HomeMy WebLinkAbout2015-1251 et al.Fitzpatrick.18-07-19 DecisionCrown Employees Grievance Settlement
Board
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Commission de
règlement des griefs
des employés de la
Couronne
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Toronto (Ontario) M5G 1Z8
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Téléc. : (416) 326-1396
GSB# 2015-1251; 2015-1340; 2015-2769; 2015-2772; 2016-0219; 2016-0220; 2016-0341;
2016-0342; 2016-0426; 2016-0427; 2016-0429; 2016-0469; 2016-0792; 2016-0793; 2016-1116;
2016-1802
UNION# 2015-0368-0285; 2015-0368-0286; 2015-0368-0373; 2015-0368-0376; 2016-0368-0046;
2016-0368-0047; 2016-0368-0055; 2016-0368-0056; 2016-0368-0061; 2016-0368-0062; 2016-0368-
0064; 2016-0368-0069; 2016-0368-0102; 2016-0368-0103; 2016-0368-0119; 2016-0368-0174
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Fitzpatrick) Union
- and -
The Crown in Right of Ontario
(Ministry of Community Safety and Correctional Services) Employer
BEFORE
Diane Gee
Arbitrator
FOR THE UNION
Rebecca Glass
Dewart Gleason LLP
Counsel
FOR THE EMPLOYER Henry Huang
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING July 3, 2018
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DECISION
[1] This decision deals with two preliminary issues. The first issue concerns the
Union’s request for an Order requiring the Employer to produce “all documents, notes,
memos, and information regarding the workplace restoration report conducted for the
grievor’s workplace”. The report referenced in the Union’s production request is a report
prepared by Rick Russell of Agree Incorporated dated December 11, 2015 that was
provided to the Ministry of Community Safety & Correctional Services CECC: Programs
Division. The report is entitled Re: Workplace Assessment: Social Work, Addictions &
Rehabilitations (the “Report”). The second issue is the Union’s request that the grievor,
Carrie Fitzpatrick, be permitted to adduce her evidence in chief by way of a “will-say”
statement. The Employer opposes both requests.
Issue #1
[2] The 20 grievances before me include, amongst other things, an allegation the
employer assigned Carrie Fitzpatrick to an unreasonably large volume of work, frequently
changed her assignments, gave her inconsistent and constantly changing directions, and
lied or condoned lying leading to Ms. Fitzpatrick taking a medical leave from June to
December 2015.
[3] The Report originates out of Minutes of Settlement (“MOS”), entered into by the
Employer and the Union on June 15, 2015 in respect of 60 other grievances filed by seven
employees, including Ms. Fitzpatrick. The grievances concerned many of the issues, set
out in the previous paragraph, that are raised by Ms. Fitzpatrick in the instant grievance.
Paragraph 1 of the MOS reads:
The Employer agrees to commence a Workplace Restoration/Mediation within
the Programs Department at CECC. For clarity the parties agree to utilize the
services of Rick Russell – Agree Dispute Resolution Services.
[4] Rick Russell was subsequently retained and, ultimately, prepared the Report. The
Report itself is clearly watermarked on every page “confidential” and it states:
At the outset of the contract, it was agreed that the conflict management consultant, Rick
Russell, would:
• Complete confidential interviews
• Prepare a short Confidential Report that would:
o Be, wherever possible, “non-attributable”
The Employer states that all individuals spoken to were told that their comments would
be kept confidential.
[5] The Union submits that the subject matter of the Report concerns Ms. Fitzpatrick’s
work area and overlaps with the subject matter of the allegations in the present matters.
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In addition, the time period under consideration by Mr. Russell in the Report overlaps with
the time period during with the alleged events occurred in the present matters. The Union
submits that the Report considers the same subject matter during the same period as is
issue in the instant grievances and is thus arguably relevant.
