HomeMy WebLinkAboutNabbout 20-07-22
IN THE MATTER OF AN ARBITRATION
BETWEEN:
PEEL DISTRICT SCHOOL BOARD
and
OPSEU
BEFORE: SUSAN L. STEWART – ARBITRATOR
GRIEVANCES OF H. NABBOUT
APPEARANCES
FOR THE UNION: R. LOSTRACCO, COUNSEL
FOR THE EMPLOYER: J. VANDERMEULEN, COUNSEL
R. YOUNAN, COUNSEL
THIS MATTER PROCEEDED IN WRITING, WITH SUBMISSIONS
CONCLUDING ON JUNE 10, 2020
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AWARD
1. This award addresses the scope of my jurisdiction in connection with
two grievances that were filed on behalf of Ms. H. Nabbout. Ms. Nabbout
was employed by the Peel District School Board as an Adult Language
Instructor and at the time of the termination of her employment, on May
2, 2019, she had not yet completed the probationary period prescribed
by the Collective Agreement. The grievances allege unjust discipline and
unjust dismissal. The disciplinary grievance arises from a suspension
and is dated April 23, 2019. It alleges a breach of Article 4 (management
rights) and Article 18 (discrimination). The dismissal grievance is dated
May 10, 2019, and alleges a breach of a number of provisions of the
Collective Agreement, including Article 4 (management rights), and
Article 17, which relates to health and safety. As well, it alleges a breach
of Article 8, the grievance procedure, and the grievance makes reference
to the “no reprisals” part of that provision. The Employer has raised a
preliminary objection to my jurisdiction to determine these grievances.
This objection is based, in particular, on Article 4:02 (b) of the Collective
Agreement which provides for its authority to: “suspend with or without
pay, discharge or otherwise discipline a probationary Employee for any
reason at the sole discretion of the Board”. There is no dispute that I do
have jurisdiction to determine whether there has been a violation of the
Human Rights Code in connection with the discipline and discharge of
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Ms. Nabbout. The parties disagree, however, as to whether my
jurisdiction extends further, to allow consideration of the Union’s
allegations that the Employer conducted itself in a manner that was
arbitrary, discriminatory (on a non-Code related basis) or in bad faith. It
is the Employer’s position that I do not possess such jurisdiction while it
is the position of the Union that I do. This award deals only with this
issue.
2. The following are the relevant provisions of the Collective Agreement:
1.01 The general purpose of this Agreement is to establish and
maintain collective bargaining relations between the Board and its
Employees, represented by the Union, and to establish and
maintain matters covering working conditions and rates of pay and
to provide procedures for the prompt and equitable disposition of
grievances.
…
4.01 Save and except to the extent modified or curtailed by any
provisions of this Agreement, the right to manage and conduct the
business of the Board is vested exclusively and without limitation
with the Board and its Administration.
4.02 Without limiting the generality of the foregoing, subject only
to the specific provisions of this Agreement and the right of any
Employee to lodge a grievance under the grievance procedures
herein provided for, the Employees and the Union recognize and
accept that it is the right of the Board to:
…
b) suspend with or without pay, discharge or otherwise discipline
a non-probationary Employee for just cause, and suspend with or
without pay, discharge or otherwise discipline a probationary
Employee for any reason at the sole discretion of the Board;
…
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8.06 e) The Arbitrator shall not by the decision rendered, add to,
delete from, modify or otherwise amend the provisions of the
agreement.
…
8.08 The Arbitrator has the powers of an arbitrator under the
Ontario Labour Relations Act.
…
8.10 There shall be no reprisals of any kind taken against any
person because of participation in a grievance or complaint or
arbitration procedure under this Agreement.
…
9.01 A newly hired Employee shall be on probation and will not
have any seniority standing until he/she has worked six (6) months
within the bargaining unit, provided the Employee has worked a
minimum of six hundred (600) hours. During the probationary
period, an Employee shall be considered as being employed on a
trial basis and may be discharged at the sole discretion of the
Board. No grievance may be submitted concerning the termination
of employment, lay-off, or disciplining of a probationary Employee.
