HomeMy WebLinkAbout2009-1749.McNally.09-09-25 Decision
Commission de Commission de
Crown Employeess
Grievance Settlement Grievance Settlement
règlement des griefs règlement des griefs
BoardBoard
des employés de la des employés de la
Couronne Couronne
Suite 600 Suite 600 Bureau 600 Bureau 600
180 Dundas St. West 180 Dundas St. West 180, rue Dundas Ouest 180, rue Dundas Ouest
Toronto, Ontario M5G 1Z8 Toronto, Ontario M5G 1Z8 Toronto (Ontario) M5G 1Z8 Toronto (Ontario) M5G 1Z8
Tel. (416) 326-1388 Tel. (416) 326-1388 Tél. : (416) 326-1388 Tél. : (416) 326-1388
Fax (416) 326-1396 Fax (416) 326-1396 Téléc. : (416) 326-1396 Téléc. : (416) 326-1396
GSB#2009-1749 GSB#2009-1749
UNION#2006-0506-0007UNION#2006-0506-0007
IN THE MATTER OF AN ARBITRATION IN THE MATTER OF AN ARBITRATION
UUnnddeerr
THE CROWN EMPLOYEES COLLECTHE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT TIVE BARGAINING ACT
BBeeffoorree
THE GRIEVANCE SETTLEMENT BOARD THE GRIEVANCE SETTLEMENT BOARD
BETWEENBETWEEN
Ontario Public Service Employees Union
(McNally)
Union
- and -
The Crown in Right of Ontario
(Ministry of Transportation)
Employer
BEFOREVice-Chair
Richard Brown
FOR THE UNION
Richard Blair
Ryder Wright Blair & Holmes LLP
Barristers and Solicitors
FOR THE EMPLOYER
Omar Shahab
Ministry of Government Services
Counsel
HEARING
August 27, 2009.
- 2 -
Decision
[1]Theresa McNally filed a grievance, dated June 21, 2006, asking to be treated as a full-
time employee. In particular, she wants to be treated like a full-time employee in relation
to her pension. The employer contends this grievance is barred by two earlier awards
dismissing grievances dealing with Ms. McNally?s entitlement to benefits including
pension.
I
[2]Ms. McNally began working for the Ministry of Transportation at its Kenora Avenue
office in Hamilton in 1976 . She has held the classification of senior licensing clerk
OAG10 since 1989 or 1990. Ms. McNally first injured her right knee at work in 1991
and has suffered recurrences of the injury. She was awarded a future economic loss
(FEL) award by the Workplace Safety and Insurance Board.
[3]Ms. McNally has never worked more than eighteen hours weekly since September of
1995. Despite her reduced hours, she was treated until 1999 as a full-time employee for
the purpose of vacation, statutory holidays, pension and health and welfare benefits.
When her status was converted to that of a regular part-time employee in November of
1999, she was told her benefits would be reduced accordingly and this announcement
prompted the grievance dated January 11, 2000. A second grievance was filed on
October 11, 2000 shortly after the reduction was implemented.
[4]These two grievances were addressed during five days of hearing in 2003. Contending
the denial of full-time benefits violated the collective agreement, the union then relied
upon articles 41.4 and 42.3 of the collective agreement:
41.4 Where an employee receives an award under the Workplace Safety and
Insurance Act and the award applies for longer than the period set out in Article
41.2 (i.e. three (3) months), the Employer will continue subsidies for Basic Life,
Long Term Income Protection, Supplementary Health and Hospital and Dental
Plans for the period during which the employee is receiving the award.
- 3 -
42.3 The employer will continue to make pension contributions and premium
payments for the Dental Plan and Supplementary Health and Hospital on behalf of
the employee, at no cost to the employee, while the employee receives or is
qualified to receive L.T.I.P. benefits under the plan, unless the employee is
supplementing a Workplace Safety and Insurance award.
[5]The employer?s response was that article 41.4 did not apply to the facts at hand because
the grievor?s FEL award was not an ?award under the Workplace Safety and Insurance
Act? within the meaning of article 41.4.
