HomeMy WebLinkAbout2019-0765.Vetsavong.21-01-11 Decision
Crown Employees Grievance Settlement
Board
Suite 600
180 Dundas St. West
Toronto, Ontario M5G 1Z8
Tel. (416) 326-1388
Fax (416) 326-1396
Commission de
règlement des griefs
des employés de la
Couronne
Bureau 600
180, rue Dundas Ouest
Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
Téléc. : (416) 326-1396
GSB# 2019-0765
UNION# 2019-0234-0156
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Vetsavong) Union
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The Crown in Right of Ontario
(Ministry of the Solicitor General) Employer
BEFORE Ian Anderson Arbitrator
FOR THE UNION Dan Sidsworth
Ontario Public Service Employees Union
Grievance Officer
FOR THE EMPLOYER Caroline Cohen
Treasury Board Secretariat
Legal Services Branch
Senior Counsel
HEARING October 5, 2020
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Decision
[1] The Grievor received a 10 day suspension as a result of an incident in which he
used “OC Spray” on an inmate. The Union disputes that any discipline was
warranted and in the alternative takes the position that the discipline imposed was
too severe and ought to be reduced.
[2] The grounds relied upon by the Employer in imposing the discipline are stated in
the disciplinary letter:
1. That you used unnecessary and excessive force when you deployed MK-3
Oleoresin Capsicum (OC) Foam [OC Spray] on an inmate who was in a position of
disadvantage on the unit floor.
2. You failed to deploy OC Spray at a minimum distance of three feet as per
Ministry Policy.
3. You were not truthful or forthcoming in you [sic: your] use of force Occurrence
report and addendum regarding the incident and your rationale for using and
deploying the OC Foam.
[3] The letter of discipline was issued by Acting Deputy Superintendent Santos. It
relates to a physical altercation between an inmate I shall refer to as Inmate L and
an inmate I shall refer to as Inmate S. Deputy Santos gave evidence on behalf of
the Employer. He did not directly witness the incident. Deputy Santos’ evidence
was that he “reviewed all the occurrence reports, the client profile, the photographs
and the video of the incident”. He signed off on the Use of Force Local
Investigation Report (“LIR”) and referred it to the Superintendent. Deputy Santos
determined that a 10 day suspension was appropriate following consultation with
the Superintendent, the Deputy Regional Director and Labour Relations. The
Grievor gave evidence on behalf of the Union. The evidence in chief took the form
of declarations supplemented by oral testimony.
Allegation 1: That you used unnecessary and excessive force when you deployed MK-3
OC Spray on an inmate who was in a position of disadvantage on the unit floor.
[4] The Employer’s Use of Force Policy provides:
3.1.4 No employee shall use force against an inmate unless force is required in
order to enforce discipline and maintain order within the institution; defend the
employee or another employee or inmate from assault; control a rebellious or
disturbed inmate; or conduct a search (see Searches) - R.R.O. 1990, Reg. 778, s.
7(1).
3.1.5 Force must always be the action of last resort. The amount of force used must
only be that amount needed to control a situation. When there is a decision to use
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force, it must be used in compliance with the law, good judgment, and Ministry
policy, procedures and training.
3.1.6 When an employee uses force against an inmate, the amount of force used
shall be reasonable and not excessive, having regard to the nature of the threat
posed by the inmate and all other circumstances of the case - R.R.O. 1990, Reg.
778, s. 7(2).
[5] The issue between the parties is not whether force was required but rather
whether the force chosen, the OC Spray, was unnecessary or excessive in the
circumstances.
[6] In his declaration, Deputy Santos stated:
8. The inmate [Inmate L] was in a position of disadvantage, lying supine on the
floor. The grievor entered the area with other staff. At the time the grievor
sprayed the inmate on the floor with oleoresin capsicum spray (“OC Spray”),
the inmate [Inmate S] who had been on top of that inmate had gotten up from
the floor and was backing away. The grievor sprayed the inmate from less
than three (3) feet away, approaching the inmate quite closely.
9. The inmate only started kicking at the same time the grievor sprayed her. The
grievor would not have seen her kicking at the time he made the decision to
spray her. She was on the floor and was therefore not in a position to cause
significant harm to either staff or inmates. Moreover, her size, strength,
gender, physical capability and history did not indicate she posed a threat. He
ought to have explored ways to gain physical control of her such as soft
physical techniques prior to resorting to using OC spray.
[7] In cross-examination Deputy Santos indicated that when considering discipline he
had reviewed the videos several times to make sure he was making the “correct
assessment”. He stated he believed that Inmate L was kicking prior to being
sprayed with the OC Spray. When directed to paragraph 9 of his declaration, in
which he stated the opposite, he stated he “believed that might have been correct
at the time of the assessment”. He maintained, however, that the Grievor should
have first attempted soft physical techniques prior to resorting to the use of OC
Spray.
