HomeMy WebLinkAbout3786-04-U - Bouchard 05-05-09
Bouchard v. Ontario Public Service Employees Union, 2005 CanLII 35106 (ON L.R.B.) Page 1 of 13
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This document: 2005 CanLlI 35106 (ON L.R.B.)
Citation: Bouchard v. Ontario Public Service Employees Union, 2005 CanLlI 35106 (ON L.R.B.)
Date: 2005-05-09
Docket: 3786-04-U
[N ()t~.LJP] [CitE?c:f.PE?Gi?i()n?9Dgl,,~gi$19tiQn]
3786-04-U Michael Bouchard, Applicant v. Ontario Public Service Employees Union,
Responding Party v. The Ministry of the Environment and Energy, Intervenor.
BEFORE: David A. McKee, Vice-Chair.
DECISION OF THE BOARD; May 9, 2005
1. This is an application made pursuant to section 96 of the Labour Relations Act, 1995, S.O.
1995, ch. 1, as am. (the "Act"). The applicant, Michael Bouchard, complains that his Union, the Ontario
Public Service Employees Union ("OPSEU") violated section 74 of the Act in the manner in which it
hand led a grievance against the Ministry of the Environment and Energy ("the Ministry"). This
application alleges an unusual set of facts. Essentially, Mr. Bouchard alleges that OPSEU, through its
counsel, conducted his arbitration in such a manner as to ensure that it was not successful. He alleges that
this was a deliberate act on the part of OPSEU and counsel, which was intended to result in the dismissal
of the grievance by an arbitrator sitting as the Grievance Settlement Board. OPSEU has asked that this
matter be dismissed, on the ground that it does not allege facts which could possibly support the
conclusions that Mr. Bouchard would like the Board to come to. This decision deals with that motion.
2. Mr. Bouchard was employed by the Ministry as an air quality technician in the City of
Cornwall from 1979 to 1997. In January 1997 he was advised that he was "surplus" as part of a general
downsizing in the Ministry. He was ultimately laid off in July of 1997.
3. At that time, Mr. Bouchard claimed he should have been permitted to displace a junior
employee in Cornwall, who was working as an "Environmental Officer 4" (E04). OPSEU referred this
matter to arbitration. The case took 11 days of hearing. The grievance failed because the arbitrator, Mr.
Richard Brown, concluded that Mr. Bouchard was not "qualified to perform the work of the identified
employee". In a displacement grievance, the arbitrator found that it was necessary to demonstrate that he
had a "present ability" to do the job. The arbitrator found that Mr. Bouchard had not demonstrated such
ability and identified a number of "deficiencies" in his capacity to perform the job. Mr. Bouchard does
not complain about the conduct of this grievance or the conclusion to which the arbitrator came. That is
not the subject of this complaint.
4. On November 20, 1998, the Ministry posted an E04 job in the Cornwall area. Mr. Bouchard
still had recall rights at that time. These recall rights lasted until July 1999. He had greater seniority than
the successful candidate. He was not recalled to the job because the Ministry concluded that he was not
"qualified to perform the required duties". This phrase, taken from Article 20.6.1 of the collective
agreement has a different meaning from the provision quoted with respect to his first grievance, as will be
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explained below.
5. Mr. Bouchard filed a grievance, and OPSEU referred it to arbitration. There were two days
of hearings with respect to the Ministry's preliminary motions and six days with respect to the merits of
the case. The grievance was dismissed.
6. Mr. Bouchard pleads that OPSEU violated the duty of fair representation in the manner in
which it handled the grievance. In his initial application, he pleads:
"It is the applicant's position that the responding party's failure in this regard was
deliberate and/or seriously arbitrary, and that this failure to call evidence reflected an
underlying reluctance, on the part ofthe responding party, to see the applicant succeed with the
grievance" .
7. In submissions in response to OPSEU's motion to dismiss the application, Mr. Bouchard
pleads, through his counsel, more forcefully. He states:
"In the simplest of terms, it is the applicant's position that the respondent party handled
the applicant's recall grievance in a manner that was deliberately intended to result in the
dismissal of the said grievance by the Grievance Settlement Board".
And somewhat later:
"The responding party engaged in a deliberate scheme to undermine the applicant's
chances of success".
8. Mr. Bouchard states that he acknowledges that the Board is "typically reluctant to second-
guess the manner in which a trade union presents a case at arbitration". This is correct, and is reflected in
paragraph 6 of the April 5, 2005 decision directing him to make submissions on this motion. That does
not apply here. If the action was a deliberate course of conduct to sabotage Mr. Bouchard's case, then
that is clearly a violation of section 74. In his second submissions, Mr. Bouchard says:
"While the Board might be understandably reluctant to accept the proposition that a trade
union might act in this fashion, the applicant has clearly pleaded materials which, if accepted to
be true, could support this conclusion".