3. The statutory powers of an arbitrator referred to supra, are the
following:
48(1) Every Collective Agreement shall provide for the final
and binding settlement by arbitration, without stoppage of
work, of all differences between the parties arising from
the interpretation, application, administration or alleged
violation of the agreement, including any question as to
whether a matter is arbitrable.
4. My jurisdiction to deal with a statutory Code violation is derived from
the seminal decision of the Supreme Court of Canada in Parry Sound
(District) Social Services Administration Board v. OPSEU, Local 324,
2003 SCC 42. With respect to the issue in dispute, counsel have referred
me to the following decisions: Abitibi Consolidated Ltd. and CEP, Local
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92 (1998), 75 L.A.C. (4th) 414 (Mitchnick); Brampton Hydro-Electric
Commission v. C.A.W., Local 1285 (1993), 108 D.L.R. (4th) 168; Blue
Door Shelters and S.E.I.U., Local 1 Canada (2013), 239 L.A.C. (4th) 260
(Harris); Blue Door Shelters and SEIU, Local 1 (Randenska) (2014), 118
C.LA.S.109 (Monteith); Scarborough Hospital v CUPE, Local 1487, 2008
CarswellOnt 8801 (Levinson); Sault College and OPSEU (Stewart), [2016]
O.L.A.A. No. 418 (Knopf); Greater Essex County District School Board v.
O.S.S.T.F., District 9, 2005 CarswellOnt 10082, [2005] O.J. No. 6401;
CAW-Canada, Local 127 v. Dajcor Aluminum Ltd., 2011 CarswellOnt
15752 (Watters); Copper River Inn and UFCW, Local 175 (Flamond),
2018 CarswellOnt 7153 (Randall); Ontario (Alcohol & Gaming
Commission) v. O.P.S.E.U., 2001 CarswellOnt 6443 (Whitaker); ATU,
Local 1587 and Ontario (Metrolinx – GO Transit) (McCurdy), 2017
CarswellOnt 18131 (Abramsky).
5. The Employer emphasizes the plain language of the provisions of the
Collective Agreement. In its submission, the parties have made it
abundantly clear that the discipline or discharge of a probationary
employee can be effected at the Employer’s sole discretion and for any
reason. In this regard, it is submitted that there is no difference between
the parties as contemplated by the provisions of the Labour Relations
Act, as concluded in the Scarborough Hospital and Dajcor Aluminum
Ltd. cases. The Employer relies on the Copper River case, where, in
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considering language that provided that termination was within the “sole
discretion” of the arbitrator, it was concluded that there was no basis to
imply a duty to act reasonably, without bad faith or without
arbitrariness. The Employer notes that in Ontario Alcohol and Gaming
Commission, in interpreting language that provided both an ability to
terminate a probationary employee at its “sole discretion” for “any
reason”, the arbitrator rejected the argument that the Union is advancing
here. As well, it is noted that in the Metrolinx case, there was deference
to the specific language of the Collective Agreement in the rejection of the
submission that there was an implied duty of the kind the Union claims
exists in this case.
6. The Union relies on the Brampton and the two Blue Door decisions in
support of the proposition that an arbitrator has jurisdiction to review
the dismissal of a probationary employee on the basis that it is unfair,
discriminatory and/or in bad faith, even where, as here, the collective
agreement provides that no grievance could be submitted in relation to
the discipline or termination of a probationary employee. Moreover, Ms.
Lostracco emphasized the reference to “equitable resolution” of
grievances in Article 1.01 and the reference to “no reprisals of any kind
taken against any person because of participation in a grievance or
complaint or arbitration procedure under this Agreement” contained in
Article 8.10. The Union also made reference to the grievor’s right to a
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healthy workplace, pursuant to Article 17. Paragraph 11 of the Union’s
submissions states in part that:
It is the Union’s position that the Arbitrator has jurisdiction
to consider the grievances on the standard that the Board
exercised its right to manage in an unfair, arbitrary or
discriminatory manner, including consideration of whether
or not the Board reprised against the grievor for exercising
her rights under the Collective Agreement. The Arbitrator
also has the jurisdiction to consider any substantive
rights of the grievor under the terms of the Collective
Agreement.