[6]In the alternative, the union argued the denial of full-time benefits to a disabled employee
unable to work full-time, even if not a violation of the collective agreement, was
discrimination based on handicap in contravention of the Human Rights Code.
[7]In a decision dated October 16, 2003, I first addressed the collective agreement. Rejecting
the employer?s argument about a FEL award, I wrote:
The foregoing analysis leads me to conclude the grievor is entitled to the
protection afforded by article 41.4. Having come to this conclusion, I need not
address the union?s alternative argument about article 42.3, because union counsel
concedes the latter article does not apply to an employee entitled to the benefit of
the former. (page 6)
I also noted:
[A]rticle 41.4 does not preclude the employer from reducing some of the grievor?s
benefits below the level previously enjoyed by her?i.e. pension, sick leave,
statutory holidays and vacation. (page 6)
[8]I then considered whether the reduction of these benefits contravened the Human Rights
Code. Applying the Court of Appeal?s decision in Ontario Nurses? Association v. Orillia
Soldiers Memorial Hospital (1999), 169 D.L.R. (4th) 489, I wrote:
[T]here is nothing discriminatory about requiring work in exchange for
compensation. Following the Court of Appeal?s lead, I conclude requiring full-
time work in exchange for some of the benefits normally offered only to full-time
employees is ?a reasonable and bona fide requirement.? I note article 41.4
entitles the grievor to other benefits not available to employees working part-time
- 4 -
for reasons other than disability. To this extent, as a disabled employee, she is
treated more favourably than others. Accordingly, the facts at hand do not
constitute unlawful discrimination on the ground of disability. (pages 9 and 10)
[9]At a hearing held after the issuance of this award, the union again sought a ruling that the
grievor was entitled to all of the benefits normally available to full-time employees. The
employer argued the initial award was a final and binding determination that Ms.
McNally was entitled to only some of these benefits. In a decision dated September 21,
2005, I ruled in the employer?s favour:
The union now contends my ruling that the grievor is protected by article 41.4 rests upon
the tacit premise that she continues to have full-time status. The gist of the argument is
that the grievor must have full-time status while enjoying the protection of this article,
because it applies only to employees holding this status. According to this line of
argument, as a full-time employee, the grievor is entitled to all of the benefits normally
associated with full-time employment.
This argument is substantively the same as the one initially advanced about article 41.4
and status. I rejected that submission in my initial decision because it would render
meaningless the distinction accepted by the union and employer when they listed in this
article some, but not all, of the benefits normally associated with full-time employment.
The union is bound by my first decision and precluded from raising the same argument
for a second time. (pages 3 and 4)
[10]Ms. McNally then sought to ?buy back? pension coverage for the time that she no longer
worked due to her disability. That request was denied by the OPSEU Pension Trust in a
letter dated April 13, 2006.
II
[11]The instant grievance was filed on June 21, 2006. The remedy sought is a declaration
that ?Ms. McNally is entitled to full pension contributions payable in respect of a full-
time employee.? The union once again relies upon articles 41.4 and 42.3 of the
collective agreement as well as the prohibition against discrimination based on handicap
found in the Human Rights Code but the arguments advanced are new.
[12]Based on the premise that the grievor is entitled to the protection of article 41.4, a
premise confirmed by my initial award, the union submits she is entitled to the same
- 5 -
LTIP coverage as an employee working full-time hours. According to this line of
argument, she is an employee ?qualified to receive LTIP benefits? within the meaning of
article 42.3, even though she is not receiving them. The union contends she is therefore
entitled under article 42.3 to pension contributions for the hours she is unable to work due
to disability.
[13]In the alternative, if the grievor has no contractual entitlement to full-time pension
contributions, the union contends withholding such contributions is discrimination on the
grounds of handicap. The essence of this argument is the grievor, whose injury arose out
of employment, is being treated less favourably than employees with other types of
disabilities, including those on LTIP who were not injured at work. Relying on the
decision of the Supreme Court of Canada in Battlefords and District Co-operative Ltd. v.
th
Gibbs (1996), 140 D.L.R. (4) 1, the union argues differential treatment based upon type
of disability constitutes illegal discrimination on the ground of handicap.