There is no reluctance on the part of the Board to come to any particular factual conclusion. This specific
allegation is well within the realm of possibility. If it is proven, the Board would have no hesitation in
naming the Union, the officers, and the counsel involved, and fashioning an appropriate remedy.
9. The question is whether there are material facts that could support the conclusion that Mr.
Bouchard asks the Board to come to. In his reply submissions, counsel for the applicant makes much of
his desire to challenge the "unsworn allegations" of the Union, and the need to test the credibility of
differing stories by cross-examination. That is not the case at this stage of this application. In
determining whether the application pleads facts capable of supporting the remedies sought, the Board
will accept as true and provable all of the facts as alleged in the application and the applicant's further
submissions.
10. The test is not a particularly stringent one for an applicant. The Board has in The County of
Brant, [2000] OLRB Rep. Nov./Dec. 1106 set out the relevant principles that are applicable in
determining whether an application has made out aprimafacie case at pages 1107-08:
The Board in International Union of Bricklayers and Allied Craftworkers, Board File Nos.
1645-98-U and 1768-98-U, decision dated February 19, 1999, unreported, [1999] O.L.R.D.
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No. 1392, had occasion to discuss the approach used by the Board when determining whether
to dismiss an application because it did not disclose a prima facie case. The Board stated at
paragraphs 4 and 5:
The test that a responding party must meet in order to persuade the Board that an
application should be dismissed on the basis that there is no prima facie case
established in the application is, in my view, a strict one. An applicant should
not be deprived of the opportunity to have a hearing on the merits of his or her
application simply because the argument is novel or the circumstances giving
rise to the application are unusual. In Caravelle Foods, [1983] OLRB Rep. June
875 the Board characterized the test a responding party must meet in seeking to
have an application dismissed on a prima facie motion in the following terms at
page 881:
The words 'primafacie case' in section 71 are meant to allow the dismissal of a
case without a hearing where the allegations are insufficient to render reasonable
or arguable a conclusion that the Act has been breached.
In 1. Paiva Foods Ltd, [1985] OLRB Rep. May 690 the Board set out the test at
page 691 as follows:
The Board's discretion to dismiss a complaint on the grounds that it does not
disclose a primafacie case should only be exercised in the clearest of cases, that
is, when the Board is satisfied that there is no reasonable likelihood that a
violation of the Act can be established on the facts as alleged.
Where, however, the Board is satisfied that the responding party bringing the
prima facie motion has met the burden imposed, it is incumbent on the Board to
dismiss the application, thereby conserving the limited resources of the Board
for matters that do require a hearing. As Mr. Justice Grange said in Shaw v.
McLeod, (1982), 35 O.R. (2d) 641:
I concede that on this motion if, after a careful review of the law, the Court
determines that he [the Plaintiff] cannot possibly succeed, then his action should
be mercifully dispatched.
See also Elizabeth Balanyk, [1987] OLRB Rep. Sept. 1121 at page 1123; Lyndhurst Hospital,
[1996] OLRB Rep. May/June 456 at 465-66; and Hunt v. Carey Canada Inc.,
19?~)q(~rlIJI?'()j?:~~:.C.::'), (1990), 74 D.L.R. (4th) 321 (S.c.c.) where the Supreme Court of
Canada wrote at page 333:
Thus, the test in Canada governing the application of provisions like Rule 19(24)(a) of the
British Columbia Rules of Court is the same as the one that governs an application under
R.S.C., O. 18, r. 19: assuming that the facts as stated in the statement of claim can be
proved, is it "plain and obvious" that the plaintiffs statement of claim discloses no
reasonable cause of action? As in England, if there is a chance that the plaintiff might
succeed, then the plaintiff should not be "driven from the judgment seat". Neither the
length and complexity of the issues, the novelty of the cause of action, nor the potential
for the defendant to present a strong defence should prevent the plaintiff from proceeding
with his or her case.
11. There is a difference, however, between facts and the conclusions one draws from those
facts. The assertion that counsel did not seek certain training schedules until after two witnesses were
called is a fact. The assertion that this was part of a deliberate scheme to undermine Mr. Bouchard's
chances of success is a conclusion. Mr. Bouchard suggests this is a matter of credibility that can only be
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assessed after viva voce evidence. If there is some evidence that could support such a conclusion he
would likely be right. However, the first question is whether there are facts that could possibly lead to the
conclusion urged upon the Board. The test is whether or not it is possible that the Board could come to
such a conclusion, not whether it is likely.