With respect to the Blue Door decision of Arbitrator Harris, the Union
notes that in the context of collective agreement language that provided
for dismissal of a probationary employee at the employer’s “sole
discretion”, the arbitrator concluded that there was support for an
implied limitation on that discretion contained in Parry Sound, reasoning
as follows:
33. The Supreme Court decision does not say that only
anti-discrimination terms are implicit in Collective Agreements.
Rather, it dealt with that issue. It said nothing about whether the
Employer's discretion may not be exercised in a way that was in
bad faith, arbitrary or unfair. Those standards were not before it.
34. Central to the Supreme Court's judgment is its conclusion
that terms may be implied in a Collective Agreement in certain
circumstances. As set out above, the Supreme Court considered
the implication of such terms both as a matter of law and as a
matter of fact, the latter by way of presumed intent. For many
years the thrust of the case law has been that the exercise of a
sole discretion to discharge a probationary employee is that the
Employer is obliged not to conduct itself or act in any way that is
in bad faith, arbitrary, discriminatory or unfair. The arbitral case
law reviewed by various Courts well establishes that standard.
That case law has been reviewed many times in the cases cited
above.
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That decision goes on to refer to the 1993 Divisional Court decision in
Brampton Hydro Electric Commission, in support of the conclusion that
there are limits on the employer’s discretion. In that case, in the context
of a provision that a probationary employee may be discharged at the
employer’s “sole discretion”, the Court concluded as follows:
38. In my view, the Collective Agreement before us has an
implied term/article/clause that neither party to the agreement
shall conduct themselves or act in any way that is in bad faith,
arbitrary, discriminatory or unfair.
39. It will be said: “if the parties had intended that type of implied
article to govern their conduct, it would have been said explicitly in
the collective agreement”. It seems to me that the answer to that
argument is found in the mere asking of this rhetorical question:
“Can you imagine any party, while negotiating a collective
agreement, bargaining to include an article: the parties shall have
the right, at all times and in all circumstances, to act in bad faith
and/or in an arbitrary manner and/or in a discriminatory way?”
40. It will be recalled that Article 1.01 of the collective agreement
states in part: “Both parties recognize a duty to cooperate in good
faith individually and collectively for the advancement of these
purposes”.
41. In my view, the Arbitrator had jurisdiction to hear the
grievance. I so find whether the tests for review be “correctness” or
“patently unreasonable”. It was open to the Arbitrator to hear the
grievances alleging bad faith and to find arbitrariness on the part
of Brampton Hydro.
The Blue Door decision was followed and its reasoning endorsed in a
decision by Arbitrator Monteith, involving the same parties.
7. Subsequent to the decision in Brampton Hydro, in Greater Essex
County District School Board, the Divisional Court considered the ability
9
of parties to a collective agreement to limit the rights of probationary
employees. At paragraph 29 of that decision, the Court noted that an
arbitrator cannot amend the language of the collective agreement and
stated that:
While an arbitrator may imply language into a collective
agreement, he or she may do so only if that language is
necessary in order to give effect to the parties’ agreement
Hamilton (City) v. C.U.P.E.. Local 167 (1977), 33 O.R. (3d) 5
(Ont C.A.) at p. 10). An arbitrator can also require an
employer to exercise its management rights reasonably
in order not to negate or unduly limit other provisions in
the collective agreement (Metropolitan Toronto (Municipality)
v. C.U.P.E. (1990), 69 D.L.R. (4th) 268 (Ont. C.A.) at p. 286.
The Court went on to make reference to the fact that it was open to
collective agreement parties to limit rights of probationary employees
pursuant to “clear terms”. In the case before the Court, it was
determined that such clear terms existed and that the arbitrator could
not rely on the general language of the purpose clause, where there was
reference to a desire to maintain harmonious relationships, as a basis to
imply protection against arbitrary dismissal. The Brampton case was
distinguished on the basis of the language of the probationary clause and
the purpose clause.
