HomeMy WebLinkAbout1984-0513.Kuyntjes.85-04-09
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CROWN EMPLOYEES
GRIEVANCE
1111 SETTLEMENT
BOARD
180 DUNDAS STREET WEST. TORONTO. ONTARIO. M5G lZ8 - SUITE 2100
TELEPHONE' 416/598-0688
513/84
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
Between:
OPSEU (Pieter B. Kuyntjes)
Grievor
- and -
The Crown in Right of Ontario
(Ministry of Transportation
and Communications)
Employer
Before:
R. L. Verity, Q.C.
M. Perrin
L. Foreman
Vice Chairman
Member
Member
For the Gri evor:
M. Wysocki
Grievance Officer
Ontario Public Service Employees Union
For the Employer:
M. Fl e is hma n
Law Officer
Crown Law Office Civil
Ministry of the Attorney General
Hearing;
December 4,1984
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D E CIS ION
This dispute concerns management's refusal to author-
ize a special leave of absence as a result of the Grievor's
failure to attend work on February 28, 1984 due to inclement
weather conditions. The grievance filed on May 2, 1984 alleges
that the Employer improperly deducted a vacation day from the
Grievor's bank of credits for the day in question. The remedy
sought was reinstatement of the vacation credit and payment for
February 28, 1984 "as a discretionary day".
Article 54 provides that the Employer has the discre-
tionaryauthority to grant a special leave of absence with pay
to an employee on an annual basis for period or periods not to
exceed three days. The real issue in dispute is the extent of
arbitral review of management's discretion. The relevant
Article in the Collective Agreement reads as follows:
"ARTICLE 54 - SPECIAL & COMPASSIONATE LEAVE
54.1 A Deputy Minister or his designee may
grant an employee leave-of-absence with pay
for not more than three (3) days in a year
upon special or compassionate grounds.
54.2 The granting of leave under this Ar-
ticle shall not be dependent upon or
charged against accumulated credits."
,
,
- 3 -
The following facts are relevant. The Grievor is
presently classified as "Technician 1 - Construction" and has
worked for the Ministry for in excess of 10 years. Normally,
he has his headquarters at Duff's Patrol Yard near Ancaster.
As of February 1984 he was assigned to the Burlington Patrol
Yard in the temporary winter assignment as Snow Plow Helper.
The Grievor lives in Ancaster and is authorized to use his own
motor vehicle to travel 18 miles from his home in Ancaster to
the Burlington yard.
At midnight on February 27, a moderately severe snow-
storm occurred within a wide geographical area of Southwestern
Ontario, including Burlington and Ancaster. The storm caused
accumulations of snow and drifting snow, and continued unabated
throughout the night of February 27 and during the day and
evening hours of February 28.
The Grievor worked his scheduled shift from 8:00
p.m. on February 27 until 4:30 a.m. on February 28, and in
addition worked some 3 hours of overtime. He was scheduled to
report for work ori February 28 at 8:00 p.m.
At 6:45 p.m. 0n rebruary 28, the Grievor telephoned
Duff's Corners Patrol Yard (approximately 2 miles from his res-
idence) to enquire as to weather conditions. According to the
Grievor's testimony, he was advised that road conditions
"
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- 4 -
then telephoned the Burlington Detachment of the Ontario Pro-
vincial Police and was told that motorists should stay off the
roads unless absolutely necessary. In addition, the Grievor
testified that he made repeated attempts without success to
clear drifting snow from his residence driveway. He also
stated that the street in front of his residence had not been
plowed.
The Grievor then notified the Burlington Patrol Yard
that he was unable to report for work due to weather condi-
tions.
Subsequently, the Grievor made the following entry on
his time sheet (Resource Utilization Record Sheet):
"February 28 - 855 code - Blizzard
Roads Closed - Could not get in"
On the evidence, it is clear that the Grievor assumed
that he would be paid for his absence on the February 28 shift
as had been the procedure followed during a major snowstorm in
1977. However, the Grievor found to the contrary when he re-
viewed his quarterly status report in late April. Upon review
of that document, he telephoned the Ministry's Head Office
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Payroll Division and was advised that instructions had
been received to charge the February 28 absence against his
vacation credits. After discussions with the Supervisor failed
to resolve the matter, the grievance was filed.