12. In an analogous matter, one justice of the Superior Court of Justice has commented on the
nature of the process of examining statements and drawing conclusions from them. In Braithwaite
Technology Consultants Inc. v. Blanketware Corp. (2004) 72 O.R. (3d), Cullity, J., sitting on a motion for
summary judgment under the simplified rules (which permit no cross-examination on affidavits without
leave) said this about credibility:
[20] It was indicated in Newcourt that issues of credibility may sometimes be
disposed of in motions under Rule 76.07. This, I believe, reflects a recognition
that such issues are not always only - or even best - determined by an
examination of a witness's demeanour when testifying. In Cash Converters
Canada Inc et al v. 1167430 Ontario Inc., [2001] O. J. No. 5860 (S.C.J.), at paras
42 - 6, O'Driscoll J. found guidance in the following passage in reasons delivered
by O'Halloran J.A. in the British Columbia Court of Appeal:
The judge is not given a divine insight into the hearts and minds of the witnesses
that appear before him. Justice does not descend automatically upon the best
actor in the witness box. The most satisfactory judicial test of truth is in its
harmony or lack of harmony with the preponderance of probabilities disclosed
by the facts and circumstances in the conditions of a particular case.
[21] O'Driscoll J stated:
Using Q'Halloran 1.A.'s criteria to test credibility, how do the depositions of the
respondents fit into the overall mosaic? How does their evidence and their cross-
examinations fit into the jigsaw puzzle that I seek to solve? It is my conclusion
that the evidence of the respondents is totally self--serving. It is wrong-shaped.
It is wrong-coloured. It is bad-coloured. The pieces are either too big or too
small and do not fit the puzzle. The depositions ofthe respondents do not fit and
blend with the other evidence that I accept.
[22] The same approach to questions of credibility is, I believe, apparent in
the decision of the Supreme Court of Canada in Guarantee Co. of North America
v. Gordon Capital Corporation!..~~~.g.t:l.~~.I..'??~J?:g.g), (1999), 178 D.L.R.
(4th) 1 (S.C.C.), where it had been submitted by counsel that, on a motion for
summary judgment under Rule 20, triable issues were raised by assertions in a
responding affidavit that "moderated" evidence previously given by the
deponent. In rejecting the submission, the court stated:
... a self--serving affidavit is not sufficient in itself to create a triable issue in the
absence of detailed facts and supporting evidence. See Rogers Cable TV Ltd v.
373041 Ontario Limited. ;~ireflex, (1994),22 Q.R. (3d) 25 (Gen. Div.);
."J.,................,
Confederation Trust Co v. Alizadeh, [1998] Q. 1. No. 4080 (QL) (Gen. Div.).
[23] Just as such assertions may be insufficient to raise an issue of credibility,
or other triable issues, for the purpose of Rule 20, they may be found to lack
probative force in rebuttal of the evidence supporting the plaintiff's claims on a
motion pursuant to rule 76.07 notwithstanding that there will have been no cross-
examination. That does not mean, of course, that all issues of credibility can be
decided on such a motion. The governing criteria are those set out in the rule:
namely, whether the court is satisfied that the issues can be decided without
cross-examination and whether it would not otherwise be unjust to do so on the
motion.
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13. The issue here is not one of credibility, but rather whether any reasonable view of the facts
pleaded could sustain a conclusion that OPSEU had instructed counsel to conduct the case in such a way
as to ensure its failure. It is therefore necessary to look at each fact pleaded and determine if such a
conclusion can be reached from any of the facts or all of them together.
14. The legal issues in the grievance were as follows. Mr. Bouchard wanted the position of an
E04 Officer. Initially, he wanted to displace a junior employee who held the job. After an II-day
hearing, the arbitrator found that he was not "qualified to perform the work of the identified employee".
In the context of that case, the phrase meant that he needed to demonstrate that he was able to step into
the position and perform all duties virtually immediately. The arbitrator concluded he did not have that
capacity and identified a number of "deficiencies". By that term, he meant to cast no aspersions on Mr.
Bouchard, but simply to identify the skills, experience and qualifications that he lacked.
15. In the second grievance, Mr. Bouchard again sought the position of an E04. There was a
vacancy for the position. He was entitled by virtue of his seniority to claim the job as a means of
ensuring a recall to employment. The provision of the collective agreement dealing with this right is set
out in Article 20.6.1 which provides:
20.6.1 A person who has been laid off is entitled to be assigned to a position that
becomes vacant within twenty-four (24) months after his or her layoff provided
that:
(a) the vacant position is in the same classification and ministry
as his or her former position; and
(b) the vacant position is within a forty (40) kilometre radius of
his or her former headquarters; and
(c) he or she is qualified to perform the required duties; and
(d) there is no other person who is qualified to perform the
required duties, who has a greater length of continuous
service and who is eligible for assignment to the vacancy
either ......... .. .. .. ..
16. There were a number of issues. These are set out in the letter from counsel to OPSEU dated
June 7, 2000, before the grievance was referred to arbitration. In that letter, counsel identified the
following issues:
Preliminary Issue No.1: Did the arbitrator's decision in the first case constitute a
complete answer to the second grievance. That is, was his determination res judicata.
Counsel opined that this argument was unlikely to succeed given that there was a
different test to be applied.