8. Greater Essex was relied on in Copper River Inn, one of the authorities
referred to by the Employer. In that case, the collective agreement
provided that the dismissal of a probationary employee was “within the
sole discretion” of the employer. There is no specific reference to a
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purpose clause in the decision, however the arbitrator concluded that
there was neither a procedural nor substantive right to challenge the
dismissal. Copper River does not make reference to either of the Blue
Door decisions, a point emphasized by Ms. Lostracco. It does, however,
make reference to and rely on Sault College & OPSEU, where a similar
result was reached. The collective agreement in that case provided that
the release of a probationary employee was “within the discretion of the
College”. It was noted that there had been a change in the language that
made the collective agreement explicit in its denial of a substantive and
procedural right for a probationary employee to challenge dismissal and
that there was no language suggesting a good faith or similar obligation
such as existed in the Brampton case. The arbitrator concluded, at
paragraph 37 that: “… the right of probationers to grieve on the basis of
bad faith or arbitrary reasons must be found in the contract itself or
have some basis for the implication or imposition of such a limitation
from a reading of the collective agreement as a whole”. Accordingly, and
subject to a recognition of statutory or other collective agreement rights,
it was determined that a probationary employee could not challenge a
dismissal on the basis that the Union suggests here.
9. In Ontario Alcohol and Gaming Commission, the collective agreement
provided that: “The Employer may dismiss a probationary employee for
any reason in its sole discretion and probationary employees shall not
11
have any recourse to the grievance or arbitration procedure. There was
no purpose clause similar to that in the Brampton case, however there
was a management rights provision that contemplated the right of the
employer to discharge employees; “subject to the right of the employees
to grieve to the extent and manner provided herein”. In considering the
Union’s submission that the employer could not exercise its discretion in
a manner that was unfair, unreasonable, arbitrary or discriminatory, the
arbitrator wrote as follows:
15. There are authorities which stand for the proposition that
language like "sole discretion" may mean that while the employer
may be the only party capable of exercising the "discretion" to
discharge, the exercise of discretion itself is subject to a "fairness"
standard of review. In Brampton Hydro Electric Commission v.
C.A.W., Local 1285 (1993), 15 O.R. (3d) 773 (Ont.Div. Ct.), the
Ontario Divisional Court interpreted the language of "sole
discretion" pertaining to the discharge of a probationary
employee to imply a review of such discretion on a fairness type of
standard where the collective agreement also provided that
the parties recognized a duty to "cooperate in good faith". This is
consistent with general arbitral opinion on the question of
how an employer's "discretionary" powers are to be exercised (see
for example, the discussion by arbitrator Swan in Meadow
Park Nursing Home v. S.E.I.U., Local 220 (1983), 9 L.A.C. (3d) 137
(Ont. Arb.).
16. There are other authorities which seem to interpret the phrase,
"sole discretion" (as distinct from simply "discretion") to indicate an
unreviewable discretion. In Cami Automotive Inc. v. C.A.W., Local
88 (1991), 19 L.A.C. (4th) 49 (Ont. Arb.), arbitrator Brandt at page
54 states:
In my opinion the clear and unambiguous intent of art. 10 is
to deny to probationary employees the substantive right to
subject a decision to terminate their employment to any
arbitral review. Thus, CAMI [is to be] the sole judge of
"suitability for employment" and termination will be at
CAMI's discretion [emphasis added]. I am unable to
understand how CAMI can remain to be the sole judge of the
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suitability of a probationary employee for employment if its
decision in that respect is subject to arbitral review.
Furthermore if its decision to terminate a probationary
employee is capable of being made subject to challenge
through the grievance arbitration procedure, it cannot be
said to be a decision which it is free to take at its discretion.
17. In my view, the plain language of Article 10.19 makes two
points. Firstly, that the employer may dismiss a probationary
employee in its "sole discretion". Secondly, that it may do so for
any reason.