The Ministry presented evidence primarily through OPP
Constable William Lee which established that Highways 403 and
the Q.E.W. from Ancaster to Burlington were indeed passable at
all relevant times. Burlington District Personnel Officer
Charles Malloy testified that of 12 employees scheduled to work
on the afternoon and evening shift of February 28 at the
Burlington Patrol Yard, only the Grievor and employee T. L.
Brodnicki failed to report for work. Mr. Malloy testified that
Brodnicki reported that the street in front of his Hamilton
mountain home was blocked by snow, and that the request had
been made by the employee to deduct the absence from his
vacation credits.
Similarly, Mr. Malloy testified that all eight
~mployees scheduled to work at Duff's Corners Patrol Yard had
reported for work. In essence, the Employer's position was to
the effect that the Grievor made insufficient efforts to report
for the assigned shift.
7
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Deputy Minister Harold Gilbert set out Ministry poli-
cy in a Memorandum dated January 31, 1977. Part of that Memor-
andum reads as follows:
"In the light of our experience on January
10 and again on January 28 and considering
the variety of weather conditions which can
occur on any given day across the Province,
it is apparent that any decision with re-
gard early closing and the treatment of
employees as a result of storm caused lates
and absences must be made locally in
the light of conditions which exist.
At the same time, it is quite apparent, in
the light of comments, criticisms and even
threats of grievances, that the treatment
of employees must be seen as reasonable,
fair and equitable where similar circum-
stances exist. Whatever practice is adop-
ted must encourage attendance and, at the
same time, demonstrate an enlightened con-
cern for employees' safety and should not
be seen as favourable treatment for govern-
ment employees as compared to employees in
the private sector in the same locality.
Therefore, "in future" any decision with
regard early closing of offices or charges
against credits for storm caused absences
will be the responsibility of Regional
Directors for all regional staff."
...Notwithstanding the fact that discretion
will be vested in the above noted offi-
cials, the following guidelines should be
considered in the interests of equitable
treatment in'similar circumstances:
1)...
2)...
3) Absences - where an employee arrives
for work before noon and circumstances war-
rant such consideration, no charge against
credits will be made. Any absence
of half or whole days should be charged, in
the case of bargaining unit employees,
against attendance credits, overtime cre-
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dits for employees on Schedule 3 or 4 and
not on Schedule 7, or vacation credits.
For management employees, since there are
no attendance credits against which to make
a charge and the majority of management
personnel do not have overtime credits, any
charge should be made against Discretionary
Leave under Section 80(1) of the Regula-
tions. You are reminded that authorization
for Discretionary Leave must be given in
accordance with the list of delegated
authorities and that such discretion is
limited to three days in any year."
The Grievor testified that he was unaware of the
Ministry policy.
On behalf of the Grievor, Ms. Wysocki argued that
reasonable attempts had been made by the Grievor to report for
work and that he had been prevented from doing so by
circumstances beyond his control.
It was argued that the
Employer had the duty to exercise its discretion under Article
54 of the Collective Aqreement in a reasonable fashion without
rJiscrimination.
The thrust of the Union's argument was that
the Employer failed to exercise its discretion reasonably,
primarily as a result of its failure to consider the Grievor's
personal circumstances.
In addition, Ms. Wysocki contended
that the Employer has no unilateral right to deduct earned
credits accumulated by an employee.
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Mr. Fleishman, Counsel for the Employer, relied upon
the Judgment of the Ontario Court of Appeal in Re Metropolitan
Toronto Board of Commissioners of Police and Metropolitan
Toronto Police Association, et al (1981), 124 D.L.R. (3d) 684,
in support of the proposition that the exercise of management's
discretion is not subject to arbitral review. Alternatively,
it was contended that, in the instant grievance, management did
exercise its discretion in a reasonable fashion.