Preliminary Issue No.2: Counsel anticipated an argument with respect to the fact
that he had declined a position in Toronto and that this, it would be argued,
compromised his ability to claim that job in the second grievance. (Apparently the
employer never made this argument).
The merits of the grievance: If the grievance got over the preliminary issues, the
only question, in counsel's view, was whether the "Hill and Campbell exception"
should apply. COllnsel identified the issue in this fashion:
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(1) Did the Ministry of Environment have a mandatory trammg program as
contemplated by Hill and Campbell and Bazinet (previous decisions of the
Grievance Settlement Board);
(2) If so, would Mr. Bouchard be minimally qualified or have the present ability to
perform the required duties of the position upon completion of the mandatory
training associated with the job.
In fact, this was the view that the arbitrator took of the issues in the case. He said at paragraph 8:
Accordingly, the remaining issues in this case are two-fold: (1) were vacancies in the
position of E04 Abatement Officer at the relevant time typically filled by employees who
received further training to be fully qualified to do the job; and (2) if so, would Mr. Bouchard
have been qualified ifhe had received the sort of training offered to others?
17. Mr. Bouchard does not dispute that these were the two issues at stake in the case. That is, he
accepts that counsel's analysis of the issues was correct. I recognize that Mr. Bouchard's case is that the
communication between counsel and OPSEU was merely a subterfuge designed to disguise the fact that
there was a deliberate policy of undermining his grievance. I refer to the letter only to indicate that
counsel had, in fact, identified those issues initially and Mr. Bouchard accepts that those were the legal
and factual issues that needed to be addressed in the arbitration.
18. Counsel then went on to discuss the likelihood of success. For various reasons, based on his
experience of the first grievance, and the facts as he understood them, he concluded that the grievance
was more likely to be dismissed than not. Whatever the merits of this opinion, Mr. Bouchard agrees that
it correctly identified the factual and legal issues in the case. The fact that the opinion was, on balance,
that the grievance was unlikely to succeed, is irrelevant. OPSEU determined that the grievance would
proceed nonetheless. Had OPSEU determined not to refer the grievance to arbitration at this stage, such
evidence might possibly be the foundation for a conclusion that OPSEU and counsel had colluded to
produce an opinion that did not reflect the true chances of success. However, this is not the case. The
most that one could make of this evidence was that the negative opinion was a ruse to "set the stage" for a
later failure at arbitration. However, before one could come to that conclusion, it would be necessary to
point to a deliberate sabotage of the case as it progressed. The fact of a negative opinion cannot, in the
circumstances of this case, in and of itself sustain a conclusion of bad faith.
Events Before the Grievance
19. Mr. Bouchard complains that it took more than two years for OPSEU to arrange a meeting
with the applicant and that the meeting took place on the eve of a scheduled mediation session. This does
appear to be a long time, but the applicant pleads no facts relating to the backlog of grievances that
OPSEU was facing in the year 2000 or 2001. The Board is aware that from time to time that backlog
becomes extremely lengthy. I do not mean that the Board is unconcerned about that length of a backlog,
but simply that the Board has no facts to judge whether the grievance was being processed as quickly as
any other grievance or whether it was being deliberately held back. The fact of this delay does not
support any particular conclusion.
20. Mr. Bouchard pleads:
"During the course of this initial meeting, the responding party's grievance officer, Don
Martin, expressly told the applicant that he (the applicant) should leave Toronto, as the
responding party did not want to argue the grievance, and did not want to win the grievance."
Accepting, as I must, that this is in fact what he said, nonetheless OPSEU proceeded with the mediation
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session and ultimately referred the matter to arbitration. Accordingly, these facts could not in themselves
be evidence of an act which undermined Mr. Bouchard's grievance, but simply be evidence of
motivation. It would require specific evidence, capable of supporting a conclusion that the grievance had
been undermined before this piece of evidence would have any meaning.
21. At the mediation session, the employer raised the issue of res judicata as had been predicted
by OPSEU's counsel. Mr. Bouchard pleads:
"Throughout the course of the December, 2002 mediation session, Mr. Martin seemed
reluctant to challenge the Ministry's argument regarding the doctrine of issue estoppel. In fact,
at times during the course of the mediation session, Mr. Martin seemed to be supportive of the
Ministry's argument that the grievance should be dismissed. Fortunately for the applicant,
agreement was eventually reached to have the preliminary objection regarding the doctrine of
issue estoppel decided by Vice-Chair Brown".
Given the result of the mediation session, the assertion that Mr. Martin was supportive of the Ministry's
position is untenable. It may have seemed that way to Mr. Bouchard (which is in fact all he pleads).
However, since the Ministry was seeking to have the Union withdraw the grievance because it was barred
by the doctrine of res judicata, and since Mr. Bouchard does not suggest that he made any comments on
this issue, that would leave only Mr. Martin as the party proposing or insisting that it be determined by
Vice-Chair Brown. It seems to me that this was an entirely appropriate thing for Mr. Martin to have
done. It negates any possible conclusion that he was supportive of the Ministry's position.