[6] Relying on Toronto District School Board and Canadian Union of Employees, Local
4400, (2002) 109 LAC 4th 20 at page 13, and Peel District School Board v. O.S.S.T.F.,
District 19, 2012 CarswellOnt 3304, the Union argues, the law in Ontario supports very
broad production such that “even a semblance of relevance is enough.”
[7] In anticipation of the Employer’s argument that the Report is confidential, the Union
states there is nothing in the terms of the MOS that provides the Report is confidential or
that the settlement itself is confidential. The Union thus submits, the Report is not covered
by any ground of privilege, is arguably relevant, and must be produced.
[8] The Employer notes that the request made by the Union that includes the Report
is not limited to the Report itself. Rather, it includes “all documents, notes, memos, and
information regarding the workplace restoration report conducted for the grievor’s
workplace.”
[9] The Employer argues the Report is not arguably relevant, is a fishing expedition
and is highly prejudicial given all who participated were assured they were speaking in
confidence.
[10] The Employer states that the report is not the results of an investigation. The
Report specifically states it is not an investigation and further states that it makes no
findings of fact.
[11] The Employer further relies on the fact that the Report was produced as part of a
process intended to repair a fractured workplace. Disclosure of the report now would be
seen as a betrayal to the staff that trusted in the confidential nature of the process and
would serve to undo all the work of the restoration process in a workplace that has only
now begun to heal. In response to the Union’s statement that there is nothing in the MOS
that states the Report is to be kept confidential, the Employer states there is equally
nothing that says it is to be provided to anyone outside of management.
[12] On the law, the Employer does not agree with the Union‘s characterization that the
test for pre-hearing production is a semblance of relevance. The Employer submits that
the appropriate test is as set out in OPSEU and The Crown in Right of Ontario (Ministry
of Environment) (Madan) Decision of M. Watters dated November 21, 2012 and Ontario
Liquor Boards Employees’ Union and Liquor Control Board of Ontario (Koonings) decision
of O. Gray dated February 17, 2006, both of which are decisions of the GSB. Based on
these decisions, the Employer argues the following five factors are to be considered:
i) the information requested must be arguably relevant;
ii) the requested information must be particularized so there is no dispute as
to what is desired;
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iii) the decision-maker should be satisfied that the information is not being
requested as a “fishing expedition”;
iv) there must be a clear nexus between the information being requested and
the positions in dispute at the hearing; and
v) the decision-maker should be satisfied that the disclosure will not cause
undue prejudice.
[13] Addressing factors 1 and 4, the Employer notes that the particulars provided by
the Union do not make reference to the workplace restoration process. The Report is not
an investigative report covering the same subject matter Ms. Fitzpatrick is complaining
about. Ms. Fitzpatrick’s complaint is specific to her manager and does not complain of a
poisoned workplace.
[14] With respect to the second factor, the Employer states that the request has not
been properly particularized and is thus overly broad. The Employer relies on Ontario
Public Service Employees Union and Ontario (Children and Youth Services), 2007 CanLII
6888 (Patterson) (ON GSB) in support of its position. The Union’s request for production
would include documents such as the procurement report that has no relationship to the
issues in dispute. The Employer submits that the grievance is not with the Report and
does not allege that the Report has not been implemented or in any way challenge the
Report itself.
[15] Turning to the third factor, the Employer argues that this must not be an endeavor
to discover whether the Union has a case or to obtain evidence to support a case. Relying
on Ontario Public Service Employees Union and Ontario (Ministry of Children and Youth
Services) (Patterson), 2007 CanLII 6888 and London (City) and CUPE, Local 101
(Idzkowski) 2017 CarswellOnt 7569 the Employer argues that the Union is not entitled to
seek disclosure of the Report in order to look for support for the grievance.
