HomeMy WebLinkAbout2007-2388.Hawkes.09-07-29 Decision
Commission de
Crown Employees
Grievance
règlement des griefs
Settlement Board
des employés de la
Couronne
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IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Hawkes)
Union
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The Crown in Right of Ontario
(Ministry of Community Safety and Correctional Services)
Employer
BEFOREVice-Chair
Deborah J.D. Leighton
FOR THE UNION
Ed Holmes
Ryder Wright Blair & Holmes LLP
Barristers and Solicitors
FOR THE EMPLOYER
Peter Dailleboust
Ministry of Government Services
Counsel
HEARING
February 3, 2009.
SUBMISSIONS
June 2, 2009.
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Decision
INTRODUCTION
[1]Ms. Valerie Hawkes, a Probation and Parole Officer with the Ministry, grieved in 2005
and 2006,inter alia, that the employer had violated the collective agreement, the Human
Rights Code, and the Workplace Discrimination and Harassment Prevention policy
(WDHP) . She alleged that she was working in a poisoned workplace and that the
employer had failed to accommodate her return to work properly. The parties reached an
agreement to settle the grievances, by Memorandum of Settlement (MOS) dated February
10, 2006.
[2]Beginning on August 1, 2007, the grievor filed multiple grievances alleging breaches of
the MOS and reprisal against her for filing a WDHP complaint. There are sixteen
grievances in total before me and the union advised that it would be forwarding more to
the board. The union seeks to tender evidence of incidents and events that were the
subject matter of the original grievances, and all evidence relating to the WDHP
complaint. The employer objects to this evidence. This decision addresses the
employer?s preliminary motion to exclude evidence underlying the original grievances.
The parties argued the preliminary motion on February 3, 2009 and at the conclusion,
they advised that they were still pursuing settlement options and asked me to wait before
rendering the decision. On June 2, 2009, the parties notified me that they required the
decision.
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EMPLOYER?S SUBMISSION
[3]Counsel for the employer submitted that the substance of the allegations in the grievances
before me is that the employer breached the MOS of 2006 and failed to protect her from a
manager. She is also alleging that she suffered reprisal for filing a WDHP complaint.
Counsel noted that the original grievances all relate to an incident that occurred during a
training session in 2005, and allegations that the employer did not handle the WDHP
complaint appropriately. He argued that the evidence of the events that led to the MOS
in February of 2006 should not be admissible because the substance of the original
complaint is not necessary in order to address the new grievances and more importantly,
since the settlement included a full and final release clause.This board has consistently
recognized the need to hold parties to their agreements and recognized the principle of
the sanctity of settlements. Counsel argued the board has said that only in exceptional
circumstances will it allow evidence of a settled grievance. In his view, there are no
special circumstances here. The union seeks to admit this evidence to show a pattern of
discrimination and harassment and relies on an allegation of bad faith. Counsel
emphasized that there was no evidence of bad faith before me.
[4]Two of the grievor?s current complaints allege that the employer violated the MOS by
concluding the WDHP investigations after the signing of the settlement and by
communicating the result of the investigation to her. Counsel argued that the letter from
the Deputy Minister to Ms. Hawkes, advising her of the results of the investigation,
should not permit the grievor to litigate a matter settled by MOS. Counsel argued that
there is no need to admit evidence of the details of the investigation because the employer
concedes that the investigation process continued to its conclusion after the MOS. He
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noted that the employer takes the WDHP investigation process seriously, and that it has a
duty to see the investigations through to completion. There was nothing in the MOS that
indicated the employer would not finish the investigation.
[5]In closing, counsel also submitted that the original incidents occurred in 2005 and the
delay in defending against the allegations that occurred some three and a half years ago
would prejudice the employer. Further, the evidence would take extensive hearing days
and it is not pertinent to the current grievances before me. Counsel for the employer
relied on the following cases in support of his submission: OPSEU (Fletcher) and
Ministry of Community, Safety and Correctional Services, GSB 2004-0083 (Leighton);
OPSEU (Rolfe) and Ministry of Community and Social Services, GSB 2003-3512
(Briggs).
UNION?S SUBMISSION
[6]Counsel for the union argued that part of the reason for wanting to provide the evidence
that underlies the incidents of the MOS is to show a pattern of harassment. However, it is
also because the Deputy Minister?s letter undermines the MOS. The letter informed the
grievor that the investigator concluded, ?the facts gathered during the investigation do not
substantiate, on a balance of probabilities, the complaint under the WDHP policy.?
Counsel argued that this letter exonerated the employer and thus it was necessary for me
to hear the evidence to assess the grievor?s current complaint. The grievor claims that the
letter has adversely affected her and it is important for me to hear the original evidence in
order to understand how damaging it was to her. The evidence is also important in
understanding the current complaint about the manager?s comment to her. Thus, the
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context is important in order to understand the current grievances. Counsel for the union
submitted that the union agrees with the principle of sanctity of settlements. However, he
argues that the employer has breached the MOS by continuing with the WDHP
investigation, which was also part of the subject matter of the grievor?s original
complaint. Counsel contended that the parties agreed that all the issues of the grievances
were resolved and withdrawn. He noted that paragraph 13 of the MOS provides:
?THE PARTIES agree that this settlement is without any admission of
wrongdoing, misconduct, action or inaction, or liability, and entered into in good
faith for the expeditious resolution and positive labour relations in this matter.?
[7]Counsel for the union argued that this clause applies to the WDHP investigation. He
argued that while the grievor gave up the right to prove her position by settling the
grievances on February 10, 2006, the employer likewise gave up the right to prove its
case. By continuing the WDHP investigation to its conclusion, the employer violated
the MOS.