In a determination of this matter, the Board adopts
the rationale of Arbitrator Swan in Re Meadow Park Nursing Home
and Service Employees International Union, Local 220 (1983), 9
L.A.C. (3d) 137 at pp 139 - 143. The Swan Award considered the
extent of arbitral review of an expressly conferred management
discretion in the light of perceived contradictions in both
arbitral and judicial precedent. Arbitrator Swan's rationale
merits repetition:
liAs is well known, arbitrators were beginn-
ing to develop a 'doctrine of fairness'
based upon the administrative law principle
of the same name, which appears first to
have been applied to an employment rela-
tionship by the Supreme Court of Canada in
Re Nicholson and Haldimand-Norfolk Regional
Board of Com'rs of Police (1978),88 D.L.R.
(3d) 671, 78 C.L.L.C. para. 14, 181, [1979]
1 S.C.R. 311. In Re Municipality of
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Metropolitan Toronto and Toronto Civic
Employees' Union, Local 43 et ale (1977),
79 D.L.R. (3d) 249, 16 O.R. (2d) 730, the
Ontario Divisional Court appears to have
approved the notion that there is to be
applied to a collective agreement a duty of
fair administration. While it may be that
the language chosen by the court in that
case was broader than it needed to be, many
observers of the labour relations scene
appear to have forgotten that the role of a
court on an application for judicial review
of an arbitration award is not to create
principles of general law, nor to say
whether an arbitrator is right or wrong in
an interpretation of a collective agree-
ment, but merely to decide whether the
interpretation given to the collective
agreement language is one which it can
reasonably bear. Once the arbitration
award has met that test, the court's juris-
diction is exhausted, and any other com-
ments which it may make, however helpful in
understanding the rationale for that deter-
mination, do not constitute binding prin-
ciples of law to be followed slavishly by
arbitrators.
The Ontario Court of Appeal appears to have
applied exactly this principle in Re Metro-
politan Toronto Board of Com'rs of Police
and Metropolitan Toronto Police Assoc.
et ale (1981), 124 D.L.R. (3d) 684, 81
C.L.L.C. para. 14,116,33 O.R. (2d) 476
[leave to appeal refused D.L.R. loco cit.,
O.R. loc, cit, (S.C.C.)]. In that case, an
arbitrator had considered herself bound by
the observations of the Divisional Court in
the Metropolitan Toronto case, surpa, and
had concluded that the management rights
clause of the collective agreement had to
be exercised fairly and without discrimin-
ation. The Court of Appeal said [po 687]:
.'
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If...the majority of the Divisional
Court in the [Metropolitan Toronto] case
were purporting to lay down a general
rule, that all decisions of management
pursuant to a management rights clause
which do not contravene any other provi-
sions of the agreement must stand the
further test whether in the opinion of
an arbitrator they were made fairly and
without discrimination, then with re-
spect we do not agree. The decisions
relied upon by Weatherston J. in the
[Metropolitan Toronto] case, as that
learned Judge rightly pointed out, dealt
with procedural fairness in proceedings
before domestic and statutory bodies;
they did not deal with the interpreta-
tion of collective agreements. In our
opinion, the management rights clause
gives management the exclusive right to
determine how it shall exercise the
powers conferred on it by that clause,
unless those powers are otherwise cir-
cumscribed by express provisions of the
collective agreement. The power to
challenge a decision of management must
be found in some provision of the col-
lective agreement.'
What the Metropolitan Toronto Police deci-
sion decides, in our respectful view, is
simply that arbitrators exceed their juris-
diction if they purport to establish general
principles for the administration of collec-
tive agreements divorced from the language
negotiated by the parties in the matter be-
fore them, and that they commit errors in
law if they purport to treat a judgment of
the courts, refusing to interfere with an
arbitration board on the basis that it did
not give collective agreement language a
meaning which it could not reasonably bear,
as binding expositions of the general law.