18. Even if one assumes that the term "sole discretion" may imply
a review on a lesser standard, what is the meaning of the
phrase "for any reason"? It is a principle of collective agreement
interpretation that parties are assumed not to intend language
to be redundant. This means that the phrase "for any reason" must
be read to mean something other than simply the same
thing as "sole discretion", otherwise there would be no purpose in
including it in addition to that phrase. The formula "for any
reason" must be given its plain meaning which is quite simply "for
any reason". The word "any" which defines the boundaries
of the category of permissible "reasons" for the exercise of the
employer's sole discretion is unlimited. "Any" means that
all reasons fall within the category of reasons which may lie
behind the employer's exercise of its sole discretion. The word
"reason" means the thing, event or understanding on the
employer's part which has caused the consequence of the
discharge. Aside from "reasons" which might be in breach of a
statute (such as the Code if the employer's reasons reveal
discrimination on some prohibited grounds), how can it be said
that any "reason" whether unfair, unreasonable, arbitrary or
discriminatory is not a "reason". If this is the case (as I find it to
be), it means that the parties have explicitly agreed that the
employer may discharge an employee quite simply "for any reason".
19. On this analysis I interpret the phrase, "for any reason in its
sole discretion" to mean on its face, that the employer may
exercise its sole discretion to discharge a probationary employee
for any reason, not excluding reasons which might be unfair,
unreasonable arbitrary or discriminatory. I make no finding that
an employer may exercise its sole discretion to discharge a
probationary employee for reasons which are contrary to statute as
it is not alleged in this case.
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10. The arbitrator went on to consider whether there was an implicit
limitation on the employer’s discretion that would compel the result
sought by the union. He noted that there was some authority for that
proposition, referring to a decision of Arbitrator Harris in an earlier
decision of his that Arbitrator Harris referred to in Blue Door. However,
Arbitrator Whitaker stated that:
21. It is certainly the case that collective agreements may be
interpreted in a manner which give rise to an implied duty on the
part of the employer to act in good faith, fairly, reasonably and
without discrimination. In my view, however, such an obligation
must be derived from the language of the agreement in question
and is not to be found to exist on the basis of first principles.
The Ontario Court of Appeal observed in Toronto (Metropolitan) v.
C.U.P.E. (1990), 74 O.R. (2d) 239 (Ont. C.A.) at page 256:
it is not patently unreasonable for an arbitrator to
oblige management to exercise its discretion reasonably
where to do so unreasonably would be to create a conflict
with or undermine the rights conferred by some other
provision in the collective agreement.
22. The question then is whether or not the provisions of this
collective agreement read as a whole indicate that there is
some implied limit on the range of possible reasons (aside
from those that are in breach of a statute) which might lie behind
the exercise of the employer's "sole" discretion to discharge a
probationary employee.
23. Unlike the collective agreement in Brampton Hydro, supra,
there is no provision which obliges the parties to "cooperate
in good faith". It is not the case that the discharge of a
probationary employee operates to abridge or frustrate the
seniority provisions of the collective agreement as seniority under
article 12.01 does not accrue until the successful completion
of probation.
24. There is little doubt that the explicit provisions of the collective
agreement indicate that the parties did not intend that
there be any review of the employer's exercise of sole discretion in
discharging a probationary employee. This is apparent from
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Articles 9.01 and 10.05.
11. In the relatively recent decision, Metrolinx (Go Transit), the
authorities were reviewed in some detail. The collective agreement
language in issue there included a provision describing its purpose as:
… to establish and maintain orderly and harmonious collective
bargaining relations at the bargaining table and the work place; to
provide a procedure for the prompt and equitable disposition of
grievances; to assist and promote the proper and efficient
operation of the Employer’s business in serving the public interest.
The collective agreement further referred to the probation period as a
period of assessment as to whether the employee, in “the sole opinion of
the Employer” is acceptable for employment and went on to provide that:
It is therefore recognized and agreed that probationary
employees may be released or dismissed at the absolute
and sole discretion of the Employer during the probationary
period and that such release or dismissal shall be deemed
to be for just cause. Any probationary employee who is
released or dismissed shall not be entitled to file a grievance.