III
[14]Counsel cited a number of decisions where a employer objected to a grievance being
heard, or a union contended a grievance should be allowed, arguing that the outcome was
determined by the decision in an earlier proceeding between the same parties. Most of
these cases can be divided into three basic categories:
a prior decision addressing the same overarching legal question based on the
very same facts;
a prior decision addressing the same overarching legal question based on
different but analogous facts; and
a prior decision answering a different overarching legal question.
IV
[15]Both awards cited by the union fall in the third category of an earlier decision answering
a different legal question that the one later litigated. The first is Liquor Control Board of
Ontario and Ontario Liquor Board Employees Union, decision dated February 2, 2001,
- 6 -
GSB No. 2000-1590 (Mikus). In an earlier decision involving the same employee but a
different overtime assignment, the Grievance Settlement Board (GSB) had ordered that
?the grievor be compensated for the loss of the overtime opportunity.? When the grievor
made a second claim relating to another overtime assignment, the union contended the
first decision barred the employer from arguing the remedy should be monetary and not
in kind. The union relied on the doctrines of res judicata and issue estoppel. Vice-Chair
Mikus construed the first decision as merely requiring some form of compensation
without specifying whether it should be monetary or in kind. In other words, the issue
decided in the first case was whether overtime had been wrongly denied, not what
remedy flowed from a wrongful denial. For this reason, the first decision did not
preclude the GSB from addressing the question of the proper remedy in the second case.
The two cases involved distinct overarching legal questions.
[16]The same was true in the other union case, Ministry of Community Safety and
Correctional Services and Public Safety and Ontario Public Service Employees Union,
decision dated September 29, 2005, GSB No. 2003-3764 (Johnston). This was the GSB?s
second decision about whether the work of correctional officers entailed ?continuous
operation of a VDT? within the meaning of the collective agreement. In the first
decision, the GSB ruled the equipment operated by the employees in question was not a
VDT and the grievance was dismissed. The second case arose out of different facts and
the employer conceded the equipment being used was a VDT. The issue was whether
employees operating it did so continuously. As the overarching legal question decided in
the initial case was different than the one later posed, the ruling on the first grievance did
not prevent the union from arbitrating the second one. Vice-Chair Johnston dismissed the
employer?s preliminary objection which was based on res judicata and issue estoppel.
V
[17]Two of the arbitration awards cited by the employer belong to the second category of a
prior decision addressing the same overarching question based on analogous facts. In
Canada Safeway Ltd. and United Food and Commercial Workers,(2004) 128 L.A.C.
- 7 -
th
(4) 175 (Keller) the issue was whether employees faced a conflict of interest when
working for a competitor. An earlier decision by Arbitrator Rayner held that they did.
Faced with analogous facts, Mr. Keller elected to follow the Rayner award, citing the
doctrine of res judicata. He quoted with approval the following passage from Brown and
Beatty, Canadian labour Arbitration, at 2:3220:
Because the relationship of the parties to a collective agreement is a continuing one and
because in different grievances the same clause may be the subject of interpretation and
application on successive occasions, both the doctrine of res judicata and issue estoppel
have been qualified to some extent in grievance arbitration. Generally, the view has been
expressed that res judicata does not apply nor is the arbitrator bound by a prior award as
to the construction of the agreement. Rather, it is said that as a matter of principle the
prior award should be followed unless the arbitrator has a clear conviction that the
earlier interpretation is wrong. Moreover, in that event it has been suggested by one
arbitrator that a previous finding on the same issue imposes an obligation on the arbitrator
who wishes to depart from it, to analyze clearly the shortcomings of the previous award
and lay a solid foundation for the departure ... And this approach has been followed
whether it is the same language in the same agreement or in subsequent agreements
where it has remained unchanged. (emphasis added.)
