HomeMy WebLinkAboutP-2002-0003.Chyczji.08-09-08 Decision
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P-2002-0003
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Ron Chyczij Grievor
- and -
The Crown in Right of Ontario
(Ministry of Labour)
Employer
BEFORE Kathleen O?NeilVice-Chair
FOR THE GRIEVORRon Chyczij
Alexandra Chyczij
FOR THE EMPLOYERRyan Conacher
Counsel
Ministry of Government Services
HEARING July 11 and 14, 2008.
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INTERIM DECISION
This decision deals with the employer?s motion for the dismissal of a portion of Mr. Chyczij?s
grievance, which contests the denial of a request for tuition assistance, on the basis of issue
estoppel and foreclosure by the terms of previous settlements of grievances. The grievor resists
the motion on its merits, and because he says it is untimely.
The employer?s argument on issue estoppel is based on a decision of a Review Officer at the Pay
Equity Commission concerning a reprisal complaint filed by the grievor with that body. It is the
employer?s position that the decision dated April 22, 2003 determines a number of issues in this
matter so that this Board should not make fresh determinations on them. In the alternative, the
employer argues that it would be more appropriate to refer the matter back to the Pay equity
Hearings Tribunal for final determination and that the settlements of two prior grievances
preclude further litigation of the issues settled.
For ease of reference the portions of the Pay Equity Act referred to in evidence and argument are
appended to this decision.
Factual Background
The grievor acted as spokesperson for an anonymous group of Review Officers who challenged
the government?s pay equity plan in 1995, which was before the Pay Equity Hearings Tribunal
for six years. A settlement was obtained in November 2001 after mediation with Mr. Gerry Lee,
a former Review Officer, who was engaged on a contractual basis for the purpose, as it involved
internal complaints.
In December 2001, not long after the settlement of the group pay equity complaint, this
grievance was filed with the employer and was referred to this Board on January 7, 2003.
Hearing dates set for January, June and November, 2003 were adjourned on consent. The first
date on which a hearing proceeded was January 25, 2005. To date, twenty-one days of hearing
have been held and several interim decisions have been issued along the way as to jurisdiction,
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disclosure, particulars and procedural issues. Three successive counsel have handled the matter
for the employer. The first time in this hearing that either party mentioned the grievor?s personal
reprisal complaint before the Pay Equity Commission or the Notice of Decision dated April 22,
2003 was on May 2, 2008, five years after its issuance, when it was put to the grievor in cross-
examination. At that time, current counsel indicated he had just become aware of the document
and wished to bring a motion concerning its effect. The Board invited submissions from the
grievor on when the motion should be heard. At the outset of the next hearing date, May 13,
2008, and prior to closing his case later that day, Mr. Chyczij agreed that rather than waiting
until the conclusion of the case, the motion should be heard. The motion was then set down for a
separate date, and heard on July 11 and 14, 2008, during which the parties presented evidence
and argument on the motion.
In June 2002, about six months after filing this grievance, Mr. Chyczij had filed the personal
complaint under s. 9(2) of the Pay Equity Act, that lead to the 2003 Review Officer decision. In
that complaint he claimed that he had been treated unfairly at work because of his previous
involvement with proceedings under that Act. Since the matter involved an internal
complainant, Bev Rosser, Manager of the Pay Equity Office, once again engaged Mr. Lee on a
contractual basis to act as Review Officer to do the investigation normally done by the employee
Review Officers. Mr. Chyczij raised an objection to the appointment of Mr. Lee for this
purpose, as he was, and remains, of the view that Mr. Lee was in a position of conflict of interest
in regards to investigating his complaint, on the basis that the Pay Equity Office was one of the
parties, and had hired and paid him. Mr. Chyczij asserts that Mr. Lee would have been biased in
favour of the employer because of his hope for future contracts or references from them.
Further, he was concerned that, although Mr. Lee had not worked for the Commission for about
ten years when he wrote the decision, he knew all the people involved on both sides from his
employment and previous dealings with them. He was of the view that all the circumstances,
including that the employer would not negotiate the terms of the appointment of the Review
Officer with him, meant that there was not a sufficient arms? length relationship between Mr.
Lee and the parties.
In his thirteen page ?Notice of Decision? dated April 22, 2003, Mr. Lee deals with and rejects the
allegation of bias and conflict of interest made by the grievor against him, as well as the reprisal
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allegations which were the substance of the complaint, and sets out the facts and reasons
underpinning his decision.