Unfortunately, many arbitrators, and indeed
some courts, have turned the rationale of
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Metropolitan Toronto Police upside down, and
have taken it instead to mean that there can
never been implied into a collective agree-
ment a duty to exercise a management func-
tion or prerogative in accordance with tests
of fairness or reasonableness. The Metro-
politan Toronto Police case does not and
cannot alter the law of contractual inter-
pretation; every allegation that an employer
is in breach of the collective agreement
must be considered individually, against the
language which the parties themselves nego-
tiated, and in accordance with the well-
known canons of construction. If, based on
the general law of implied terms in con-
tracts, as the general law may be adapted to
the particular case of collective agree-
ments, the implication arises that a parti-
cular management function must be exercised
in a certain way, then an arbitrator is
bound to make that implication, since it
arises from the collective agreement from
which the arbitrator draws his or her juris-
diction and which constitutes the entire
bargaining between the parties. To whatever
extent such cases as Re United Glass &
Ceramic Workers of North America et ale and
Libbey-St. Clair Inc. et al (1981), 125
D.L.R. (3d) 702, 33 O.R. (2d) 760 (Ont.
Div. Ct.) appears to suggest some other con-
clusion, it would be our respectful sub-
mission that they should not be followed.
...The concept of a discretionary power is
not unknown to the law, and the administra-
tive law jurisprudence is full of cases on
the restrictions which the law places on
someone to whom a power to make a discre-
tionary decision has been confided. Mullan,
Administrative Law (Carswell, 1973) de-
scribes the legal position at para. 107 as
follows:
Discretion exists every time a decision-
maker deriving his authority from statute
has a choice between two or more courses
of action. Where the courts will not
usually substitute their view as to how
such a discretion is to be exercised,
they will ensure that the decision-maker
uses his authority within certain
limits. First, it is necessary that
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there be an absence of bad faith or fraud
in the authority making the decision. In
addition, there must be a genuine as
opposed to a purported use of discretion-
ary power. This means that the
decision-maker charged with the taking of
the decision should personally exercise
the authority conferred upon him and
should neither act under dictation from
some person not charged with the exercise
of the discretion nor delegate the dis-
cretionary power to another. Addition-
ally, the discretion should be exercised
in relation to each individual matter
coming before the decision-maker and
should not be automatically determined or
even fettered by reason of a rigid policy
laid down in advance. Of course, the
laying down of general guidelines and
principles for future action by a
statutory decision-maker is not objec-
tionable so long as he still considers
the merits of each individual matter for
decision in the light of those guidelines
and principles and is prepared to admit
of exceptions to the general policy in
appropriate cases.
Continuing in para. 108 the learned author
states:
Beyond the requirements of good faith and
a genuine exercise of discretionary
powers, the courts do have a further role
in ensuring that the decision-making
authority keeps within the proper scope
of the empowering statute while perform-
ing his functions. Discretionary power
must not be used for improper purpose.
Extraneous factors or irrelevant consid-
erations must not be taken into account.
Conversely, all relevant factors must be
taken into account.
And again in para. 109:
Even if the decision-maker in question
takes into account all relevant factors
and does not take into account any extra-
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neous considerations, he may still be
subject to review on the basis that the
decision or conclusion ultimately reached
was so unreasonable that no reasonable
authority could ever have come to it.
The ability of the courts to review deci-
sions on this basis of unreasonableness
is not, however, frequently utilized
since the courts generally express reluc-
tance in interfering with the actual
merits of discretionary decisions.
It will be observed that these principles
arise from the general law, but that they
have been largely created by a process of
statutory interpretation. Similarly,
arbitrators have applied similar principles
as a part of the process of collective
agreement interpretation where, having
regard to all of the language used by the
parties, it is impossible to conclude that
the conferral of a certain decision-making
authority on management could have been
intended to confer an untrammelled and
capricious license. In every case, the
standard of arbitral review of management's
action will depend upon the words used by
the parties to confer the discretion, in the
context of the collective agreement in which
the discretion is included."
....where the parties have agreed to give
the employer a discretion to suspend the
payment of earned benefits in certaih cir-
cumstances, we think that it must have been
intended in using that formulation to incor-
porate a number of the elements of the
administrative law concept of discretion.