Applying the prevailing approach described by Brown and Beatty, Mr Keller wrote:
In the result, therefore, although there may be some factual differences between the
matter before me and Mr. Rayner the essential facts are not different and I am unable to
formulate a clear conviction that the conclusions reached by Mr. Rayner were wrong.
(para. 39)
[18]The GSB has followed a slightly different tack in relation to the second category of cases.
Union counsel cited Ministry of Transportation and Communication and Ontario Public
Service Employees Union, dated February 8, 1982, GSB No. 1981-843 (Delisle). The
GSB had previously ruled an employee named Stewart should be classified as a
Draftsman II. Another employee, named Battens, then claimed his work should be
classified in the same way. The employer conceded both individuals had the same duties
but contended the earlier decision had been made in error. Vice Chair Delisle allowed
the second grievance, based upon the doctrine of res judicata, without considering
whether the first decision was manifestly wrong.
[19]I would be remiss to overlook a more recent decision, by Owen Shime, then Chair of the
GSB, adopting a more nuanced approach. In Toronto Area Transit Authority and
Amalgamated Transit Union, dated May 3, 1988, GSB No. 1987-1276, Mr. Shime wrote:
In the private sector ad hoc boards of arbitration have a separate and distinct capacity to
decide each case on its own merits. Recognizing that individual, but different, decisions
- 8 -
on the same point or issue may create confusion, arbitrators have balanced the interests of
individual decision making with predictability by generally adopting a policy that they
will not depart from earlier decisions unless such decisions are manifestly in error.
But the Grievance Settlement Board is one entity?it is not a series of separately
constituted boards of arbitration. ?
Thus each decision of a panel becomes a decision of the Board and in our
opinion the standard of manifest error is not appropriate for the Grievance Settlement
Board. The [Crown Employees Collective Bargaining] Act does not give one panel the
right to over-rule another panel or sit on appeal from the decisions of an earlier panel.
Also, given the volume of cases that are currently administered by this board, the
continuous attempts to persuade one panel that another panel was in error only
encourages a multiplicity of proceedings and arbitrator shopping which in turn creates
undue administrative difficulties in handling the case load.
We are mindful, however, that there is no provision for appeal and there are
limits to judicial review. While it is our view that the ?manifest error? theory is too lax a
standard, we recognize that there may be exceptional circumstances where an earlier
decision of this board might be reviewed. At this point we are not prepared to delineate
what constitutes exceptional circumstances and the fleshing out of that standard will be
determined on a case by case basis. The onus will be on the party seeking review to
establish exceptional circumstances. (pages 7 to 9)
VI
[20]The remaining two awards cited by the employer fall in the first category of an earlier
decision involving the same overarching question of law and the same facts. In Pharma
th
Plus Drugmarts Ltd. and United Food and Commercial Workers (1991), 20 L.A.C. (4)
251 (Barton), the grievor?s complaint was that the employer had ceased a long-standing
practice of paying her more that the applicable hourly rate specified in the collective
agreement. In keeping with this practice, for the first pay period after an annual increase
came into effect, the grievor was paid $9.38 per hour rather than the contract rate of
$8.85. Thereafter she was paid at the contractual rate. She grieved the reduction and
Arbitrator Stanley ruled her rate should be red circled at $9.38, but he rejected the
union?s request for a declaration that she would be entitled to the same differential over
the contractual rate after the next annual general increase was applied. The second
grievance was filed after that increase came into effect and the employer continued to pay
the grievor $9.38 hourly. Applying the doctrine of res judicata, Arbitrator Barton refused
to entertain the second grievance because Mr. Stanley had already decided she had no
claim to any further increase.