Two of the three examples of differential treatment alleged to comprise a violation of the Pay
Equity Act in that the complaint had already been grieved and settled by the time of Mr. Lee?s
decision. These were an allegation that the grievor had not been promoted to Manager, Pay
Equity in July/August 2000, and that he was not permitted to carry-over unused vacation credits
from 2001 to 2002. The employer took the position that Mr. Chyczij?s inclusion of those matters
in the reprisal complaint was foreclosed by the settlements, as it does in these proceedings.
Relying on jurisprudence from the Pay Equity Hearings Tribunal concerning situations where
proceedings under the Pay Equity Act were not mentioned in a release clause, and the fact that
the grievor was alleging a pattern of behaviour, Mr. Lee decided to consider those matters on
their merits independent of the settlement.
Prior to issuing his notice of decision, Mr. Lee made Ms. Rosser aware of the allegation of
conflict of interest. When asked by the grievor in cross-examination what her response had
been, she said that the focus in their discussions was that Mr. Lee would have to make a decision
on the issue. She acknowledged that she reviews the decisions of Review Officers before they
are released, but said that she only gives process guidance, and that, like any other Review
Officer, she would not tell them how to conduct the investigation. As to the decisions, her
regular role was to ensure they were legally correct, and could be easily understood by the
parties. In the case of the decision Mr. Lee issued in Mr. Chyczij?s case, she knew she had made
no corrections, and had no memory of seeing it before it was issued. Normally, the Pay Equity
Office staff physically prepares the decisions, but not on that occasion. Further, Mr. Lee made
no mention of what the likely outcome was before he wrote up his decision. Ms. Rosser could
not recall what, if any disclosure Mr. Lee had asked for, but said she would have provided
disclosure if requested. She was not sure whether Mr. Lee had investigated whether Mr. Chyczij
was the only one to have his vacation cancelled, and Mr. Lee does not mention the point in his
decision. She would have explained her decision, and did not recall exactly what she said to Mr.
Lee.
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Ms. Rosser said that although the Statutory Powers and Procedures Act does not apply by
statute, the Review Officer process is run, as a matter of policy, as if it were. Further, although
she said there is no reverse onus applying to Review Officers explicitly in section 9(2) of the act,
they operate on that basis. Mr. Chyczij is of the view that the reverse onus does not apply until a
complaint is before the Hearings Tribunal.
Subsection 34(4) of the The Pay Equity Act provides that a Review Officer need not hold a
hearing prior to making an order, and Mr. Lee did not conduct a hearing before issuing his
Notice of Decision, nor take evidence under oath. Rather, he separately interviewed people,
including Ms. Rosser and Mr. Chyczij.
With those facts in mind, we turn to the employer?s motion, starting with the grievor?s
submission that it should be dismissed on the basis that it has been brought too late in this
process.
I. is the Motion Untimely?
The grievor maintains that the employer?s motion is untimely, as it should have been brought
at the outset of the case along with the other preliminary motions brought by previous
counsel, rather than after he had closed his case. The grievor points out that the allegations of
differential treatment concerning the vacation carry over and job competition issues were part
of the particulars he filed in 2005, and that he has already given his evidence, including facts
related to these issues and the settlement of the grievances. It is the grievor?s position that it
is now too late in the case for the employer to be trying to narrow the issues.
Further, the grievor asserted that he had tried to object to the admission of the decision of the
Review Officer, but that the ruling had been that he had not objected to it in a timely manner.
Thus, the grievor argues it would not be fair to allow the employer?s motion at this stage of
the proceedings. Further, the grievor characterizes the motion as an attempt to apply a rule on
a retroactive basis, which would amount to a denial of natural justice. He states that if he had
known of the objection earlier, that he might have introduced other evidence or sought to
amend his particulars.
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The employer responds that it is trying to reduce the length of an already protracted hearing,
and refers to the Grievance Settlement Board?s decision OPSEU (Latimer) and the Crown in
Right of Ontario (Ministry of the Solicitor General and Correctional Services)
#0131/95,0132/95, 2132/95, dated June 22, 1999 where the Board referred to the timing of a
motion concerning the scope of the evidence to be ?fortunate? where it was brought prior to
the commencement of the employer?s case.
