HomeMy WebLinkAboutP-2005-3536.Jones.10-04-08 Decision
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P-2005-3536
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Complainant
Jones
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The Crown in Right of Ontario
(Ministry of Community Safety and Correctional Services)
Employer
BEFOREDeborah J.D. Leighton Vice-Chair
FOR THE COMPLAINANTRuth P. Orton-Pert
Mousseau DeLuca McPherson Prince LLP
Barristers and Solicitors
FOR THE EMPLOYERFerina Murji
Ministry of Government Services
Counsel
HEARINGJanuary 19, 2010.
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Decision
[1]The complainant in this matter has applied to the board under the Public Service of Ontario
Act, alleging that her dismissal from employment was without just cause. At the outset of
the hearing, counsel for the employer presented a motion for production of certain medical
documents. The employer seeks the production of the following documents:
1)All copies of the clinical notes and records of the grievor?s general practitioner and any
and all specialists from the date April 1,2007 to October 31, 2009;
2)The complete file of Dr. Felicity Davies, the complainant?s psychiatrist, from April 1,
2007 to October 31, 2009 including all clinical notes and records, charts, tests and any
other record or note including correspondence from the grievor?s counsel;
3)The decoded OHIP form for the grievor from April 1,2007 to October 31, 2009.
The employer reserved the right to ask for additional documents depending on the results of the
production from the complainant. The complainant opposes the production of these medical
documents, primarily on the basis of arguable relevance and privacy concerns. This decision
therefore addresses the motion for production of medical documents.
Submission of the Employer
[2] Counsel for the employer argued that the issue before the parties in this application is a
narrow one. The issue is whether or not the complainant abused her short term sick leave when
she attended school. The complainant takes the position that attending school while she was on
short term sick was part of a treatment plan recommended to her by her psychiatrist, who will be
testifying to that opinion. Counsel for the employer argued that since the complainant has placed
her health and wellbeing at issue in the grievance, the employer is entitled to the medical
production it requests. Counsel argued that it is arguably relevant, that it has been requested with
sufficient particularization and that it is not merely a fishing expedition.
[3] Counsel for the employer also noted that another factor in assessing whether or not
production ought to be made in these cases is whether there would be undue prejudice to the
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complainant. She noted that there had been no disclosure of any prejudice to the grievor.
Counsel argued further that when a grievor put her medical health at issue, she was not entitled
to pick and choose as to what medical evidence would be presented to the board. Counsel
argued that the Grievance Settlement Board decisions have held that a party relying on a medical
document cannot do so in a vacuum and that the individual must provide all medical documents
that form the basis of such an opinion or document. Finally, the request for damages for pain
and suffering also supports an order for production of medical documentation. Counsel relied on
the following cases in support of her submission: Sysco Food Services of Toronto and Teamsters,
Local419 [2006] O.L.A.A. No. 340 (Briggs); Stelco Inc. v. U.S.W.A., Local 1005 [1994] 42
L.A.C. (4th) 270 (Dissanayake); Celgar Pulp Inc. v. P.P.W.C, Local 1 [1999] 85 L.A.C. (4th)
436 (Hickling); British Columbia and B.C.G.E.U. [2003] 120 L.A.C. (4th) 46 (Germaine);
Hendrickson Spring and United Steelworkers of America, Local 8773 [2006], 151 L.AC. (4th)
245 (Solomatenko); OPSEU (Fabro) and Ministry ofIndustry, Trade &Technology)GSB 1989 -
0755 et al. (Roberts) 1992; Kulpinski v. Toronto Transit Commission [2000] 0.J. No. 169 (SCJ);
Becker Milk Co. and Milk &Bread Drivers, Local 647, [1996] 53 L.A.C. (4th) 420 (Joyce);
OPSEU (Atkins/Taylor) and Ministry of Transportation, GSB 1993 -2035 et al. (Kaufman) 1996;
Thermal Ceramics and U.S.W.A. [1993] 32 L.AC. (4th) 375 (Gray); Toronto (City) and Toronto
Civic Employees Union, Local 416 [2002] CarswellOnt 5139 (Starkman); OPSEU (Richard) and
Ontario Clean Water Agency, GSB 2000 -1220 (Abramsky) 2005.
[4] In summary, counsel argued that the case law was clear that where a grievor puts her
health at issue in a complaint, either where the remedies relate to health or where a grievor has
challenged a termination on the basis of health, then the employer ought to get full and complete
medical disclosure. The arbitration decisions show that fairness and natural justice require that
the employer get all medical information. Counsel also noted in closing that the employer
agreed to the kind of order made in the Richard,supra, to restrict who has access to the medical
documentation. She argued, in the alternative, if I was of the view that the request for medical
information was too broad, the employer sought documentation from April 1,2008 to October
31, 2009.
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Submission of the Complainant
[5] In response to the employer?s motion, counsel for the complainant reserved her right to
respond to the motion that her own letters provided to Dr. Davies be produced. She noted that
this issue had been raised for the first time on the day of the motion and she was not in a position
to argue against it. There was no objection to this by the employer counsel. Thus this decision
will not address the issue.