- 9 -
[21]The other award falling in the first category is Telus Communications Inc. and
th
Telecommunications Workers Union (2006), 158 L.A.C. (4) 67 (McConchie). During
negotiations for a new collective agreement, the employer served lockout notice and then
reduced sick benefits while allowing employees to continue to work. The union initially
filed a complaint with the Canada Industrial Relations Board (CIRB) contending the
lockout and ensuing reduction in benefits were unlawful because the employer had failed
to bargain in good faith and had committed other unfair labour practices. This complaint
was dismissed. The union subsequently filed a grievance alleging the reduction in paid
sick leave contravened a section of the Canada Labour Code not mentioned in the
proceedings before the CIRB. Applying the doctrine of res judicata, Arbitrator
McConchie declined to hear the grievance, even though it was based on a section not
considered by the CIRB. He wrote:
There are two aspects to the doctrine. First, it bars a party from relitigating an issue which
has already been decided in a previous proceeding. Secondly, it also prevents a party
from litigating a matter which it ought to have brought up at an earlier proceeding.
The parties here agree that the issue before me revolves around the second, not
the first, of the two aspects. The CIRB did not receive the Union's argument under s.
94(3)(d.1) and so it has not been previously decided. The question is whether the Union
was bound to bring the matter up in those earlier proceedings.
Adjudicators express in somewhat different ways the circumstances in which a
party may find itself bound to raise a matter. I will italicize the key phrases. In the
paradigm case of Henderson v. Henderson [1843] 3 Hare 100, 67 E.R. 313, the court held
that the doctrine applied to bar "every point which properly belonged to the subject of
litigation and which the parties, exercising reasonable diligence, might have brought
forward at the time". The British Columbia Court of Appeal described the obligation as
being to "bring forward their entire cases and avoid carving up in sections a controversy
that should be resolved in all aspects": Lim at para. 4. In Duhaime, as has been seen, the
British Columbia Labour Relations Board barred the complainant's claim upon a finding
that all of the matters raised by the complainant (with one exception not relevant here)
"arise out of the same set of facts and are inextricably linked" and "[a]ll occurred before
the First Complaint was adjudicated"
?
The Union's legal position under s. 94(3)(d.1) properly belonged to the subject of
the litigation, which was the Employer lockout and alteration of terms. It arose out of the
same facts as the arguments under s. 89 and the other unfair labour practice arguments
raised as an alternative position by the Union at the hearing. In substance, the Union did
not bring forward its whole case. It was bound to do so.
I must also conclude that the policy reasons behind the application of the doctrine
ofres judicata are clearly invoked in this proceeding. ? In the case at hand, the parties
should have had the expectation that the CIRB would clarify the legal relationship and
put an end to the controversy, namely, whether and to what extent the Employer was
entitled to lockout and/or change terms and conditions of employment. (paras 38 to 41,
48 and 49)
- 10 -
The overarching legal question in both proceedings was whether the reduction in benefits
was proper. The CIRB had ruled it was. Arbitrator McConchie declined to hear a new
argument advanced in the hope of obtaining a different answer to the same question.
VII
[22]In addition to the arbitral awards reviewed above, the employer cited court decisions
dealing with res judicata and issue estoppel. In my view, two of those cases are
particularly pertinent for present purposes. Both belong to the first category of an earlier
decision addressing the same overarching legal question based on same factual scenario.
[23]The first is Maynard v. Maynard, [1951] S.C.R. 346 involving two family law
proceedings. In the course of a divorce action, the wife agreed to accept $1,200 in full
satisfaction of her claim for maintenance and alimony; that agreement was endorsed by
the court. She subsequently commenced another action seeking additional payments,
alleging that the earlier agreement had been induced by a fraudulent misrepresentation by
the husband. A motion in the original divorce action was launched while judgement was
pending on the fraud allegation, but the motion was not heard until that allegation had
been rejected. The motion claimed additional maintenance and alimony, attempting to
avoid the original agreement on grounds other than fraud. The issue before the Supreme
Court was whether the motion was barred by judgement in the fraud action. Addressing
the doctrine of res judicata, the Supreme Court cited with approval the following passage
from the judgment of the Judicial Committee in Hoystead v. Commissioner of Taxation,
[1926] A.C. 155:
Parties are not permitted to begin fresh litigation because of new views they may
entertain of the law of the case, or new versions ? of the construction of documents or
the weight of the certain circumstances.