[16] With respect to the final factor, relying on AMAPCEO and Ontario (Ministry of
Attorney General), (Horne) Decision of N. Dissanayake dated October 12, 2012, the
Employer submits that the probative value of the document must be balanced with the
harm production would cause. The Employer relies on the following paragraph:
16. The parties are agreed that the Board has a discretion with regard to the
nature and the extent of disclosure to be required. In exercising that discretion the
considerations are practical rather than legal. (See, Re Thermal Ceramics. (1993),
32 L.A.C. (4th) 375 (Gray)). Moreover, the arbitrator must balance the desirability and
value of disclosure with any countervailing interests such as prejudice to one party,
confidentiality concerns or unduly onerous burden in terms of time, effort or expense.
(See, Re Stelco Inc. (Hilton Works), (1994) 42 L.A.C. (4th) 270 Dissanayake).
[17] The Employer’s primary position, as set out above, is that no order requiring
production be made. The Employer submits, in the alternative, if disclosure it to be
ordered, limits be put on the disclosure as follows:
vi) Disclosure be limited only to the production of the Report itself and not to
include other unparticularized items. The Employer states that any notes
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taken in the course of preparing the report would not be in the Employer’s
control.
vii) Secondly, the Employer seeks to be permitted to redact aspects of the
Report that are not relevant.
viii) The Employer asks that Ms. Fitzpatrick and the Union only review the
Report in presence of Union counsel without receiving a copy for
themselves and any copies of the Report be destroyed at the conclusion of
the proceedings.
ix) The Employer asks that Ms. Fitzpatrick and any Union representative who
views the Report be reminded of the implied undertaking to only use the
Report for the purpose of this proceeding and no other purpose. This
includes a restriction on discussing the Report with anyone including co-
workers and family.
[18] In reply, the Union argues that the fact that individuals who were spoken to in the
course of the preparation of the Report were told their comments would be kept
confidential should have no bearing on the decision. Whether they have been assured
of confidentiality or not, the Report can be subject to disclosure. Concerns about
confidentiality can be dealt with by placing limits on the scope of distribution or discussion
of the Report. The Union has no objections to such restrictions being imposed.
Analysis and Decision
[19] For the purposes of this decision, I have applied the test as set out in the decisions
relied upon by the Employer. As such, the factors to be considered are:
i. Are the documents requested arguably relevant to the issues in dispute?
ii. Is the request for production sufficiently particularized so there is no dispute as to
what documents are being sought?
iii. Are the documents being requested as a “fishing expedition”?
iv. Will disclosure of the documents cause undue prejudice?
[20] In the vast majority of cases where there is an issue concerning the production of
a “report” it is in connection with an investigative report that was relied upon by the
employer in order to decide whether or not to impose the discipline that is at issue in the
arbitration. In such a case, arbitrators routinely order the production of the report on the
basis it is arguably relevant to the employer’s reasons for imposing discipline. As the
Employer has pointed out, the Report in issue in this case is not an investigative report
relied upon by the Employer to impose discipline or make any decision that is being
contested in this arbitration. Thus, the Report is not arguably relevant to any decision
being challenged in this proceeding and the usual basis upon which reports are found to
be arguably relevant does not apply.
[21] The Report looks into some of the problems Ms. Fitzpatrick alleges existed in her
workplace at the very time period covered by Ms. Fitzpatrick’s grievance. The Report
contains numerous quotes from what was said by personnel during interviews held by Mr.
Russell. In fact, the only information Mr. Russell had at his disposal is what he obtained
through personnel interviews. The Report, in so far as it consists of a recitation of what
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personnel said during interviews, is, of course, hearsay. To the extent the Report
expresses views or conclusions as to the existence or cause of problems in the
workplace, it cannot be determinative as such are issues that I must determine based on
the evidence before me.
[22] In addition to the Report itself, it is evident, from a statement contained in the
Report, Mr. Russell took notes during the interviews he conducted. Mr. Russell’s notes
are, again, hearsay and thus would not be admissible for the truth of their contents. At
best, the notes would be admissible as a record of what Mr. Russell was told by the
personnel he interviewed.
