HomeMy WebLinkAboutP-2020-1993.Illeman.21-02-26 Decision
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Commission des
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PSGB# P-2020-1993
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE OF ONTARIO ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Illeman Complainant
- and -
The Crown in Right of Ontario
(Ministry of the Solicitor General)
Employer
BEFORE Marilyn A. Nairn Vice-Chair
FOR THE
COMPLAINANT
FOR THE EMPLOYER
Susan Illeman
Peter Dailleboust
Treasury Board Secretariat
Legal Services Branch
Senior Counsel
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Decision
[1] In this complaint, Susan Illeman asserts that she did not receive the 2019-2020
performance rating given to her by her evaluating manager and that it was changed with
malice by the Employer. She seeks compensation for lost wages associated with the
higher rating. She asserts that she was treated unfairly, inequitably, and with malice.
[2] The complainant is a manager in Corrections within the Ministry of the Solicitor
General. Her complaint was filed with the Board on November 12, 2020. Her notice of
proposal to file a complaint was given on October 7, 2020. She received no response.
[3] This complaint is very similar to a number of complaints received by the Board
concerning the 2018-2019 and 2019-2020 performance rating periods. Although the
timing is different, the allegations made and remedies requested are in essence the same.
A number of those complaints have already been considered by the Board.
[4] Rule 11 of the Board’s rules provides:
Dismissal Without a Hearing or Consultation
Where the Board considers that a complaint does not make out a case for the orders
or remedies requested, even if all the facts stated in the complaint are assumed to
be true, the Board may dismiss the complaint without a hearing or consultation. In
its decision the Board will set out its reasons.
[5] Having regard to the complaint and the material filed in support, and assuming the
facts asserted therein to be true and provable, I find that the Board is without jurisdiction
to entertain this complaint because sub-paragraphs 4 and 5 of Ontario Regulation 378/07
(the “Regulation”) made pursuant to the Public Service of Ontario Act, 2006 (the “PSOA”)
expressly preclude this type of allegation from forming the subject of a complaint.
[6] The relevant and applicable provisions of the Regulation provide:
Complaint about a working condition or a term of employment
…
4. (1) Subject to subsection (2), a public servant who is aggrieved about a working
condition or about a term of his or her employment may file a complaint about the
working condition or the term of employment with the Public Service Grievance
Board…
(2) The following matters cannot be the subject of a complaint about a working
condition or about a term of employment:
…
4. The evaluation of a public servant’s performance or the method of evaluating his
or her performance.
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5. The compensation provided or denied to a public servant as a result of the
evaluation of his or her performance. O. Reg. 378/07, s. 4 (2).
[7] In Bowmaster et al. v Ontario (Solicitor General), 2020 CanLII 105698, the Board
had received a number of complaints concerning the 2018-2019 performance ratings of
the various complainants. They each asserted that their performance rating had been
unilaterally changed to their detriment and in a manner that reflected the arbitrary,
discriminatory, or bad faith exercise of the Employer’s discretion. They each sought a
higher rating and the increase in pay associated with that higher rating. The Employer
raised sub-paragraphs 4 and 5 of section 4(2) as a bar to those complaints. After hearing
from the parties, the Board considered the scope of those provisions and concluded:
[14] This Board is established pursuant to the terms of the Public Service of
Ontario Act, 2006 (the “PSOA”) and the scope of its authority to consider and resolve
complaints is set out in Ontario Regulation 378/07 (the “Regulation”) made pursuant
to the PSOA. That Regulation sets out the type of complaints that the Board has
jurisdiction to entertain, providing a limited forum in which excluded employees may
bring complaints about the alleged breach of, inter alia, terms and conditions of
employment.
…
[27] The Board’s decision in Garratt, supra, confirms that there may be
circumstances where the Board will inquire into an allegation of arbitrary,
discriminatory or bad faith conduct on the part of the Employer. Fundamentally, the
allegation must relate to an existing term or condition of employment which the
Board has jurisdiction to enforce. In Garrett, the complainants sought a transparent
process for setting and communicating wages. No such process then existed and
the Board dismissed the complaint on the basis that the complainant was seeking
to establish a new process - to create a new term of employment, a matter beyond
the Board’s jurisdiction. The Board’s role is the enforcement of existing terms and
conditions of employment. The Board did go on to say that an allegation that an
existing term or condition of employment had been applied in bad faith was a matter
that could be brought to the Board. However, that decision did not deal with a term
or condition of employment that was otherwise expressly excluded from the Board’s
purview.
…
[34] Pay for performance is a term and condition of employment for excluded
employees, including these complainants (and see Kaine v. Ontario (CYS), 2014
CanLII 48097 at paragraph 36).These complaints all assert that the manner in which
their performance was evaluated, first done by their direct manager and then
changed without notice or consultation was in breach of the EPP and that the
Employer cannot shield itself from its own misconduct. However, what is being
fundamentally complained about are those matters excluded from the Board’s
purview by paragraphs 4 and 5 of sub-section 4(2) of the Regulation. Each complaint
seeks to be remedied by the complainant being awarded a higher performance
rating as each challenges the evaluation ultimately made by the Employer. In
asserting that the Employer acted in a manner that was arbitrary, discriminatory
and/or in bad faith the complainants are challenging “the method of
evaluating...performance”. They also seek “the compensation.. denied…as a result
of the evaluation”.
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[35] Having regard to the specific exclusion in the Regulation, I find that the
Employer is effectively protected from a complaint at the Board asserting that it acted
in a manner that was arbitrary, discriminatory, or in bad faith in respect of matters
concerning pay for performance. This in no way speaks to the quality of the
Employer’s treatment of the complainants or to the actual work performance of any
complainant. It is a decision based on the fact that this Board has no inherent
authority and the clear language of the Regulation specifically excludes these
allegations from the Board’s jurisdiction to consider and/or remedy.
[8] That decision did go on to note that the Employer did not challenge that the Board
had the jurisdiction to consider an allegation of discrimination made pursuant to the
Employer’s statutory obligations under the Human Rights Code (the “Code”). To the
extent that some of the complaints raised such allegations and identified prohibited
grounds, those complaints continued within that limited scope.
[9] However, this complaint makes no allegation that the Employer breached any
statutory obligation and asserts no facts that would support an allegation of discrimination
under the Code. As in the decision in Bowmaster et al., supra, it falls therefore to be
determined based on the scope of the regulatory language.
[10] Given the specific regulatory exclusion of matters relating to either the method of,
or the evaluation of a manager’s performance and the further exclusion of any issue
relating to the compensation provided or denied as a result of an evaluation of
performance, the Board has no jurisdiction to entertain this complaint. It is a complaint
fundamentally about pay for performance, a matter expressly excluded from the Board’s
purview.
[11] As noted in paragraph 35 of the decision in Bowmaster, cited above, this in no way
speaks to “the quality of the Employer’s treatment of the complainant or to the actual work
performance of the complainant”. It is a decision regarding the scope of the Board’s
authority.
[12] In the result, this complaint is hereby dismissed.
Dated at Toronto, Ontario this 26th day of February, 2021.
“Marilyn A. Nairn”
________________________
Marilyn A. Nairn, Vice-Chair