22. Mr. Bouchard asked OPSEU to provide him with counsel for this case from an outside law
firm. In fact, he suggested the same lawyer who had represented him on the first grievance as an
appropriate person to handle the case. OPSEU initially declined. Section 74 does not impose on a trade
union an obligation to hire a lawyer to conduct a grievance.
23. Mr. Martin handled the evidence and argument with respect to the preliminary objection.
The argument took two days in late 2002. Mr. Martin succeeded in resisting the employer's motion to
dismiss on the basis of res judicata. The fact that he succeeded is hardly evidence of a deliberate attempt
to undermine the grievance. It may well be that Mr. Martin displayed what, to Mr. Bouchard, was an
inadequate level of optimism or enthusiasm about the grievance during the course of arguing this
preliminary issue. The Act does not require enthusiasm or passionate belief in the cause espoused by a
grievor. It requires that a union behave in a manner that is not arbitrary, discriminatory or in bad faith. It
would be difficult to find that success on a preliminary motion in a grievance was evidence of any of
those things.
24. Thereafter, OPSEU acceded to Mr. Bouchard's wishes and appointed counsel for the
remaining hearing dates. It was, in fact, the same lawyer who had represented him on the first case. This
was, of course, in accordance with his expressed wishes. Mr. Bouchard raises no issue with respect to the
fact that Mr. Brown was once again the arbitrator.
The Arbitration Hearing
25. Mr. Bouchard does not take any issue with the manner in which the case was framed. That
is, his complaint accepts as a given that counsel identified the correct legal and factual issues and that
they were dealt with by the arbitrator. Rather, his complaint is that a presentation of evidence was
deliberately mishandled so as to ensure the defeat of the grievance. As Mr. Bouchard sets out in his
application, there were three factual issues to be addressed:
(a) The qualifications and training possessed by others who had secured the
job when a vacancy was posted;
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(b) The training that was required and/or available upon obtaining such a position;
and
(c) Evidence of whatever sort (Mr. Bouchard says it will only be opinion evidence)
which would persuade the arbitrator that Mr. Bouchard would have been able to
do the E04 job if he had received the same type of training received by others in
the job.
26. The process followed at the arbitration is somewhat different from the typical job-posting
grievance outside of the Ontario Public Service. In a case of this sort, the employer is required to present
its evidence first, although the legal onus rests ultimately on the Union. The Ministry called two
witnesses, Mr. Paterson and Mr. Helliar. They were subject to cross-examination by counsel for OPSEU.
During the course of Mr. Paterson's and Mr. Helliar's evidence, there was considerable evidence about a
mandatory training program. That was what counsel had identified initially as the basis of the "Hill and
Campbell" exception. In addition to the mandatory training program, there were other voluntary or non-
mandatory courses offered. The evidence ofthose two individuals constituted the Ministry's entire case.
27. It was then open to OPSEU to call evidence. Counsel requested and obtained production of
two sets of documents at this point. First, the Union requested and obtained production of resumes for
everyone, without prior E04 experience at the Ministry, who was appointed as an E04 Abatement
Officer between January of 1996 and the Spring of 2003. Second, he sought and obtained production of
a list of courses taken by each of the twelve officers after their appointment at the E04 level. Counsel for
OPSEU then called no further evidence, and argument proceeded on the basis of the evidence before the
arbitrator. He concluded that the grievance did not establish that Mr. Bouchard could have performed the
duties of the job, even with the maximum amount of training that had been afforded to others who had
obtained such a position. The grievance was dismissed.
28. Mr. Bouchard complains that counsel for OPSEU failed to call two kinds of evidence.
Specifically, he asserts that counsel ought to have called one or more, or perhaps all twelve, of the
successful applicants with respect to their qualifications and training, and secondly, that he ought to have
led evidence either through those twelve individuals or through Mr. Paterson or Mr. Helliar about the
likely effect oftraining on Mr. Bouchard's ability to perform the job. I shall deal with these in two parts.
Precise Qualifications and Training
29. The issue with respect to the qualifications and training of the twelve individuals who did
obtain the job in and around the time of this job posting was not their level of skill and qualifications as
compared to that of Mr. Bouchard. If he was qualified to do the duties of the job, then his grievance
succeeded. I conclude that the only value in adducing any evidence about the qualifications and training
of the other twelve individuals was to show that their qualifications were similar to those of Mr.
Bouchard. It was taken as a given (for reasons not disclosed in the award and which Mr. Bouchard does
not challenge) that the evidence and findings of fact in the first arbitration were available to the parties
and the arbitrator in the second arbitration
30. The second grievance proceeded on the basis that the arbitrator had already found that Mr.
Bouchard's previous training and experience were not sufficient to permit him to perform the duties of
the job immediately. This was not a matter that Mr. Bouchard suggests could be disputed in the second
grievance. However, if it could be demonstrated that the level of qualifications and training of the other
twelve who received the job was no better than that of Mr. Bouchard's, then logically it was the training
they received that made the difference. Counsel therefore required production of the resumes for the
twelve persons who were appointed from 1996 to 2003 to the position.
