor’s privacy rights. This incident and the resulting disposition both occurred within
the three (3) year period prior to the filing of this grievance. While not much detail was
provided about this matter, I am satisfied it does form part of the record for purposes of
this proceeding. Clearly, however, it cannot be relitigated as part of this case.
[18] For all of the above reasons, it is ordered that the scope of evidence is limited to
the three (3) year period prior to the filing of the instant grievance.
Dated at Toronto, Ontario this 1st day of May, 2018.
“M. V. Watters”
________________________
M. V. Watters, Arbitrator