It was noted that the phrase “absolute and” had been added to the
original language in collective bargaining, The collective agreement also
provided for the consideration of probationary employees for other
positions with the employer’s opinion not to “be exercised in an arbitrary
or discriminatory manner” and further in relation to a consideration of
internal applicants before external, a provision to the effect that
discretion would not be exercised in an “arbitrary or discriminatory
manner”. Elsewhere in the collective agreement there was specific
reference to “good faith” obligations.
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12. In her reasons for concluding that she was without jurisdiction to
consider a dismissal grievance filed on behalf of a probationary employee,
the arbitrator noted that the provisions of the collective agreement must
be read together as a whole and that the intention of the parties must be
derived from the language employed. It was the arbitrator’s view that the
“absolute and sole discretion” of the employer to dismiss a probationary
employee had to be given effect in accordance with its clear meaning and
could not be subject to arbitral review. With respect to the issue of
whether there was an implied obligation on the employer not to exercise
its discretion in an arbitrary, discriminatory or bad faith manner, the
arbitrator rejected the argument that the purpose clause in that instance
could provide a basis for an implied limitation on the employer’s
discretion and at paragraph 34 stated as follows:
… even if I am wrong and, as a matter of law, there is an
implied obligation not to dismiss a probationary
employee for an arbitrary or discriminatory reason,
or in bad faith, it is my conclusion that this implied
obligation has been overridden in this instance by
Article 4.4(1). The Union recognizes that this implied
obligation may be overridden by contractual language,
but submits that the type of words set out by the
Ontario Divisional Court in Brampton Hydro-Electric
Commission v. CAW-Canada, Local 1285, supra, would
be required. With respect, I do not agree. The parties
here did not phrase it in the manner outlined in
Brampton Hydro-Electric Commission v. CAW-Canada,
Local 1285, supra. They did so in a more positive
manner - they determined that any release or dismissal
"shall be deemed to be for just cause." As noted above,
this means that the dismissal of a probationary
employee, no matter the reason, "shall be deemed to be
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for just cause." This is similar to the "any reason"
language reviewed in Ontario (Alcohol & Gaming
Commission) v. OPSEU, supra. The parties' explicit
agreement overrides any implied obligation that may be
inferred. This clear language would be rendered a nullity
if a probationary employee were permitted to assert a
claim that their dismissal was arbitrary, discriminatory
or in bad faith. Such a claim cannot exist in the
context of the explicit agreement that probationary
dismissals "shall be deemed to be for just cause."
13. To the extent that Arbitrator Harris expressed a view to the contrary,
it is my view that the analysis expressed by Arbitrators Whitaker and
Abramsky is preferable. In any event, the language in the Collective
Agreement before me is readily distinguishable from the language under
consideration in the Blue Door decisions. The language at issue there
was “sole discretion”. Here the language of the Collective Agreement
refers to “sole discretion for any reason” [emphasis added]. With respect
to the comparability of this case to Brampton Hydro-Electric, the
purpose provision here: “to provide procedures for the prompt and
equitable disposition of grievances” does not contain the “good faith”
reference contained in the Brampton collective agreement. I agree with
Ms. VanDerMuelen that the reference to “equitable disposition of
grievances” properly refers to grievances contemplated by the Collective
Agreement. Grievances alleging suspension or discharge of a
probationary employee are not contemplated by the Collective Agreement
and thus this provision cannot apply here. In my view, the Court’s
decision in Greater Essex County District School Board makes it very
17
clear that it is open to the parties to a collective agreement to determine
that a probationary employee has neither a substantive nor procedural
right to challenge disciplinary action.
14. Giving meaning and effect to the agreement of the parties as
expressed in the written terms of the Collective Agreement is the
fundamental duty of the arbitrator. The parties have expressly required
me to do so here. The Collective Agreement is properly read subject to
statutory provisions, which, in this instance, has resulted in agreement
that a breach of the Code is a matter that is properly within my
jurisdiction.