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3l.
11:
It is apparent from the award that this step did not assist the case. The arbitrator said at page
. .. In response to this request, resumes for twelve officers were produced. Reviewing
these documents after the hearing, I noted the resumes for five of the twelve indicated they had
worked in a junior abatement position before being appointed at the E04 level. I asked the
parties about this. The response of counsel for the employer was that six of the twelve in fact
did have prior abatement experience with the Ministry and should be ignored. Union counsel
asserted the employer should not be allowed to revoke its earlier stipulation that none of the
twelve had such experience. This evidentiary dispute need not be resolved, because its
resolution would not affect the disposition of the grievance.
Of the twelve new E04 abatement officers, seven at the time of appointment held
either a university degree or a community-college diploma in environmental science,
environmental studies, environmental health or environmental technology. The other five had
at least a degree or diploma in a related field: Bradshaw had a BSc. in geology and a MSc. in
earth sciences; Leavoy had a diploma in terrain and water resource technology; Lendvay had a
BSc. in biology from one university and had taken seven environmental courses at two others;
McNiece had one diploma in natural resources technology law enforcement and another as a
fish and wildlife technician; and Ryan had a diploma in civil engineering with an
environmental speciality.
And again at page 14:
In coming to this conclusion, I have not overlooked the fact that the officers were able to
do the E04 abatement job, having received this amount of basic training, or less, after being
appointed to the position. The employer contends some of them had previous experience doing
abatement work. Even if none of them had such experience, their ability to do the job with at
most this amount of basic training post-appointment is not sufficient to demonstrate the grievor
would have b~en qualified if he had gotten the same training, because the evidence does not
show that he was qualified for the job as they were before assuming it. In particular, each of
them held a degree or diploma in an environmental field or some related subject. As noted by
union counsel, such a degree or diploma is not a requirement for the job. Nonetheless, this sort
of formal education is one way to acquire the sort of knowledge that is a requirement.
32. It is obvious to me that counsel was attempting to demonstrate that Mr. Bouchard could have
performed the duties of the job given the available training in one of two ways. One of the ways he
sought to address this was to look at the type of qualifications which were typically held by successful
candidates. If their qualifications were no better than those ofMr. Bouchard's, that would go a long way
to proving the case. To ask the question, however, posed a risk. Counsel clearly did not know the answer
to what those documents would disclose. It is evident that they were not helpful.
33. However, Mr. Bouchard does not criticize the request for production of the resumes. Indeed,
he accepts that this was relevant evidence. His complaint is:
"... at all material times, he urged the responding party to call some and/or all ofthe other
twelve officers as witnesses at the arbitration hearing. Although the applicant is not a lawyer,
it was apparent to him, even as a layperson, that much of the required evidence could only be
adduced through these witnesses".
The decision not to call one or more of these twelve persons cannot possibly lead to the conclusion that it
was based on a conscious decision to sabotage the grievance. To call any of the twelve of them on this
issue would have been foolish in the extreme. Having asked for the resumes, it was presumably as
obvious to counsel as it is to me that they were not helpful to the grievance. To call the individuals as
witnesses about their qualifications could only have worsened Mr. Bouchard's position. If counsel called
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them, the twelve would have been his witnesses. He would have been unable to cross-examine them.
The likelihood that they would minimize the value of their own qualifications for the job, on which they
had relied to get the job in the first place, is so remote that, absent specific evidence that one or more of
them was actually prepared to do so, no reasonable counsel would ever take that step.
34. There are times when it is the function of counsel to make decisions that prevent those they
represent from digging themselves into a deeper hole than they are already in. That is the only conclusion
that one can draw about the decision not to call twelve persons to discuss the issue of their basic
qualifications. To do so would have been a serious tactical error. I do not accept that the fact that counsel
did not call any of the twelve to describe their qualifications could in any way be evidence of a desire to
undermine or sabotage the grievance. It was the right decision to have made.
Training afforded to the Twelve Candidates
35. More serious is the evidence with respect to training received by these same twelve persons.
It is apparent from the arbitration award that cross-examination was directed at the kinds of training that
they received. Training was of two sorts: (a) mandatory and (b) available but not mandatory. These latter
were referred to as "one-hundred level" or "one-hundred series" courses. The evidence of the employer
was that there were once a number of mandatory courses which were rolled up into a single mandatory
course entitled "Level One Compliance", a three-week course. There were also a number of non-
mandatory courses.