Having considered all the submissions and evidence on this motion, and although it would have
been preferable if this motion had been brought earlier, and the situation thus been clarified
earlier, I find it appropriate to entertain the motion on its merits. The grievor had notice of this
motion prior to closing his case in chief, and did not seek leave to introduce further evidence.
Nor did he give any indication of what other evidence could have been brought or amendment to
his particulars that could have been required in response to the narrowing of issues sought by the
motion. If it had been an expansion of the issues which was sought, it might have been another
matter. Nonetheless, he will still have the right to bring reply evidence in response to any
element of the employer?s case that he could not have anticipated in his case in chief. In the
circumstances, it is the Board?s view that the grievor will not be prejudiced by the hearing of this
motion.
As to the grievor?s remarks about the admission of the decision of the Review Officer into
evidence, there was no ruling on that matter as the grievor did not press an objection to its
admission. In any event, as a published decision, it could be referred to in argument without
being proven in evidence. Further, even if there had been a ruling, it would not have constituted
a precedent on the question of whether the Board, which has the right to control its own
procedure, should hear a motion on the points of law the employer wishes to argue. What
evidence is admitted, and what use is made of it when the law is applied to it, are two different
matters.
Further, it is not a denial of natural justice or a retroactive application of a rule for the Board to
rule on a motion, of which there was ample notice, after hearing the parties? evidence and
argument.
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Moreover, the motion involves principles of issue estoppel and the importance of settlements that
are very important to the Board?s process, and all litigants who come before it, including the
grievor. Given the length of this hearing to date, and the purpose of the motion, which is to
keep
the employer?s case to issues which are necessary to respond to, there is no sufficient reason not
to entertain the motion. It is not too late for the employer to seek direction as to the scope of the
issues to which it must respond, or too early for the Board to rule on the legal points involved.
II. Issue Estoppel
Issue estoppel is a longstanding feature of the law, which is meant to prevent a party from having
to repeatedly engage in litigation of the same issues in different proceedings. Both parties cited
the decision of the Ontario Court of Appeal in Rasanen vs. Rosemount Instruments Ltd. [1994]
17 O.R. (3d) 267, (application for leave to appeal to the Supreme Court of Canada dismissed
September 1, 1994), as the source of the applicable test for deciding whether a prior decision in a
different forum should prevent an issue being dealt with in a subsequent proceeding. The three
questions that need to be answered in the affirmative for the doctrine to apply are:
1. Has the same question been previously decided?
2. Was the previous judicial decision on the issue final?
3. Were the parties in the two decisions the same?
This Board has adopted those tests in G. Morrison and the Crown in Right of Ontario (Human
Rights Commission)) #P/0037/95, and the arguments of the parties will be discussed in answer to
them below.
1.Did the Review Officer Decision Answer the Same Question?
The employer argues that three allegations made by the grievor in this grievance proceeding
were already decided by the Review Officer in 2003 in the context of his complaint under s. 9(2)
of the Pay Equity Act.. These are first, whether the employer?s failure to pay the tuition
assistance sought was a reprisal for the grievor?s activities related to enforcing the Pay Equity
Act in relation to the Review Officers themselves, and further, whether the employer?s treatment
of the grievor in regards to his vacation credits and in a job competition show a pattern of bias
against him. The employer relies on the fact that all three of these were addressed in the Review
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Officer?s Notice of Decision, and were found to be unsubstantiated. Further, the three elements
alleged were found not to constitute a pattern of differential treatment toward the applicant
because of his involvement in a protected activity.
However, both parties acknowledge that there are additional issues raised in the grievance that
were not covered in the Review Officer decision. For instance, the grievance involves the
additional allegation that the failure to pay tuition was not in compliance with policy. Thus, the
employer is not seeking the dismissal of the grievance in its entirety.
I am satisfied that the incidents complained of in several of the allegations set out in the grievor?s
particulars related to this grievance are the same as ones dealt with in the proceeding before the
Review Officer. The grievor did not really suggest otherwise as a factual matter. Rather, he
argued that the statutory framework of a complaint under s. 9(2) of the Pay Equity Act and
differences in jurisdiction or practice as to remedy between the Pay Equity Commission and the
Pay Equity Hearings Tribunal as compared to a grievance before the Public Service Grievance
Board should lead to a finding that the same question was not being addressed.
In the alternative, he argued that even if it were decided that the same question was at issue, he
had the right to determine which venue to pursue. Further, this grievance was filed prior to the
complaint under the Pay Equity Act. Moreover, the grievor is of the view that it is necessary to
consider the whole sequence of events to understand the present grievance.