[8]Counsel argued that the current grievances relate to the old grievances. One grievance
refers to alleged reprisal for filing a WDHP complaint, which cannot be addressed
without evidence of the original complaint. Another grievance alleges a breach of the
duty to accommodate the grievor in a safe workplace and another that the grievor has
been harmed by the Deputy Minister?s letter, adversely affecting her, but also continuing
the gender-based discrimination against her.
[9]The union submitted that while it accepts the need for settlements to be honoured, there
are exceptions to the rule, citing Fletcher, supra and Rolfe, supra. In certain
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circumstances, it is reasonable for the board to hear evidence that underlies a MOS.
Counsel urged me to make an exception in this case and hear the evidence. He argued
that the employer had not acted in good faith when it continued the WDHP investigation.
He argued that by continuing the investigation, which concluded that there was not
sufficient evidence to support the allegations, the employer had acted in bad faith. It is
unfair to the grievor that the employer was able to go forward and exonerate itself, while
she was not able to do the same. Counsel noted that the Deputy Minister?s letter was sent
out approximately a month after the MOS. He noted that the WDHP policy requires a
response thirty days after the investigation is finished. The investigation into this matter
finished in December of 2005, so the response should have been out at the time the MOS
was signed. Nothing in the MOS reserves the right to release the WDHP investigation
results.
[10]The union is not seeking a remedy for the events that occurred before the MOS, but
counsel argued that it was necessary in order to fully understand and appreciate the
current grievances. Counsel also submitted OPSEU (Patterson) and Ministry of Children
and Youth Services (2006) GSB 1989-1546 et al. (Abramsky); OPSEU (Ranger) and
Ministry of Community and Correctional Services (2005) GSB 2002-2375 (Leighton)
DECISION
[11]The issue before me is whether evidence of events in 2005 that were the subject matter of
grievances, settled by MOS in early 2006, should be admitted in the current proceedings.
The union seeks to adduce the evidence to show a pattern of harassment and to provide
the context for the current grievances. The union acknowledges the principle of the
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sanctity of settlements-- that parties must be able to rely on the agreement that the matter
will not return in another forum or guise. However, the union argues that I should make
an exception here because the employer has acted in bad faith by continuing a WDHP
complaint.
[12]The board has addressed this issue consistently over the years, recognizing the
importance of enforcing settlements between the parties. The board has discretion as to
what evidence it admits, but it has said that it will not admit evidence of a settled matter
unless there are special circumstances. As Vice-Chair Abramsky stated in her thorough
review of the board?s case law on the issue in Dale, ? once a matter is settled, the
expectation is that the matter is resolved and will not reappear in some different guise? (
as cited in Fletcher, supra, at p. 8).
[13]The facts in the case before me are almost identical to those in Fletcher, supra. In
Fletcher, the union sought to adduce evidence in a subsequent grievance hearing of an
incident that occurred on a picket line, which had been grieved and settled. The
argument before the board was that in order to appreciate the current grievances, it was
necessary for the context of the case to hear the evidence of the original grievance. The
union also alleged that the employer had acted in bad faith. After carefully considering
the submissions, I decided that the evidence of what occurred on the picket line was not
relevant to the grievances then before me. It was not necessary to hear the picket line
evidence in order to assess the reprisal allegations made by the grievor. Further, the
principle of sanctity of settlements meant that the evidence could not be used even for a
limited purpose, such as to show an ongoing pattern of harassment, or to provide a
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context for the subsequent grievances. Finally, there was no evidence of bad faith to
support a decision to find special circumstances to admit the evidence.
[14]The same reasoning applies to the case before me now. The evidence of the training
session incident, which was grieved and settled, is not relevant to the current grievances,
which allege breaches of the MOS. For example, the allegation that after signing the
MOS the employer failed to provide a safe workplace for the grievor must be proved with
evidence of incidents subsequent to the settlement. Whether the continuation of the
WDHP investigation is a breach of the settlement likewise does not require the
underlying evidence of the original complaints. The issue is not whether the events as
alleged in the original grievances occurred during the training session in 2005. This
evidence is simply not helpful in deciding the issues of the current grievances. Further, I
am not persuaded that it should be allowed even for the limited purpose of arguing
damages, should a breach be proven. I am convinced that the harm that would occur by
allowing such evidence far outweighs any probative value. As noted above, this board
has held repeatedly that when the parties settle a case, with clear language that includes a
release clause, as is the case here, the evidence that would have been called to support the
original complaint, should not be permitted, even for a limited purpose in a subsequent
grievance, except in special circumstances. The principle of sanctity of settlements is too
important to whittle away with exceptions, except in the clearest case.
[15]Counsel for the union argues that this is such a case, because the employer has breached
so many provisions of the MOS. Further, because the employer has acted in bad faith by
continuing the WDHP investigation to its completion after the MOS was signed, it cannot
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rely on the principle of sanctity of settlements. I am not persuaded that I should make an
exception for the reasons as argued and admit this evidence. I have no evidence before
me that the employer acted in bad faith by finishing the WDHP investigation. The
alleged breaches of the MOS are as yet allegations only. Even if I assumed for the sake
of the motion that the union will prove the breaches, it does not follow that the evidence
of the original grievances should be admitted. To be clear the union is not arguing that
the breaches are so significant that the board ought to find that the MOS is void and begin
a fresh hearing into the original grievances.
[16]Having carefully considered the submissions of the parties and for the reasons above, I
have decided to grant the employer?s motion. The evidence of the original grievances
settled by MOS in early 2006 and the evidence relating to the WDHP complaint to the
date of the last original grievance shall not be admitted. The original grievance forms
and the MOS of 2006 shall be part of the record before me in the current proceeding.
th
Dated at Toronto this 29 day of July 2009.
Deborah J.D. Leighton, Vice-Chair