In particular, we think that the exercise of
the employer's discretion must be in good
faith, must be a genuine exercise of discre-
tion and not merely the application of a
rigid policy, and must include a consider-
ation of the merits of each individual
case. All relevant factors must
be considered, but no extraneous or irrele-
vant considerations may be taken into
account."
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In the matter before this Board, th~re can be no
doubt that management is given broad discretionary powers under
Article 54 to grant or refuse a special request for paid leave
of absence. However, the Board cannot accept Mr. Fleishman's
initial argument that as a result of the Court of Appeal
Judgment in Metropolitan Toronto that the exercise of
management's discretion can no longer be the subject of arbi-
tral review. In the Collective Agreement before us, we find
that the Parties have contemplated the inclusion of the basic
elements of administrative law jurisprudence in the exercise by
management of discretionary powers.
In our opinion, the Metropolitan Toronto Judgment
does not change the arbitral jurisprudence as stated by
Grievance Settlement Board Vice-Chairman Swinton in Re Young
and the Crown in Ri ht of Ontario (Ministr of Communit and
Social Services ), 220/79 and reported at (1979), 24 L.A.C.
(2d) 145. In that matter, the grievor alleged that she had
been unjustly denied a leave of absence without pay, pursuant
to Article 29.1 of the Working Conditions Collective Agreement
in place at the time. In that case, the Article in question
read:
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"Leave of absence without pay and without
the accumulation of credits may be granted
to an employee by the Deputy Minister."
At pages 147 and 148 of the Award, Vice-Chairman
Swinton states:
"The grievor is arguing that she. has been
unreasonably denied leave of absence under
art. 29.1. While that article is framed in
a way which appears to give management an
unlimited discretion in the granting or de-
nial of leaves of absence, in fact that dis-
cretion must be exercised in a non-
discriminatory and reasonable manner, as
many arbitration awards have held: Re
Canada Valve Ltd. and Intll Molders & Allied
Workers' Union, Local 279 (1975),9 L.A.C.
(2d) 414 (Shime)j Re York University arid
C.U.P.E., Local 1356 (1976), 12 L.A.C. (2d)
213 (Abbott). The employer, in deciding
whether to grant or deny a leave of absence,
must consider the merits of the individual
application... "
An arbitration board, in subsequently
assessing what the employer has done in
reaching its decision, then plays a restric-
ted role. It must decide whether the em-
ployer has acted reasonably and without dis-
crimination and has turned its mind to the
merits of the particular request. If satis-
fied that these criteria have been met, the
board must deny the grievance, even if it
disagrees with the result reached by the
employer or if it might have reached a
decision other than that reached by the
employer. The board's concern is the
reasonableness of the decision, not its
'correctness' in the board's view. Such an
approach is the proper one to adopt in
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situations such as leave of absence cases,
where the collective agreement gives the
employer a broad discretion and where the
board has less familiarity than has the
employer with the needs of the work place.
Unlike the disciplinary area, where employee
interests in job security require active
arbitral review, it is unwise for an arbi-
tration board to second guess management in
the structuring of the work-load."
In cases involving the exercise of managerial
discretion, Boards of Arbitration generally hesitate to
substitute their view for that of the decision-maker, which is
a recognition of the fact that Boards have less familiarity
than does the Employer with the exigencies of the work place.
However, Arbitrators must ensure that decisions are made within
the confines of certain minimum standards of administrative
justice.
Those administrative law concepts relating to the
proper exercise of discretion include the following
considerations:
1) The decision must be made in good faith
and without discrimination.
2) It must be a genuine exercise of discre-
tionary power, as opposed to rigid policy
adherence.
3) Consideration must be given to the
merits of the individual application under
review.
4) All relevant facts must be considered
and conversely irrelevant consideration must
be rejected.
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In the application of those minimum guidelines to the
evidence presented, the Board is not satisfied that the
Employer has given adequate consideration to the procedural
requirements of fairness as set out above.