TheRasanen decision makes clear that the precise formulation of the question, or the fact that
the question arises under a different statute or process is not determinative of the issue of
whether the same question was being determined. In the case before me, the question as to
whether the employer?s actions in regards to tuition assistance, a job competition and treatment
of vacation credits was improperly motivated in response to the grievor?s protected activity
under the Pay Equity Act are questions also raised in the particulars filed before this Board.
Further, they were a necessary and fundamental part of the Review Officer?s decision, rather
than a side issue which did not need to be decided. Therefore, I find that the first criterion in
Rasanen has been satisfied.
2. Was the Review Officer?s decision a final judicial decision?
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This criterion requires two elements, that the prior decision be final and judicial.
i)Was the decision final?
InRasanen, the majority of the Court had no hesitation in finding that the Referee under The
Employment Standards Act whose decisions was being considered had rendered a final decision
because that statute provided that the referee?s decisions were final and binding. Similarly,
answering the question of whether the Review Officer?s decision is final starts with the statute
which gives such officers their powers, and describes their role in the statutory scheme of the
Pay Equity Act.
The statute provides that two principal types of matters are to be dealt with by Review Officers.
The first deals with the establishment or amendment of a pay equity plan, and is dealt with in s.
16(1) of the Act. It provides that a review officer will investigate a notice of objection and
endeavor to effect a settlement. Failing settlement, the officer is directed to decide all
outstanding matters by order. This is not the role the Review Officer was playing in dealing with
the grievor?s complaint. Nonetheless, the Review Officer?s mandate to decide all outstanding
matters by order for this type of matter is usefully contrasted with the provisions relating to
complaints, which is what the Review Officer was dealing with in the grievor?s case, which does
not contain such a direction.
Sections 23 and 24 provide that, when investigating complaints, the officer shall investigate and
endeavour to effect a settlement. As a result of the investigation, the Officer has the option to
decide that the complaint should not be considered if it falls outside the jurisdiction of the
Commission or is trivial, frivolous, vexatious, or made in bad faith. Further, if a contravention of
the Act is found, the Review Officer is entitled to make an order to effect compliance, as set out
in sections 24 (3). However, where no contravention has been found, as in the grievor?s case,
the statute simply provides that the parties are to be notified that a settlement cannot be
effected and that he or she will not be making an order under subsection 24 (3).
In the decision on the grievor?s complaint, the Review Officer took the route set out in section
23(2) in that he did not make an order under s. 24 (3), and had not effected a settlement of the
matter. He expressed this in the final paragraph of his ?Notice of Decision? as follows:
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Pursuant to subsection 23(2) of the Act, I am notifying the parties and the Pay Equity
Hearings Tribunal that I have found no contravention of the Act and that I will not be
making an Order under subsection 24(3) of the Act.
Earlier in the decision the Review Officer made clear that if the complainant was unhappy with
any aspect of his decision, he could have a hearing de novo at the Pay Equity Hearings Tribunal.
In fact, s. 25 (1) (a) of the Pay Equity Act provides that the Hearings Tribunal shall hold a
hearing in the circumstances where the Review Officer is unable to effect a settlement of a
complaint and has not made an order under subsection 24 (3). Nonetheless, the grievor?s
complaint did not proceed on to the Pay Equity Hearings Tribunal, as it could have.
Employer counsel submitted that when the grievor chose not to pursue a hearing at the Pay
Equity Hearings Tribunal, the Review Officer?s decision became final. By contrast, the grievor
says he chose to pursue a remedy before the Public Service Grievance Board instead. The
employer characterizes this as forum shopping, and asserts that the grievor had already chosen
the Pay Equity Commission and received a decision which should be found to be binding on
him, and the employer should not have to relitigate the matter. The grievor?s position is that the
Review Officer process was more akin to a grievance procedure than litigation, and that in any
event he had started this grievance proceeding prior to the pay equity complaint process.
If the matter had proceeded to the Pay Equity Hearings Tribunal and they had issued a decision,
it would clearly have been final, given the provisions of subsection 30(1) as follows:
30. (1) The Hearings Tribunal has exclusive jurisdiction to exercise the powers
conferred upon it by or under this Act and to determine all questions of fact or law that
arise in any matter before it and the action or decision of the Hearings Tribunal thereon
is final and conclusive for all purposes.