36. The opinion given by counsel before the grievance was referred (which analysis Mr.
Bouchard does not challenge) dealt with the likely chance of establishing what counsel called a "Hill and
Campbell" exception. This exception, according to his opinion, is based on the existence of a mandatory
training course. If training is mandatory, it is necessary only to prove that the grievor could have done the
job after taking the training course, i.e. was he capable of starting the training course. It is evident from
the award that counsel did cross-examine Mr. Paterson and Mr. Helliar with respect to that first issue.
Mr. Helliar's response was that the mandatory courses did not teach pollution source identification,
sampling and results interpretation, pollution control processes or spill response. It is again obvious from
the award that counsel was cross-examining the employer's witnesses with respect to the areas identified
by the arbitrator as "deficiencies" in Mr. Bouchard's first case in the hope of persuading the arbitrator that
these deficiencies might be remedied by the mandatory training. This is precisely the kind of "opinion"
evidence that Mr. Bouchard said he should have been seeking.
37. Unfortunately, counsel did not get the kinds of answers that he was hoping for. This may in
fact have been because the witnesses, particularly Mr. Helliar, gave different evidence at the first and
second arbitration. It may simply be that cross-examination was not successful. Certainly Mr. Bouchard
made no allegations that cross-examination was perfunctory, that it did not address any of the issues, or
that it ought to have been conducted in a different manner from the way in which it was conducted.
38. Although the award does not identify it as a secondary argument, my reading of the award is
that counsel then shifted his attack to the second possibility, i.e. that the non-mandatory courses that were
available and were taken by some of the officers would have provided the necessary training for Mr.
Bouchard.
39. The one-hundred level courses were described this way by the arbitrator:
The table produced by Mr. Paterson lists thirteen non-mandatory abatement courses at the
one-hundred level. He testified each of them was offered only when a minimum often people
registered for it. There is no evidence about the duration of these courses and very little
evidence was led about their content. Mr. Paterson did testify they deal more with the
identification of violations than do the mandatory courses.
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In cross-examination, Mr. Paterson was asked about training on the ministry's
compliance policy for new abatement officers between 1995 and 2001, during the years when
this subject was not addressed in mandatory courses. He testified aspects of this subject were
taught in a 1998 course called Introduction to Compliance. However, he conceded between
1995 and 1998 and again between 1998 and 2001, the only place for a new abatement officer
to learn about the ministry's compliance policy was on the job. Asked whether one-hundred
level courses might be accurately described as "basic" or "low-level", Mr. Paterson answered
in the affirmative. He testified they were typically taken by someone in the "first two or three
years" of doing abatement work.
At the hearing of the second grievance, Mr. Helliar testified the mandatory courses did
not teach pollution source identification, sampling and results interpretation, pollution control
processes or spills response. He painted a different picture than he had done previously about
new officers taking one-hundred level courses. In particular, he testified non-mandatory
courses were "recommended" for new abatement officers but often not taken by them. As
reasons why a course might not be taken, he listed only a person already having the requisite
knowledge but also conflicting personal commitments, courses not being offered for an
extended period and local budgetary constraints. Asked in cross-examination about his
testimony at the first hearing, Mr. Helliar replied the "ideal" state of affairs would be for new
officers to take the full range of courses as he had described, but that was and not "reality".
[sic]
Arbitrator Brown found that Mr. Helliar played down the value and importance ofthe one-hundred level
courses in comparison to his evidence at the first arbitration. That is, in my view, indisputable evidence
that counsel pursued the issue of the value of the one-hundred level courses with Mr. Hilliar, precisely
what Mr. Bouchard complains he should have done again in the course of the union's case.
40. Ultimately the arbitrator accepted the legal proposition put forward by counsel for OPSEU,
that the grievance could succeed if mandatory or even the available but non-mandatory training would
have enabled the grievor to perform the duties of the job. It was still of course necessary to establish that
the available and mandatory course would place Mr. Bouchard in a position where he could fully perform
the job.
41. Obviously counsel needed to know what non-mandatory courses the twelve candidates had
taken. Again, he sought a production order and again the results were not helpful. Of the 13 one-hundred
level courses, four employees took none of them, two took one, four took two, and two (Messrs. Kentish
and Anderson) took three of them.
42. At this point, Mr. Bouchard wanted counsel to call evidence with respect to the one-hundred
series courses. He suggested that this evidence might be adduced from those who took the courses (i.e.
the twelve successful candidates) or by recalling Messrs. Paterson or Helliar as union witnesses to seek to
elicit their opinion that taking the non-mandatory courses would have been sufficient to remedy Mr.
Bouchard's deficiencies. Counsel chose not to do so.
43. Not to call Messrs. Helliar and Paterson was clearly the correct decision. It seems to me
unlikely that the arbitrator would have permitted him to call them for the purposes of asking them
questions about an area he had at least touched on in cross-examination. Even assuming the arbitrator did
so, they would have been his witnesses and he would have been unable to cross-examine them. To expect
to elicit favourable opinion evidence from the two witnesses whom the employer had put forward to
establish the proposition that Mr. Bouchard could not do the job, without the advantage of cross-
examination, would have been foolishly optimistic.