15. Article 4 of the Collective Agreement reserves management rights to
the Board, subject to specific provisions of the Collective Agreement.
Such rights are vested “exclusively and without limitation” in the
Employer, except as expressly modified or curtailed. Article 4:02 (b) of
the Collective Agreement provides for the explicit right to: “suspend with
or without pay, discharge or otherwise discipline a probationary
Employee for any reason at the sole discretion of the Board”. This
discretionary right is reinforced in Article 9.01, which then goes on to
state that: “no grievance may be submitted concerning the termination of
employment, lay-off, or disciplining of a probationary Employee.” The
purpose provision of this Collective Agreement does not contain
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“reasonableness” or “good faith” language and the “equitable” reference
in that provision is not a general undertaking, but, rather, is a specific
undertaking in reference to the disposition of grievances.
16. In considering the interpretation to be given to the critical phrase;
“sole discretion for any reason” contained in Article 4.02(b), I note that
the phrase is almost identical to the phrase “for any reason in its sole
discretion” that was contained in the Ontario Alcohol and Gaming
Commission case. I find Arbitrator Whitaker’s conclusion to the effect
that this phrase must mean “all reasons” to be compelling and agree with
the result in that case. I further agree with Arbitrator Abramsky’s
observation in connection with similar language, that such clear
language cannot be rendered a nullity. There is no history of language
changes here that demonstrates the inevitable interpretation of the
language as in other cases, a point emphasized by Ms. Lostracco.
However, the Collective Agreement language is abundantly clear on its
face and its meaning is readily apparent from the words agreed to by the
parties. The language of Article 8.06 (e) prohibits an interpretation of the
Collective Agreement that does not accord with its terms. The parties
have agreed that the Employer can discipline or dismiss a probationary
employee for any reason at its sole discretion. It is my conclusion that
the Employer’s discretion to discipline or dismiss a probationary
employee is not subject to arbitral review on the basis that the discretion
19
was exercised in a manner that was arbitrary, discriminatory or in bad
faith. There is simply no reasonable contextual reading that can lead me
to the conclusion that the provisions of the Collective Agreement can be
interpreted otherwise.
17. I now turn to the question of whether the reprisal claim and the
health and safety claim can be considered on the basis that these are
discrete entitlements under the Collective Agreement that can be
properly advanced. In considering this matter, I am mindful of the
principle that recognition of an employer’s unfettered right to discipline
or discharge a probationary employee cannot conflict with or undermine
other provisions of the Collective Agreement. With respect to the health
and safety claim, the suggestion appears to be that the Employer’s
actions giving rise to the dismissal were not in accordance with its
obligations to make reasonable provisions for the grievor’s health and
safety and were damaging to the her emotional wellbeing. It is difficult to
imagine any situation in which a perceived sense of unfairness
associated with discipline or dismissal would not raise an issue of
emotional health. Arising in the context of a grievance alleging unjust
dismissal, it is my view that the prohibition against allowing a challenge
to that dismissal must necessarily encompass such a claim. To allow the
grievance to proceed on this basis would, in my view, undermine the
agreement of the parties that such claims cannot proceed. The claim of
20
reprisal in the discharge grievance, as I understand it, relates to a claim
that the grievor’s filing of a suspension grievance played a role in her
termination. The difficulty with that position is that the reprisal language
must, by its terms, be interpreted in the context of an ability to
participate in a grievance complaint or arbitration procedure. Here, the
provisions of the Collective Agreement specifically preclude such an
ability in relation to the discipline and dismissal grievances that have
been filed.
18. For the foregoing reasons, it is my conclusion that the Employer’s
preliminary objection to my jurisdiction must be upheld. While the
matter may proceed on the basis of the allegation of a Code violation, I
am otherwise without jurisdiction to consider the Employer’s decisions to
discipline and to discharge Ms. Nabbout. The matter will proceed
accordingly.
Dated at Toronto, this 22nd day of July, 2020
“S. L. Stewart”
S. L. Stewart - Arbitrator