It is the grievor?s position that the fact that no similar provision is provided in regards to the
Review Officer?s decisions, that the finality required for issue estoppel to apply has not been
shown.
Given the provisions of s. 25(1) of the Pay Equity Act, it would appear that in the case of a
finding such as the one made in this case, i.e. that no settlement had been effected, and no order
was to be made under s. 24(3), it was the intention of the drafters of the statute that such
a case
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would proceed to a hearing before the Pay Equity Hearings Tribunal. This is a strong indication,
at least in the circumstances of a complaint of a breach of the Act, where the Review Officer has
made no order, that the Review Officer investigation was not to be the final step in the
determination of the issue. There is no evidence, statutory provision or authority before me
which persuades me that the fact that the grievor did not pursue a hearing on the matter before
the Pay Equity Hearings Tribunal necessarily turns the Notice of Decision into a final decision, if
it is not otherwise final. Although it contains factual and legal conclusions, the decision makes
no order one way or the other. Although there was a conclusion that no violation of the statute
had been shown, the complaint was not dismissed, and there was no suggestion in argument that
the Review Officer had the authority to dismiss the complaint. As well, the Review Officer?s
?Notice of Decision? contains an explicit acknowledgment that his process was subject to a de
novo hearing before the Hearings Tribunal. The statutory statement of finality applies only to
the Pay Equity Hearings Tribunal, and not the Review Officer?s notice of the result of his
findings and determination that no order would follow. As a result, there is not the clarity of a
final decision in this matter that the Court had in Rasanen. In sum, I am not persuaded in the
circumstances that this element of the criteria set out therein has been sufficiently established.
With that said, I would like to underline that the facts of this case do not involve an order made
by a Review Officer, and thus this decision should not be taken as any comment about Review
Officer orders. The question of whether the provisions of The Pay Equity Act concerning orders
could, in the facts of some other case, result in a conclusion that an order was a final decision, if
it was not challenged at the Pay Equity Hearings Tribunal, is a question that does not arise here
and thus does not need to be answered.
ii. Was the decision a judicial one?
The broad formulation set out in Rasanen of what is necessary to meet the spirit of the test of a
judicial proceeding is that the process be designed to be an ?independent, fair, impartial and
binding adjudicative process.? It was not suggested that the Review Officer process was not
designed to be independent, fair and impartial. The issues raised by the grievor in this case were
whether the decision was binding, whether the Review Officer process should be seen as an
administrative tribunal when it is the Pay Equity Hearings Tribunal that holds hearings in the
usual sense of an administrative tribunal hearing, and whether the process was in fact impartial,
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given that the grievor maintains the concerns which he expressed in the bias and conflict of
interest allegations he made against the Review Officer in the proceedings at the Pay Equity
Commission. However, given the finding above on the question of finality, it is not necessary to
decide any additional issues as to issue estoppel, including whether alleged defects in the process
at the Pay Equity Commission render the process non-judicial and whether the parties were the
same.
Employer counsel also argued in the alternative that it would be more appropriate to refer these
matters back to the Pay Equity Hearings Tribunal for a determination. Whatever might have
been the merits of such a proposal if it had been made during the early stages of this proceeding,
it is not appropriate after the many days of hearing that have already been held in this matter, and
at a point where the grievor has closed his case. In terms of the desirable goal of avoiding
relitigation, it would now be counterproductive.
III. What is the effect of the settled grievances?
The employer argued that, in the event issue estoppel was not found to apply, that the
settlements entered into by the grievor resolving two prior grievances should prevent any
further evidence about them being lead in this matter, and that previously admitted evidence
concerning them should be struck.
In July and November 2002 Mr. Chyczij and the employer entered into two memoranda of
settlement putting an end to the grievor?s grievance dealing with vacation carry-over and two
grievances dealing with the competition for the position of Manager, Pay Equity respectively.
In the July settlement, the release clause reads as follows:
This memorandum of settlement constitutes full and final settlement of any and all
matters which were or could properly have been raised in the grievance.
In the November settlement, the release was worded this way:
In consideration for the foregoing Mr. Chyczij agrees that the terms of this Settlement
satisfy all claims arising out of the foregoing grievances and hereby releases and
forever discharges the Crown in Right of Ontario and the Employer, its servants,
agents, directors, commissioner, and managers from all actions, causes of action ,
claims, complaints and demands of every nature and kind arising out of or as a result
of or in any way relating to the grievances as referenced in this settlement.