[6] In response to the motion for production of medical documentation, counsel for the
complainant reviewed the particulars as outlined in Appendix A of the complainant?s application
to the board. She noted that in addition to the complaint of wrongful dismissal, the grievor here
is alleging a breach of the MOS signed February 20, 2007. It is the complainant?s position that
an offer of work in the Western Regional Office made on May 30, 2008 was made in bad faith,
was a breach of the MOS, and lead to the grievor going off on sick leave on June 8, 2008. Her
doctor provided monthly reports to the employer while the grievor was on short term sick leave
through the summer and fall of 2008.
[7] During the fall the complainant attended a college in North Bay at the recommendation of
her psychiatrist, Dr. Davies. When the short term sick leave was about to end, the employer
contacted the complainant, who at that time advised that she was going to school and needed a
leave. Upon learning that the complainant had been attending school and collecting sick benefits
the employer launched a CISU investigation and subsequently terminated her employment.
Counsel submits that it is ironic that when the complainant sought to provide medical
information to the employer before the decision was made to terminate her employment the
employer was not willing to wait for the information.
[8] Counsel?s main argument in opposing the production as requested by the employer was
that it was not arguably relevant. The request went well beyond the subject of the complainant?s
mental health in seeking all her medical information for the period identified and really amounts
to a fishing expedition. Counsel also argued that the medical information should not be
produced until the employer has put in its case, since it has the onus of proof here. She
submitted further that where medical records are sought, particularly psychiatric records, there is
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a higher standard applied than arguable relevance and that the order should not be made until it is
clear that it is necessary. Counsel relied on the following cases in support of her submission:
OPSEU and Ministry of Community Safety and Correctional Services, GSB 2005-2769 et al
(Tims) 2006; Winchester District Memorial Hospital and ONA [1989] 8 L.A.C. (4th) 342
(Bendel); Ministry of Correctional Services and OPSEU [1994] 39 L.A.C. (4th) 205 (Kirkwood);
Keating and Ministry of Community and Correctional Services, PSGB 2005-2315(O?Neil).
Decision
[9] Having carefully considered the submissions of the parties I have decided to grant the
employer?s motion for production of documents in part. I am persuaded that the clinical notes
and all records for the complainant from Dr. Felicity Davies? file, from April 1, 2008 to October
31, 2009 should be produced to the employer. If the complainant was seen by any other
specialist regarding her mental health during the same period, that is, April 1, 2008 to October
31, 2009, then these documents must also be produced. If the complainant was not seen by
another specialist regarding her mental health, counsel for the complainant should advise the
employer forthwith. These documents do not have to be produced before the commencement of
the hearing into this matter at the end of April, but should be produced one month before the start
of the complainant?s defence to the employer?s case. Counsel will be in the best position to
estimate the timeline here. As agreed by the employer, I hereby order that certain conditions, as
imposed in Richards, supra, will apply here. Only counsel for the employer and one advisor
may review the documents. Further, the documents may only be used for the purposes of the
current complaint and no copies may be made of any of the documents.
[10] I am not persuaded that it would be appropriate to order the other documents requested
by the employer, at least at this time. The complainant has put her mental health at issue in this
case and has clearly indicated that her psychiatrist will testify in these proceedings as to the
advice that the complainant should attend school as part of a treatment plan. Thus, the
psychiatrist?s notes and records or other specialist?s notes and records pertaining to the
complainant?s mental health are arguably relevant. While privacy concerns here are still valid, it
is also necessary to balance the employer?s rights to natural justice and a fair hearing.
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[11] In making this decision I have kept in mind this statement from Becker Milk,supra:
In ordering the disclosure of medical records, arbitrators must be sensitive to the fact that such
records may include personal and confidential information. In exercising the required discretion,
the individual?s interest in the non-disclosure of personal and confidential medical information
must be balanced with the policy considerations that suggest that disclosure is useful and
necessary. (p. 428)
In balancing these interests I have decided that the rest of the complainant?s medical information,
at least at this point, is not useful or necessary. To order all of it to be produced would be wrong
in my view. I am persuaded that the notes and records of the complainant?s general practitioner
and the decoded OHIP form are over broad and not warranted. In Richards the GSB ordered a
decoded OHIP form where the grievor?s recollection of doctors that he had seen over the years
regarding his medical issue was not clearly complete. The only way to ascertain this information
was to get the OHIP form. It was arguably relevant and clearly necessary. This is not the case
before me. I am not convinced, as counsel for the employer argued that given the nature of the
case, the complainant cannot be trusted to forward all relevant medical documents relating to her
mental health during the identified period, so that only an OHIP form will satisfy. There is no
evidence to support such a finding.
[12] Thus, for the reasons noted above the employer?s motion is granted in part.
th
Dated at Toronto this 8 day of April 2010.
Deborah J.D. Leighton, Vice-Chair