[23] The fact that the Report and the notes taken by Mr. Russell are hearsay is not,
however, determinative of whether or not they ought to be produced. The Report and the
notes are arguably relevant in that they may be used to challenge, assist a witness to
recall, or corroborate, evidence. If a witness testifies that matters were X and Mr. Russell
recorded a note of his interview with that same person that said Y, Mr. Russell’s note
could be put to the witness to challenge their evidence as to X. Equally, where a witness
is unable to recall what happened, Mr. Russell’s note could be put to them in an attempt
to refresh their memory. Further, where a witness testifies as to X and Mr. Russell’s notes
are consistent with X, the notes may serve to strengthen the probability of the witness’
testimony. Accordingly, I find the Report and any notes taken by Mr. Russell in the course
of his interviews to be arguably relevant.
[24] The request is for “all documents, notes, memos, and information regarding the
workplace restoration report conducted for the grievor’s workplace.” It is clear, and not
disputed, that the Report is the “workplace restoration report” sought by the Union. At the
hearing, in response to concerns expressed by the Employer, the Union indicated it did
not require production of the procurement documents. As argued by the Employer, it is
necessary for a request for the production of documents to be particularized with sufficient
clarity that the party being asked to produce the documents knows what the other side is
seeking. In this case, there is no confusion as to the report that the Union is referring to
in its request. It is that Report, and all documents relating to it, that are being sought. I
find the request to be sufficiently particularized.
[25] I am not persuaded that the Union’s request amounts to fishing. The Union has
provided quite detailed particulars of its allegations. I am satisfied it is not using this
production request to find a case.
[26] The Employer is strongly opposed to producing the documents in question due to
the fact that the personnel interviewed by Mr. Russell were told the interviews were
confidential. It is argued that breaching that confidence would cause undue prejudice.
This issue has been canvassed in a number of decisions and it has been consistently
held that such an assurance of confidentiality will not protect the document from
production. The following quote from Board of Governors of Laurentian University v.
Laurentian University Faculty Association, 2011 CanLII 20778 (ON LA) is instructive:
25. There are few documents that are confidential for all purposes or in all
circumstances. All manner of documents, communications or other information that
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are confidential outside of the litigation process; including business or corporate
information, or personal medical information, may have to be disclosed in a
grievance arbitration proceeding if the documents, communications or information
are arguably relevant to the matters in issue. The only documents or
communications that are exempt from production are those to which a legal privilege
applies. All arguably relevant documents, “confidential” or not, must be produced
unless a legal privilege applies. A party cannot object to producing arguably relevant
documents, whether or not they are “confidential” and regardless of the effect that it
may have on its case.
As stated in the foregoing quote, the fact that notes were taken in the course of a
confidential interview that was conducted for the purposes of a workplace review, does
not shield them from production in the context of a labour arbitration.
[27] In the alternative to its position the documents ought not to be produced, the
Employer requests limitations be placed on the use and disclosure of the documents.
The Union does not object. Accordingly, I hereby order the Employer to produce to Union
counsel, no later than one month in advance of the next hearing date, a copy of all
documents, notes, memos, and information within its possession and control regarding
and including the Report. I further order the following restrictions on the use and
disclosure of the documents provided:
i. The documents and all copies thereof are to be maintained in Union Counsel’s
possession.
ii. The documents are to be reviewed by Ms. Fitzpatrick and one union representative
of her choosing only in the presence of Union Counsel.
iii. Ms. Fitzpatrick and her chosen union representative are not to discuss the contents
of the documents with anyone else except Union counsel nor are they to discuss
the documents between themselves in the presence of others.
iv. Soft copies of the documents are not to be made.
v. The documents are for the purposes of this litigation and for no other purpose.
vi. The documents are to be destroyed at the conclusion of the litigation except to the
extent Union Counsel may be required to maintain a copy in her file pursuant to
her professional obligations.