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The grievor maintains that these release clauses should not preclude his reliance on what he
alleges was differential treatment concerning the vacation carry over and job competition
issues because they form part of the particulars he filed in 2005, and that his evidence
included facts related to these issues and the settlement of the actions. The grievor repeated
his allegation that the employer was reacting to his role as spokesperson in what turned out to
be an expensive settlement when it denied him the management job he was applying for
shortly after he had turned down a settlement offer for the pay equity complaint. He submits
that they had become aware that the settlement would cost them more than they thought
during the same period as he unsuccessfully applied for the management job. When he did
not get the job, he grieved that, and then shortly after he grieved the treatment of his vacation
credits. All of these legal processes involved his manager and he has concluded that his
activities were not pleasing his supervisors.
Given the above circumstances, I am invited to allow the grievor to pursue the issues relating
to the incidents grieved despite the settlements because the objection is brought too late, and
there should be an exception from the usual jurisprudence because the incidents are part of a
pattern. In the grievor?s submission, ?something is going on here?, so that one part cannot be
divided off from the other. It is a cumulative course of action, so that it is hard to exclude any
part of it. Referring to the Latimercase, cited above, the grievor urges the Board to similarly
consider the matter a continuous course of action. In that case, the Board consolidated
grievances that had arisen subsequent to the one under consideration, but before the employer
had started its case, as the underlying facts were part of a continuous sequence of events.
There had been no settlement of any of the issues; it was a question of the appropriateness of
consolidating grievances midway through a hearing.
The grievor does not argue that the settlement terms were illegal, that he was under duress or
any other extraordinary circumstance that would mean that the settlement should not be
enforced. Rather, he argues that because he alleges a pattern, these incidents should not be
excluded, and relies on the Latimercase, cited above. There is nothing in that decision or in
the law of which I am aware concerning settlements generally which stands for the
proposition that allegations of a pattern of conduct form a recognized exception to the
enforcement of settlements.
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The Board has found on many occasions, that absent duress, which is not alleged, or some other
circumstance that would justify not enforcing clearly worded settlements, it is the Board?s duty
to enforce them, rather than to re-open matters covered by them. As the Board wrote in De Boer
and the Crown in Right of Ontario (Ministryof Community Safety and Correctional Services)
(O?Neil) PSGB #P-2005-1033 at pg. 10:
It is very important as a matter of policy that agreements voluntarily signed be upheld, or
workplace parties would not be able to have confidence in the finality of agreements made
and their ability to govern their affairs accordingly. The question of finality of agreements
is fundamental to the entire legal system, and is especially important in the ongoing
operation of any workplace. Otherwise, parties would be constantly wondering which
agreement they could count on, and which one would be subject to being reconsidered
indefinitely in the future.
The two settlements from July and November 2002 were final settlements of grievances
related to vacation credits and the job competition for Manager of Pay Equity respectively.
The first settlement was admitted as part of the grievor?s case, over the objection of a previous
employer counsel, as arguably relevant to the grievor?s case on reprisal, and in light of the
fact that there is no non-disclosure clause within its terms. The second settlement, which
similarly contains no confidentiality or non-disclosure clause, was introduced without
objection as part of the grievor?s case. I see no reason to strike any of the evidence given in
the grievor?s case about the settlements. At the very least, they are part of the narrative that
explains the context of the grievor?s allegations as to the employer?s motivation for denying
his tuition assistance request. I agree with the grievor?s submission that it is too late to object
to evidence that has already been submitted without objection. Nor do I find it appropriate to
prohibit all further evidence about the fact of the settlements or the employer?s reactions to
them to the extent that it is relevant to the remaining reprisal allegations. As found in
OPSEU (Fletcher) and the Crown in Right of Ontario (Ministry of Community Safety and
Correctional Services) dated June 22, 1999, evidence of events after a grievance are not
precluded by a settlement.
What is foreclosed by the settlements is any further dispute concerning the facts put in issue
by the settled grievances, or remedy for those facts. For example, the grievor?s contention
that the vacation credit grievance shows that he was the only person to whom management
applied a selective policy is an argument which is covered by the settlement which precludes
15
any matters that were, or could have been, raised in that grievance. Further, the settlements
preclude any remedy for the facts of the incidents grieved and settled, whether separately or
as part of a pattern of unfair treatment against the grievor. The settlements contained no
finding or admission of wrongdoing, and were both explicitly without prejudice or precedent.