[8] The Grievor’s evidence was that he heard someone yelling a fight was happening
in the unit, and responded by going to the unit door. From the door he could see
Inmates L and S engaged in a physical altercation. He stated it was common for a
correctional officer to have his or her OC Spray out of its holster and in hand when
responding to incidents of this sort. He testified he observed Inmate L kicking
twice prior to using the OC Spray foam. He also testified that on two occasions
prior to using the OC Spray he yelled out “stop or I will spray”. This evidence was
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not contradicted. In cross-examination he acknowledged that Inmate S had
backed away at the point he used the spray on Inmate L, but denied the fight was
over. He noted that Inmate L continued to kick twice and stated that he had been
involved in altercations before in which one inmate continued to strike another
inmate whom he was restraining. He stated Inmate L was about the same size as
himself, he was unable to comment on her strength, but believed she had been in
altercations within the facility before. He stated he did not first try to use soft
physical techniques because he did not want to be kicked. In re-examination he
stated there was nothing in the use of force training which stated that soft
techniques had to be used prior to use of OC Spray.
[9] Deputy Santos was recalled to address certain points in the Grievor’s evidence.
Deputy Santos testified the Grievor’s statement that it was common for a
correctional officer to have OC Spray unholstered and in hand when responding to
situations was not accurate, but added that there are situations in which it is
appropriate to have OC Spray unholstered and in hand, including when inmates
fail to respond to commands from an officer and continue to fight. Deputy Santos
initially appeared to state that the Grievor had not issued commands, but then
conceded that it appeared he had. Deputy Santos also disagreed with the
Grievor’s statement that there was nothing in the use of force training which stated
that soft techniques had to be used prior to use of OC Spray. This statement,
however, was qualified as Deputy Santos elaborated on the use of force model,
which he described as involving a process of assessing, planning and acting in
which soft techniques are to be “considered” prior to moving on to the use of OC
Spray. He was then asked whether there was an expectation that soft physical
techniques would be used prior to OC Spray. He responded “depending on the
severity of the situation, yes”. I infer that in Deputy Santos’ view, there are
circumstances in which it would not be expected that soft physical techniques be
attempted prior to the use of OC Spray. He went on to state that in this instance it
was his assessment that soft physical techniques should have been used first
because the inmates were separated and “were not combative with each other or
anyone else”.
[10] The degree to which the inmates were combative or, as reframed by the Union in
argument, compliant, is the key issue in this proceeding. The Grievor’s evidence
was that the fight was ongoing. Deputy Santos’ evidence that the inmates were no
longer combative is based on his viewing of the video. In that respect, he stands
in no better position than I. The video clip of the incident was entered into
evidence. I have reviewed it several times. The video clip does not have audio.
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[11] The video shows the day room of a cell block. A number of inmates can be seen
seated at separate tables. Inmate L and Inmate S, are seated at separate tables
but facing each other. They are approximately 12 to 15 feet apart. Inmates L and
S rise from their seats at approximately the same time and Inmate L runs at
Inmate S. They start grappling, punching and kicking at each other. Inmate S
succeeds in throwing Inmate L to the ground beneath or beside a table. The table
largely obstructs the view of Inmate L. Inmate S appears to be kneeling on top of
Inmate L and can be seen to continually punch down towards Inmate L. Inmate
L’s feet can be seen kicking upwards towards Inmate S. I would note that it would
be surprising in the circumstances if she were not.
[12] The first of what is ultimately at least nine correctional officers can then be seen
entering the field of view from the centre bottom of the screen. The first officer is
officer Manning. The Grievor is the second officer to be seen, entering the field of
view almost at the same time as officer Manning. He comes in from the bottom left
hand corner. He has his OC Spray out of its holster and in his right hand as he
enters the field of view. Other correctional officers enter the field of view within the
same fraction of a second as officer Manning and the Grievor. Just before the
officers enter the screen, Inmate S looks up from Inmate L in the direction from
which some of the officers will enter, stands up, and then backs away, towards
another table. Inmate L continues to kick and Inmate S stumbles slightly while
backing away.
[13] Officer Manning runs directly towards a gap between the table under which Inmate
L is located and another table. The Grievor also runs towards Inmate L. Inmate S
is on the other side of Inmate L, further away from both officer Manning and the
Grievor. Both the Grievor and officer Manning are looking down towards Inmate L
as they approach, who continues to kick. The Grievor sprays Inmate L when he
reaches her. There is no pause in his motion before doing so. As the Grievor
sprays Inmate L, officer Manning steps over the legs of Inmate L and the seat of
an adjacent table while shifting his focus to Inmate S. He reaches Inmate S,
places his hands on her arms and directs her away from the scene.
[14] The inmates fought for about 13 seconds prior to Inmate S standing up. The
Grievor sprays Inmate L within three and a half seconds of when Inmate S first
started to stand up and within two seconds of when he entered the field of view.