At the Hearing, the Employer presented insufficient
evidence to establish the nature of the enquiry during which
management exercised its decision making process.
There is no
evidence to establish when and where the enquiry took place, or
who was in attendance at the enquiry, or the extent of the
Employer's investigation.
On ~he evidence, the Board is not satisfied that the
Grievor's personal circumstances were taken into account, in
spite of the general statement of Charles Malloy that "the
circumstances of the Grievor were considered". Mr. Malloy's
evidence was to the effect that management concluded that
because most patrol yard personnel did manage to get to work at
both the Burlington Patrol Yard and Duff's Corners Patrol Yard,
the Grievor should have been able to do likewise.
Mr. Malloy
alleged that information available at the time of the enquiry
satisfied the Employer that Highways 403 and the Q.E.W. to
Burlington were passable at all relevant times.
. .
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In summary, there was insufficient evidence presented
to establish the extent of the Employer's investigation in the
denial of paid leave of absence.
As a result, management has
failed to establish that any meaningful consideration was given
to the Grievor's personal circumstances.
The Board is of the
opinion that the facts listed in evidence at the Hearing would
have been readily available to the Employer. With knowledge of
that information, the Employer would have been able to make its
decision, either to grant or deny the leave of absence, in a
reasonable manner.
Accordingly, deficiencies in the
presentation of evidence by the Employer lead the Board to the
conclusion that special leave was unreasonably withheld.
In our opinion, there was insufficient evidence to
establish whether or not the Ministry decision was made in good
faith and without discrimination.
However, evidence advanced
by the Union in support of alleged discrimination on the part
of this Employer by reference to another Ministry's policy in
its. application to employees in a different geographical area
during the same snowstorm, is not, in this case, a relevant
consideration.
Similarly, on the evidence presented by the Employer,
the Board is unable to find that there has been a genuine
exercise of discretionary power as distinct from rigid policy
adherence.
The Board accepts the Union's contention that the
Employer lacks the unilateral right to reduce or deduct earned
. .
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credits from an employee's accumulated bank of credits.
The
relevant Collective Agreement provides for employee
accumulation of credits such a travel credits, vacation
credits, attendance credits and earned overtime credits, all of
which are earned by employees on the basis of service, pursuant
to the terms of the Collective Agreement.
In our opinion, the
Collective Agreement contemplates that employees be given the
right to make an input prior to any reduction of accumulated
credits.
In this grievance, the Grievor was afforded no such
opportunity prior to management's unilateral decision to deduct
1 day from his vacation credits.
In the result, this grievance is upheld and the
Grievor shall be granted special leave with pay for his absence
on February 28, 1984. In addition, the lost vacation credit
will be reinstated.
DATED at Brantford, Ontario, this
9th day of April, 1985.
.L:
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R. L. Verity, Q.C. - Vice-Chairman
/k~'n- A. ~
M. Perrin - Member
"I dissent" (see attached)
L. Foreman
. -
DISSENT
Re: OPSEU (Pieter B. Kuyntjes) and Ministry of Transportation &
Communications - 513/84
Reading dissents is not normally one of my favourite pastimes. Writing
them is even less so. Nevertheless, in the circumstances of this case
I feel it is necessary to set out, in some detail, the reasons why, with
great respect, I cannot support this award.
(A) The Arbitral Authorities
In my opinion, this decision rests on a misstatement and misapplication
of the relevant law. In arriving at a set of minimum standards of
administrative justice, the majority quotes with approval Mullan's text
on Administrative Law. As I read the extract on pages 11, 12, and 13 of
this award, Mullan enumerates five considerations:
(1) It is necessary that there be an absence of bad faith or fraud.
(2) There must be a genuine as opposed to a purported use of
discretionary power, i.e., the decision maker should personally
exercise the authority.
(3) The discretion should be exercised in relation to each individual
matter and should not be automatically determined by reason of
a rigid policy laid down in advance.
(4) Extraneous factors or irrelevant considerations must not be taken
into account. Conversely, all relevant factors must be taken
into account.
(5) The decision cannot be so unreasonable that no reasonable authority
could ever come to it.