In terms of narrowing the issues to which the employer must respond, which was the purpose
of the employer?s motion, it is unnecessary to present any defense of the incidents grieved and
settled in the two 2002 settlements. The main relevance of the settlements to the grievor?s
case on tuition assistance, as expressed in his own submissions, is in relation to the timing of
the grievance activity and settlements. The grievor?s general allegation is that his activity in
acting on behalf of Review Officers in a Pay Equity complaint, competing against managers
for promotion and in filing grievances against the employer, was not making him popular with
his managers, and that this was an improper part of the employer?s motivation in denying him
tuition assistance. That part of this grievance is not precluded by the settlements.
***
n the result, I have determined that the second criterion for the application of the principle of
I
issue estoppel, finality, has not been established, and that in the result, this is not an appropriate
case in which to apply it. Further, the grievor is precluded by the settlement of two prior
grievances from re-litigating their underlying facts and from receiving any remedy for those
matters. Nonetheless, evidence subsequent to those grievances may be relied on, if otherwise
relevant to the remaining issues in dispute between the parties.
Employer counsel undertook to notify the grievor of what witnesses he intends to call on the
resumption of this matter within fourteen days of the ruling on this motion, which would be
September 22, 2008. The hearing is scheduled to resume on September 30.
th
Dated at Toronto this 8 day of September, 2008
_____________________________
Kathleen G. O?Neil, Vice-Chair
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Appendix
Excerpts from the Pay Equity Actreferred to in evidence and argument:
9 (2)
No employer, employee or bargaining agent and no one acting on
behalf of an employer, employee or bargaining agent shall intimidate,
coerce or penalize, or discriminate against, a person,
(a) because the person may participate, or is participating, in a
proceeding under this Act;
(b) because the person has made, or may make, a disclosure required
in a proceeding under this Act;
(c) because the person is exercising, or may exercise, any right under
this Act; or
(d) because the person has acted or may act in compliance with this
Act, the regulations or an order made under this Act or has
sought or may seek the enforcement of this Act, the regulations
or an order made under this Act.
16. (1) If the Commission,
(a) is advised by an employer or a bargaining agent that no agreement
has been reached on a pay equity plan or an amendment to a pay
equity plan; or
(b) receives a notice of objection to a pay equity plan for employees
who are not represented by a bargaining agent or a notice of objection
to an amendment of such a plan, a review officer shall investigate the
matter and endeavour to effect a settlement. R.S.O. 1990, c. P.7, s. 16
(1); 1993, c. 4, s. 11.
Orders by review officer
(2) If the review officer is unable to effect a settlement as provided for
in subsection (1), he or she shall by order decide all outstanding
matters.
Investigation of complaints
23. (1) Subject to subsection (2), when the Commission receives a
complaint, a review officer shall investigate the complaint and may
endeavour to effect a settlement.
Idem
(2) The review officer shall notify the parties and the Hearings Tribunal as soon as he
or she decides that a settlement cannot be effected and that he or she will not be
making an order under subsection 24 (3).
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Decision to not deal with complaint
(3) A review officer may decide that a complaint should not be considered
if the review officer is of the opinion that,
(a) the subject-matter of the complaint is trivial, frivolous, vexatious or
made in bad faith; or
(b) the complaint is not within the jurisdiction of the Commission.
Hearing before Tribunal
view officer shall notify the complainant of his or her decision
(4) The re
under subsection (3) and the complainant may request a hearing before
the Hearings Tribunal with respect to the decision. R.S.O. 1990, c. P.7,
s. 23.
Orders by review officers
24. (1) Where a review officer is of the opinion that a pay equity plan is not
being prepared as required by Part II or III.1, the review officer may
order the employer and the bargaining agent, if any, to take such steps as
are set out in the order to prepare the plan. R.S.O. 1990, c. P.7, s. 24 (1);
1993, c. 4, s. 14 (1); 1996, c. 1, Sched. J, s. 5 (1).
Idem
(2) Where a review officer is of the opinion that a pay equity plan is not
being implemented according to its terms, the review officer may order
the employer to take such steps as are set out in the order to implement
the plan. R.S.O. 1990, c. P.7, s. 24 (2).