If this were permitted litigation would have no end, except when legal ingenuity
is exhausted. It is a principle of law that this cannot be permitted, and there is abundant
authority reiterating that principle. (emphasis added)
Holding the motion was barred by judgement in the fraud action, Cartwright J. wrote:
The issue now before us was, I think, expressly raised in the pleadings of the earlier
proceeding and decided ?The appellant [wife] has submitted the same question as is
- 11 -
now before us (although perhaps not the same arguments) to the decision of a court of
competent jurisdiction and cannot now relitigate the matter. (emphasis added)
The overarching legal question in both proceedings was the same?i.e. whether the wife
was entitled to more maintenance and alimony than specified in the agreement. The
Supreme Court ruled that the earlier judgement prevented her from bringing the motion,
even though arguments made in support of the latter proceeding had not been considered
in the former.
[24]The employer also relies upon Tsaousis v. Baetz [1998] O.J. No. 3516(C.A.) where two
actions were brought claiming compensation for a young child injured in a motor vehicle
accident. Approximately two years after the accident, the child?s mother agreed to accept
a payment of $5,420 in full satisfaction of her claim and the agreement was approved by
éÕÔÊØÇÔÙØÏÚØ
the court based upon medical evidence that the child was ?normal.?
ÍËÎÇØÙÉÎÛØ×ÜÈÑÉÄÜÏÙ
the mother launched a second actionclaiming $2.2 million as
compensation for ongoing medical and developmental problems. Noting the medical
evidence presented in the later action would have available at the time of the first, if due
diligence had been exercised, the Court of Appeal concluded the second action was
barred by the first. Speaking for the Court, Doherty J.A. wrote:
The importance attached to finality is reflected in the doctrine of res judicata. That
doctrine prohibits the re-litigation of matters that have been decided and requires that
parties put forward their entire case in a single action. Litigation by instalment is not
tolerated ? Finality is so highly valued that it can be given priority over the justice of an
individual case even where fundamental liberty interests and other constitutional values
are involved ..
That is not to say that finality interests always win out over other interests once
final judgment is signed and entered. Sometimes the rigor of the res judicata doctrine
will be relaxed ? The limitations on the res judicata doctrine and the power to set aside
previous judgments are, however, exceptions to the general rule that final judgments
mark the end of litigation. Those exceptions recognize that despite the value placed on
finality, there will be situations in which other legitimate interests clearly outweigh
finality concerns. The power to set aside a final judgment obtained by fraud is the most
obvious example. As important as finality is, it must give way when the preservation of
the very integrity of the judgment process is at stake. (para. 18 and 19; emphasis added)
In short, the Court of Appeal ruled that the need for finality precludes relitigation even
when personal liberty and constitutional rights are at stake, unless there are exceptional
circumstances such as fraud.
- 12 -
VIII
[25]How does the case law reviewed above apply to the employer?s preliminary objection
that the instant grievance is barred by my earlier decisions?
[26]The case at hand belongs to the first category of an earlier decision addressing the same
overarching legal question based on the same facts. The initial grievances challenged the
reduction in benefits, including pension, incurred by the grievor as a result of working
part-time. I ruled that she was entitled to continue receiving some benefits without
diminution, but that pension was excluded from the list of benefits protected in this
fashion. In the most recent grievance, the union seeks to advance new arguments in
relation to the same overarching legal question about the grievor?s pension entitlement.
In the cases reviewed above, arbitrators and courts have held relitigation should not be
allowed in this context.
[27]The union emphasized the importance of pension to the grievor?s financial security and
the quasi-constitutional nature of human rights legislation. The cases reviewed above
lead me to conclude these factors do not outweigh the importance of finality in the
determination of whether relitigation is warranted. The wife?s financial security was at
stake in Maynard v. Maynard as was the child?s in Tsaousis v. Baetz, but relitigation was
not permitted in either case. In the latter case, the Court of Appeal stated that finality
trumps even constitutional rights when the same claim is being advanced for a second
time.
[28]The preliminary objection is sustained and the grievance is dismissed.
th
Dated at Toronto this 25 day of September 2009.
Richard Brown, Vice-Chair