Having cited
Professor Swan in
on thi s revi ew,
administrative law
Mullan, the majority then reviewed the
Meadow Park and Vice-Chairman Swinton in
the Chairman then lists the minimum
concepts on page 16. To wit:
decisions of
Young. Based
standa rds of
(1) The decision must be made in good faith and without discrimination.
(2) It must be a genuine exercise of discretionary power, as opposed
to rigid policy adherence.
(3) Consideration must be given to the merits of the individual
application under review.
(4) All relevant facts must be considered and conversely irrelevant
consideration must be rejected.
2
Unfortunately, and in my oplnlon incorrectly, this latter statement of
minimum standards separates the application of a rigid policy from the
consideration of the merits of each individual matter. As well, it drops
the requirement for reasonableness, which is an essential element of both
the other awards.
Finally, the decision proceeds to expand the third consideration on
page 18 when there is a requirement that it must be a "meaningful"
consi derati on. Thi s injects an unwonted el ement of subjecti vity to the
arbitral review that is not found in any of the cases submitted by the
parties or cited in the award.
But more important is the separation of the rigid policy from the
consideration of the individual merits. In my humble opinion, the real
test of whether or not consideration was given to the individual merits
rests on whether there was a blanket application of a rigid, predetermined
policy.
(B) Constraints on the Exercise of Discretion
On page 10, this award cites with approval a statement that,
"Arbitrators exceed their jurisdiction if they purport to establish
general principles for the administration of collective agreements
divorced from the language negotiated by the parties in the matter
before them....every allegation that an employer is in breach
of the collective agreement must be considered individually,
against the language which the parties themselves negotiated,
and in accordance with the well known canons of construction."
Again on page 13 Professor Swan is quoted as follows,
"Having regard to all of the language used by the parties, it
is impossible to conclude that the conferral of a certain
deci si on-maki ng authority on management coul d have been intended
to confer an untrammelled and capricious licence. In every case,
the standard of arbitral review of management's action will depend
upon the. words used by the parties to confer the discretion,
in the context of the collective agreement in which the discretion
is included."
The arbitrator then proceeds to deal with a situation in which the employer
purported to suspend the payment of an earned benefit. Surely the principle
articulated by Swan and other cases is that arbitrators should not import
concepts to a collective agreement that the language cannot reasonably
bea r .
In my oplnlon, the collective agreement in the instant case does not
confer unfettered discretion to management. At the very least, the exercise
must not be arbitrary, discriminatory, or in bad faith. Having said that,
I believe that the rigour with which the test is applied depends on the
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circumstances of the case and the particular language. For example, the
employer's actions would be open to a more stringent examination in a
situation involving an earned benefit than would be the case for an unearned
benefit. An analogy can be drawn to the arbitral application of the test
of just cause as it appl ies to permanent and probationary employees. It
is now widely accepted that the test of just cause for probationary employees
is much less rigourous than that which applies to permanent staff.
Article 54 of the collective agreement states that,
"A Deputy Minister or his designee may grant an employee leave
of absence with pay for not more than three (3) days in a year
upon special or compassionate grounds."
The first thing to note is that we are dealing with an unearned benefit.
Second, it is a 1 ea ve of absence with pay. Both these facts suggest, to
me, that review of the exercise of discretion would necessarily be less
rigourous than would apply in circumstances when an arbitrator is dealing
with removal of an earned benefit or a request for a leave of absence without
pay. Yet in this particular case the majority has seen fit to apply a
more stringent test than was used by arbitrators Swan and Swinton in cases
involving an earned benefit and a leave of absence without pay, respectively.
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4
Only after an employee has managed to place himself squarely within
the grounds for granting the leave may the exercise of discretion be called
under revi ew. Even then, as noted above, such a revi ew wi 11 necessarily
be constrained by the fact that the language would indicate that this is
a gift and there must be some evidence that the gift was given or withheld
discriminatorily.