Issue #2
[28] The Union is seeking to adduce the evidence in chief of Ms. Fitzpatrick by way of
a will-say statement. The Union argues that the Collective Agreement evidences an
intention for the arbitrator to control the proceedings to the extent possible to have the
litigation completed with economy and efficiency. In this regard, the Union refers to
Article 22.16.2 of the Collective Agreement wherein it states:
When determining the grievance by arbitration, the mediator/arbitrator may limit the
nature and extent of the evidence and may impose such conditions as he or she
considers appropriate.
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The Union further relies on the following articles of the Grievance Settlement Board Rules
of Procedure: Appendix A:
g. The hearing shall be conducted in the most informal and expeditious way
that is possible according to the nature of the grievances and all the circumstances.
…
m. Where any dispute arises concerning this procedure, a party may refer such
dispute to the mediator/arbitrator for resolution or determination
[29] The Union submits, receiving Ms. Fitzpatrick’s evidence in chief by way of a will-
say statement, is the most efficient and economical way to proceed. The Union notes that
the issues in these 20 grievances stretch over a long period of time and it would take a
number of days for Ms. Fitzpatrick’s evidence to be adduced orally. The Employer would
be given full right of cross-examination providing me the opportunity to assess her
credibility. In addition, the Union states that Ms. Fitzpatrick’s evidence is supported by
contemporaneous documents. As such, the options are allowing the evidence to be
adduced by way of a will-say or having her testify orally referring and relying on the
documents.
[30] The Employer acknowledges I have the jurisdiction to permit evidence be adduced
by way of a will-say but argues that I ought not to do so in this case. The Employer submits
that adducing evidence by way of oral testimony is the standard practice. The party that
asks to depart from that practice bears the onus of establishing a good reason for doing
so.
[31] The Employer points to the large number of grievances that have been filed by Ms.
Fitzpatrick that advance very serious allegations. The Employer argues that I will be
called upon to assess Ms. Fitzpatrick’s credibility and thus need to see her give her
evidence in chief. Further, Ms. Fitzpatrick may be the only Union witness. The Employer
submits that allowing Ms. Fitzpatrick to file her evidence as a will-say will significantly
prejudice the Employer’s ability to defend itself.
[32] I agree with the Union that the article 22.16 of the Collective Agreement evidences
an intention on the part of the parties that arbitrations be conducted in a manner that is
respectful of the need for the matter to be resolved in a timely and efficient way. W ill-say
statements are commonly used to adduce evidence in chief primarily where there are few
factual issues in dispute or where the credibility of the witness is not going to put in issue.
[33] At the hearing of this matter I voiced the view that I was not inclined to grant the
Union’s request, however, having now reviewed the Report, at least with respect to the
allegations falling within its scope, I suspect there may not be as much dispute about the
facts as I first thought. There may certainly be dispute about whether the facts amount
to harassment or any violation of the collective agreement or whether Ms. Fitzpatrick
contributed to the problems in the workplace but the basic facts as to the state of the
workload may not be in dispute. As the Union suggests, it will take days for Ms. Fitzpatrick
to orally adduce her evidence. If it is adduced by a will-say statement the Employer will
have it in advance and be able to focus its cross-examination on the areas of contention.
The time saved will likely be considerable.
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[34] Thus, I grant the Union’s request to adduce Ms. Fitzpatrick’s evidence by way of a
will-say statement, however, I grant the same option to the Employer with respect to any
witnesses it may call. All will-say statements are to be in chronological order
accompanied by a bound and tabbed book of documents. The documents will be subject
to review by the other side and objections as to admissibility of the documents can be
made.
[35] The Union is directed to provide Ms. Fitzpatrick’s will-say and book of documents
to the Employer no later than two weeks in advance of the next hearing date. At the
commencement of the hearing, I will hear brief opening statements following which Ms.
Fitzpatrick will give her testimony. The Union is to ask Ms. Fitzpatrick basic questions
including having her testify that the contents of the will-say are true and accurate. The
Employer will then begin cross-examination.
Dated at Toronto, Ontario this 19th day of July, 2018.
“Diane Gee”
______________________
Diane Gee, Arbitrator