[15] Over the course of the next seven or eight seconds, the Grievor looks up towards
Inmate S, raising his OC Spray and pointing it towards her as he does. Officer
Manning has control of Inmate S by then and is leading her away. At the same
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time the Grievor is joined by another CO, who is between him and Inmate L. The
Grievor looks back down at Inmate L who has stopped kicking. As other COs
arrive and the other inmates move towards their cells, he re-holsters his OC Spray.
While not on the video, there is no dispute that the Grievor then followed
procedure in assisting Inmate L in removing the OC Spray from her eyes.
[16] The Employer argues that there is a continuum with respect to force options. The
Employer notes that the Use of Force Guidelines (the “Guidelines”) distinguish
between situations in which use of force is considered “routine” and those in which
it is “not routine”. OC Spray Foam is listed as a “not routine” use of force. OC
Spray Foam falls quite far down the list of force options contained in the
Guidelines, which also note that OC Spray is a prohibited weapon. The Employer
makes reference to the continuum illustrated in the “Use of Force Management
Model” (2016) schematic contained in training materials provided to correctional
officers. It notes the concentric rings of responses, in which the blue ring (staff
presence, verbal intervention, tactical communication, negotiation / diffusion skills)
is reached before the yellow ring (physical handling (soft), physical handling
(hard), restraints, aerosol spray, chemical agents, impact weapons). The
Employer argues it is improper to jump on the continuum to aerosol spray without
first trying soft and hard handling techniques.
[17] The Union notes that use of physical handling (soft), physical handling (hard),
restraints, aerosol spray, chemical agents, impact weapons all appear in the
yellow ring of the Use of Force Management Model. The Union argues there is no
sequential order to these steps and that it is up to an individual correctional officer
to determine which level of force will be used. The Union also notes the training
materials with respect to the use of OC Spray indicate that it may be used to
distract, disorient, disrupt activities, disperse or disable. It argues any number of
these uses have application to stop an inmate from fighting, in particular where the
fight is occurring in a day room with other inmates (who are potential combatants)
present. The Union notes the training materials actually give two inmates fighting
as an example where OC Spray may need to be deployed. The Union also notes
that section 7(1) of Regulation 778 to the Ministry of Correctional Services Act
authorizes correctional officers to use force to enforce discipline and maintain
order within the institution, defend the employee or another employee or inmate
from assault, or to control a rebellious or disturbed inmate, among other things.
[18] I note OC Spray is a prohibited weapon, but one which correctional officers are
authorized to use in appropriate circumstances. In my view, as a matter of
common sense, the use of OC Spray cannot be considered routine. The
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distinction in the Guidelines between routine and not routine use of force, however,
relates to the triggering of the Local Investigation Protocol. Routine use of force
(e.g. the application of restraints to a compliant inmate during escort and other
similar listed circumstances) does not trigger the Protocol. Use of force which is
not routine does trigger the Protocol and results in the generation of a Local
Investigation Report (“LIR”), as was the case here. The purpose of the
investigation is to ensure that non-routine use of force is reviewed to ensure that
its use was appropriate. There is no presumption that it was not.
[19] I agree with the Union there is no sequential ordering in the training materials of
the types of force listed in the yellow ring (physical handling (soft), physical
handling (hard), restraints, aerosol spray, chemical agents, impact weapons). I
disagree, however, with the Union’s suggestion that as a result, a correctional
officer may simply choose which of those types of force to use. I also disagree
with the Employer’s suggestion that there is an obligation to attempt lesser levels
of force before use of a given level of force can be considered reasonable and not
excessive.
[20] A correctional officer’s choice of force is subject to the obligation set out in section
7(2) of Regulation 778:
When an employee uses force against an inmate, the amount of force used shall be
reasonable and not excessive, having regard to the nature of the threat posed by the
inmate and all other circumstances of the case.
This obligation effectively gives rise to a continuum with respect to the amount of
force which may be used against an inmate. For example, depending on the
nature of the threat posed by the inmate and all other circumstances of the case,
use of soft handling techniques may be reasonable and not excessive, where use
of OC Spray would not be. Unsuccessful use of a lesser level of force is a factor
to consider in assessing whether use of a higher level of force was reasonable and
not excessive, but it is not a precondition. It is not difficult to think of examples in
which requiring an officer to attempt lesser levels of force prior to using a higher
level of force would significantly increase the risk of injury to the inmate, the officer
or others. Finally, the requirement that the force be reasonable means that an
officer’s choice of force is to be assessed on an objective standard having regard
to nature of the threat and all other circumstances. The training received by
officers is one such circumstance.
[21] I turn now to consider the evidence in this case.