Same
(2.1) If a review officer is of the opinion that because of changed
circumstances a pay equity plan is no longer appropriate, the officer may
order the employer to amend the plan in such manner as is set out in the
order or to take such steps with a view to amending the plan as are set
out in the order. 1993, c. 4, s. 14 (2).
Same
(3) If a review officer is of the opinion that there has been a contravention
of this Act by an employer, employee or bargaining agent, the officer
may order the employer, employee or bargaining agent to take such
steps to comply with the Act as are set out in the order. 1993, c. 4, s. 14
(3).
?.
25. (1) The Hearings Tribunal shall hold a hearing,
(a) if a review officer is unable to effect a settlement of a complaint and
has not made an order under subsection 24 (3);
18
(b) if a request for a hearing, as described in subsection 23 (4) or 24 (6),
is received by the Hearings Tribunal; or
(c) if a review officer refers a matter to the Hearings Tribunal under
subsection 24 (5). R.S.O. 1990, c. P.7, s. 25 (1). (5) Where an
employer or a bargaining agent fails to comply with an order under this
section, a review officer may refer the matter to the Hearings Tribunal.
R.S.O. 1990, c. P.7, s. 24 (5).
Same
(5.1) The Pay Equity Office shall be deemed to be the applicant for a
reference under subsection (5).
Same
(5.2) On a reference under subsection (5), the Hearings Tribunal shall not
consider the merits of the order that is the subject of the reference.
Burden of proving compliance
(5.3) On a reference under subsection (5), the person against whom the
order was made has the burden of proving that he, she or it has
complied with the order. 1993, c. 4, s. 14 (5).
Hearing before Tribunal
(6) An employer or bargaining agent named in an order under this section
may request a hearing before the Hearings Tribunal with respect to the
order, and, where the order was made following a complaint but the
complaint has not been settled, the complainant may also request a
hearing. R.S.O. 1990, c. P.7, s. 24 (6).
30. (1) The Hearings Tribunal has exclusive jurisdiction to exercise the powers
conferred upon it by or under this Act and to determine all questions of
fact or law that arise in any matter before it and the action or decision of
the Hearings Tribunal thereon is final and conclusive for all purposes.
Reconsideration of decisions, etc.
(2)The Hearings Tribunal may at any time, if it considers it advisable to do
so, reconsider a decision or order made by it and vary or revoke the
decision or order. R.S.O. 1990, c. P.7, s. 30.
19
Parties to proceedings
Definition
32. (0.1) In this section,
"representative" means, in respect of a proceeding under this Act, a
person authorized under the Law Society Act to represent a person or
persons in that proceeding. 2006, c. 21, Sched. C, s. 127 (1).
Parties to proceedings
(1) Where a hearing is held before the Hearings Tribunal or where a review
officer investigates for the purposes of effecting a settlement of an
objection or complaint, the parties to the proceeding are,
(a) the employer;
(b) the objector or complainant;
(c) the bargaining agent (if the pay equity plan relates to a bargaining
unit) or the employees to whom the plan relates (if the plan does not
relate to a bargaining unit); and
(d) any other persons entitled by law to be parties. R.S.O. 1990, c. P.7, s.
32 (1); 1993, c. 4, s. 19 (1).
Review officers
34. (1) The head of the Pay Equity Office shall designate one or more
employees of the Office to be review officers.
Review officers, duties
(2) Review officers shall monitor the preparation and implementation of
pay equity plans, shall investigate objections and complaints filed with
the Commission, may attempt to effect settlements and shall take such
other action as is set out in this Act or in an order of the Hearings
Tribunal.
Powers
(3) A review officer, for the purpose of carrying out his or her duties,
(a) may enter any place at any reasonable time;
(b) may request the production for inspection of documents or things
that may be relevant to the carrying out of the duties;
(c) upon giving a receipt therefor, may remove from a place documents
or things produced pursuant to a request under clause (b) for the
purpose of making copies or extracts and shall promptly return them to
the person who produced them;
(d) may question a person on matters that are or may be relevant to the
carrying out of the duties subject to the person?s right to have counsel or
some other representative present during the examination; and
(e) may provide in an order made under subsection 16 (2) or 24 (1) that
any job class is a female job class or a male job class.
20
Procedure
(4) The Statutory Powers Procedure Act does not apply to a review officer
and he or she is not required to hold a hearing before making an order
authorized by this Act. R.S.O. 1990, c. P.7, s.34.
?.