44. However, he might have called one of the two officers who had taken three courses (Messrs.
Kentish or Anderson). Perhaps he might also have thought to seek production before the employer's case
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.
began so that he could have cross-examined the employer witnesses more thoroughly on the issue of the
content and value ofthe one-hundred series courses. Perhaps he concluded the risks were too great.
45. It is difficult to assess the likelihood of success of any particular alternative strategy. Mr.
Paterson had already described the one-hundred series courses as "basic" and "low level". Only one of
the courses taken by Mr. Kentish appears from its title to relate to an area in which Mr. Bouchard had
already been found to be deficient, namely "sampling in the environment".
46. The fact is that counsel did not pursue it. Mr. Bouchard points to this as a set of facts that
could lead the Board to conclude that counsel, on OPSEU's instructions, deliberately sabotaged the
grievance. There may be many explanations for why he chose the course he did, but a desire to sabotage
the grievance cannot logically be one of them. It appears that he pinned his hopes on the mandatory
training programs, and when he did not succeed in cross-examination, sought an alternative factual basis,
which did not look at all likely to make the case better and would perhaps make the case worse. Perhaps
he made an error, particularly in not asking fOr production before Mr. Paterson or Mr. Helliar took the
stand. Perhaps not: criticism of a lawyer's tactical decisions are easier to make after one has read the
award than before the case begins.
47. However, I cannot conclude that these facts could support a conclusion that OPSEU and
counsel chose deliberately to adopt a course of conduct to ensure the grievance was dismissed. It must be
remembered that the production orders sought by counsel did not address facts that were inevitably part
of the case, or that were clearly part of the case from the beginning. That is, had he not sought them out,
he would have simply been left with the argument that the evidence on cross-examination should
persuade the arbitrator to find Mr. Bouchard could have remedied his deficiencies by taking the
mandatory training course. Obviously counsel concluded that the argument could fail (although that
would have been a convenient place to stop if one were determined to ensure the grievance's defeat). So
he went further. When he did so, he found evidence that was of very little value (the non-mandatory
courses) or actually harmed the case for Mr. Bouchard (the qualifications of the other twelve successful
applicants). Whatever one's assessment of the evidence, to seek production of the additional material was
the act of counsel seeking to bolster a weak case rather than seeking to sabotage a good one.
48. Thus, in looking at the decision counsel made not to pursue more evidence about the content
of the non-mandatory training courses, it is not possible to describe this as a decision made about not
pursuing an obvious course of evidence. Indeed, raising the issue of the non-mandatory training courses
was not the original focus of the grievance and carried with it its own risks. Objectively, one can say that
the evidence was weak and more likely to hurt Mr. Bouchard's case than to help it if pursued. Whatever
conclusions counsel came to or whatever his motivation was, he cannot have been motivated by desire to
sabotage the grievance by not pursuing that evidence.
49. It is true that people often do improper acts which, in hindsight, could have been disguised
more cleverly. The facts in many cases where employees are discharged for theft demonstrates that with
admirable clarity. However, the conduct of a six-day case was not a matter that was done without some
considerable thought and strategy. The only explanation for raising the issue of the non-mandatory
training courses was an attempt to bolster a weak case, regardless of whether it might have been stronger
had counsel pursued a different approach to the case. Seeking further evidence about non-mandatory
training courses cannot be seen as part of a strategy to undermine the case, and indeed Mr. Bouchard does
not suggest that it was. Failing to pursue evidence that did not turn out to be particularly helpful or
promising, in the context of a pursuit of a second line of argument, cannot possibly be seen as evidence
leading to a conclusion that counsel and OPSEU sought to sabotage Mr. Bouchard's case.
50. It is also important to note that Mr. Bouchard, through his counsel, does not suggest that
there was any other evidence or any other witness to be called to address these evidentiary issues. He
simply says that counsel failed to seek favourable opinion evidence from the employer's witnesses and
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failed to call some or all of the twelve successful candidates, none of whose evidence appeared likely to
have been helpful. Had counsel not taken the step of pursuing the issue of non-mandatory training
courses, none ofMr. Bouchard's complaints would exist.
51. There is therefore no fact alleged in the application of any act by OPSEU or its counsel that
could sustain a conclusion that OPSEU or its counsel took any step designed to undermine the chance of
success of Mr. Bouchard's grievance. It may be possible in hindsight to quarrel with counsel's tactics
(though I would not be inclined to do so), but there is nothing that could possibly lead to a conclusion of
bad faith or arbitrariness as Mr. Bouchard alleges. There are therefore no facts pleaded that, even if all
are proven to be true, that could make out a case for a finding of a violation of section 74.
52. This application is therefore dismissed.
"David A. McKee"
for the
Board
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