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[22] I conclude Inmates L and S were involved in a physical altercation at the time that
the Grievor entered the day room. The Grievor called out twice that he would use
the spray if they did not stop. While Inmate S disengaged from Inmate L following
the arrival of officers in the day room, it is not possible to tell whether she did so
immediately after being commanded to do so or only after some delay. In any
event, Inmate L continued to kick as Inmate S was disengaging and while the
Grievor and officer Manning were approaching Inmate L. In particular, Inmate L
continued to kick as officer Manning was stepping over her, notwithstanding the
fact that she was supine on the floor. The Grievor then sprayed her. All of this
took place within a matter of a few seconds. I note as well that the training on OC
Spray provided to officers by the Employer contemplates its use when two inmates
are fighting.
[23] There are other relevant facts, but I place less weight upon them. For example,
Inmate L was approximately the same size as the Grievor and was someone
whom he believed had been involved in altercations before. There were also a
number of other inmates present, who could have become potential combatants.
But this is counterbalanced by the fact that there were also a number of other
correctional officers present who could assist in gaining control.
[24] In these circumstances, was the Grievor’s use of OC Spray Foam on Inmate L not
excessive and objectively reasonable?
[25] The Employer argues that when the Grievor used the OC Spray, Inmate L was
lying on her back and not a threat. The Employer asserts that the Grievor used
the OC Spray at the same time or perhaps an instant before Inmate L kicked
towards Inmate S who was being removed. The Employer argues that the Grievor
would barely have had time to register the kick and that he was ready to use the
OC Spray regardless of the actions of Inmate L, as evidenced by the fact that he
ran towards her with the OC Spray unholstered.
[26] In my view, this argument is not supported by the evidence. Inmate L was kicking
out at Inmate S for several seconds prior to the Grievor arriving by her side. Thus,
the Grievor had plenty of time to register the fact that Inmate L was kicking. The
Grievor issued two verbal warnings to stop or he would spray, but Inmate L
continued to kick, including after Inmate S stood up and backed away. Inmate L’s
kicking may not have been directed towards officer Manning, but it did impede him
in reaching Inmate S. Inmate L did not stop kicking until sprayed. These facts do
not support the characterization of Inmate L as simply lying on her back and not
posing a threat.
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[27] The Employer argues the Grievor should have first attempted soft physical
techniques, as officer Manning did, prior to using the OC Spray.
[28] This argument ignores the difference in behaviour of Inmate S and Inmate L.
Inmate S had disengaged from the fight and was backing away at the point in time
officer Manning reached her and used soft physical techniques. Inmate L was still
actively kicking out at the point in time the Grievor reached her.
[29] I discount Deputy Santos’ evidence that in his assessment the use of the OC
Spray by the Grievor was not necessary and excessive. That evidence was
predicated on the assumption that the Grievor had not first issued oral commands
to the inmates to stop fighting and that Inmate L only started kicking after the
Grievor used the OC Spray on her. Neither was the case, as Deputy Santos
appeared to concede in other parts of his evidence. I am unable, therefore, to give
any weight to his assessment as critical assumptions on which it was based are
not made out.
[30] Deputy Santos’ evidence invites the inference that in his assessment use of OC
Spray would be justified on the facts as I have found them to be: the Grievor first
issued oral commands and Inmate L, at least, was still fighting. In any event, I
note that the Employer’s training materials specifically contemplate the use of OC
Spray in the circumstance of a fight. In the result, I am unable to conclude that the
Grievor’s use of OC Spray was objectively unreasonable and excessive in the
circumstances. Accordingly, I find the Employer has failed to prove the first
allegation.
Allegation 2: You failed to deploy OC Spray at a minimum distance of three feet as per
Ministry Policy.
[31] The Grievor’s evidence was that he deployed the OC Spray on Inmate L’s face
from a distance of approximately four feet. The only other evidence was the video.
In the video, a table obstructs the view of everything but Inmate L’s feet when she
is kicking. It is simply not possible to tell the distance from which the OC Spray
was deployed in relation to Inmate L’s face from the video. Accordingly, I find the
Employer has failed to prove the second allegation.
Allegation 3: You were not truthful or forthcoming in your use of force Occurrence report
and addendum regarding the incident and your rationale for using and deploying the OC
Spray.
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[32] The Employer’s argument is in essence that the occurrence reports filed by the
Grievor were inaccurate. The occurrence reports are consistent with the facts as I
have found them and thus not inaccurate. The occurrence reports also set out the
Grievor’s rationale for deploying the OC Spray: to stop the fight. Accordingly, I find
the Employer has failed to prove the third allegation.
Conclusion
[33] For all of the foregoing reasons, the grievance is allowed. The Employer is
directed to rescind the discipline and to make the Grievor whole. I remain seized
should there be any issues arising from those directions.
Dated at Toronto, Ontario this 11th day of January, 2021.
“Ian Anderson”
________________________
Ian Anderson, Arbitrator