In the particular case, the Grievor failed to establish that the
circumstances were sufficiently special in order to cause the Deputy Minister
to grant the leave. Not only did no other employee apply for the same
provision, the vast majority (18 of 20) of employees on the night shift
in that area managed to get to work. In my opinion, the Grievor has not
managed to clear the first hurdle so it may not even be necessary to consider
the exercise of discretion. But if it is necessary to do so, I believe
that the review should be conducted with a relatively low threshold
requi rement.
(D) The Evidence
The first obligation of an Arbitration Board is to act as a finder
of fact. In this regard, a Board can only deal with the evidence presented
to it. Unfortunately, there appears to be a lack of information concerning
the nature, timing, and extent of the employer's investigation. But that,
surely, is not the point at issue. The requirement is that the employer
consider the merits of the individual case and not apply a blanket policy.
The extent and nature of the investigation is at best a secondary factor,
if relevant at all. What evidence, then, was presented to the Board to
deal with this issue?
On page 18 the majority states,
liThe Board is of the opinion that the facts listed in evidence
at the hearing would have been readily available to the employer.
With knowledge of that information, the employer would have been
able to make its decision, either to grant or deny the leave
of absence, in a reasonable manner.1I
There was no evidence that the Ministry relied on any other evidence, in
coming to its decision, than that presented at the hearing. Surely, the
inference to be drawn is that the evidence (which the Board finds
satisfactory to make a reasonable decision) is the same evidence that the
Ministry used in arriving at its decision.
In addition, the majority notes on page 17 that the Ministry official
gi vi ng evi dence stated that, liThe ci rcumstances of the Gri evor were
consi dered". Thi s evi dence was not di sputed either in cross-exami nati on
or by the submission of alternative evidence on the part of the Grievor
that the circumstances were not considered. In those circumstances, I
believe that a Board either ha:s to accept the statement at face value or
make some other finding concerning the credibility of the witness.
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5
Finally, the employer counsel argued, on the basis of evidence
presented, that there was no application of a rigid policy that precluded
the exercise of discretion.
In the face of this evidence, the majority blithely comes to the
concl us i on that the Gri evor' s personal ci rcumstances were not taken into
account. I neither understand nor agree with that conclusion.
(E) The Role of Common Sense
Arbitration Boards were established to remove labour relations from
the legal constraints of the judicial system and inject a level of common
sense and reasonableness into the resolution of industrial disputes.
Deci si ons based on narrow techni ca 1 grounds represent an unfortunate trend
away from this original purpose. Moreover, I believe that Arbitrators
should exercise caution when allowing procedural difficulties to overturn
the substanti ve issues of a case. That is not to say that procedure is
not important or even that it should not be accorded its due. This is
particularly true in cases where there has been a denial of natural justice
or the Grievor is facing severe disciplinary penalties, such as discharge.
But that is not the situation in this particular grievance. The substantive
issue is whether or not the Grievor has a right to a particular unearned
benefit. While the employer may be required to follow certain rules in
order to establish that it acted properly, that should not be allowed to
cloud the real issue. In this particular case, 18 of the Grievor's
colleagues, including several who lived in more remote and isolated areas,
managed to get to work. He was the only employee from two adjacent patrol
yards who requested special leave. As well, the Ministry relied on him
to be at work to help operate the snowplows during a snowstorm. Common
sense suggests that he is not entitled to be paid for his absence from
work. To find otherwise, while it may arguably be correct in a very narrow,
procedura 1 sense, has the effect of turni ng the purpose of Arti cl e 54 on
its head. Arbitrators should exercise great care before they abandon common
sense in favour of technicalities.
Conclusion
In summary, I would allow the grievance in part. I would find that
the employer improperly deducted a vacation day from the Grievor's bank
of credits. At the same time, I would find that he is not entitled to
be paid for February 28, 1984 "as a discretionary day". Thus, I would
direct the parties to determine whether the employee wishes to be deducted
a day's payor some other attendance credi tin recogni ti on of the fact
that he is not entitled to be paid for that date.
All of which is respectfully SUbmitted.tI"~/'//(;~' ~:, ,
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Le lle &: For man