HomeMy WebLinkAboutP-2021-0715.Gregory.22-07-12 DecisionPublic Service
Grievance Board
Suite 600
180 Dundas St. West
Toronto, Ontario M5G 1Z8
Tel. (416) 326-1388
Commission des
griefs de la fonction
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Tél. : (416) 326-1388
PSGB# 2021-0715
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE OF ONTARIO ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Gregory Complainant
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The Crown in Right of Ontario
(Ministry of the Solicitor General) Employer
BEFORE Allen Ponak Vice Chair
FOR THE
COMPLAINANT
Selwyn A Pieters
Selwyn A Pieters Law Office
Counsel
FOR THE EMPLOYER Paul Meier
Treasury Board Secretariat
Legal Services Branch
Counsel
SUBMISSIONS February 24, 2022; April 6 and 22, 2022
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Decision
ISSUE
[1] Ms. Monique Gregory is a sergeant at the Toronto South Detention Centre
(TSDC) and has been employed by the Ministry of the Solicitor General since 2008. She
is Black and a single mother to a seven-year-old son. Through her lawyer, Mr. Selwyn
Pieters, Ms. Gregory filed a Notice of Proposal to File a Complaint on May 9, 2021,
followed by the complaint itself on June 24, 2021 (Form 1). The complaint alleged
discrimination based on “family status, sex, marital status, race, colour, ancestry, ethnic
origin, and disability” and accused the Ministry of reprisal. Ms. Gregory filed a similar
complaint with the Human Rights Tribunal of Ontario (HRTO) on May 10, 2021.
[2] In its Form 2 response on September 29, 2021, the Employer denied the
allegations and raised a preliminary objection to the timeliness of the complaint. It
argued that the Complainant had failed to meet the time limits set out in Ontario
Regulation 378/07 under the Public Service of Ontario Act (PSOA) and its Regulation
and, therefore, the complaint should be dismissed on that basis.
[3] Following a case management conference call on August 23, 2021, mediation
was held by video conference on November 29, 2021 and January 13, 2022 but the
parties were unable to reach a resolution of the complaint. It was agreed that the
Employer’s preliminary objection would be addressed through written submissions and
this award is devoted exclusively to the Employer’s objection.
CONTEXT AND BACKGROUND
[4] It is useful to briefly set out some basic background facts to provide the context
for the submissions. In the foregoing review, I am relying primarily on the Complainant’s
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Form 1 rendition of events which, for the purposes of this preliminary matter only, I am
accepting as if proven.
[5] The Complainant worked as a correctional officer from 2008 to 2018, became an
acting sergeant in 2018, and was promoted to Institutional Training Manager at the rank
of sergeant in 2019. Her son was born in 2014 and, by 2020, was attending elementary
school with a pre- and post-school day care program. Some scheduling accommodation
was arranged with the Employer to enable the Complainant to drop off and pick up her
son.
[6] On March 11, 2020, the Complainant underwent surgery. A post-operation
assessment, necessary for a return to work, was scheduled for several weeks after the
surgery. Before the assessment could take place, COVID-19 shut down everyday life.
The post-operation assessment was postponed and her son’s day care program was
closed indefinitely. At the time, the severity of the COVID-19 outbreak was unclear nor
was it known how long the COVID-19 outbreak would last or how disruptive it would
prove.
[7] In early July 2020, the Complainant was medically cleared to return to work but
was unable to arrange daycare for her son given the widespread closures of such
facilities. She requested that she be allowed to work remotely as an accommodation but
the request was denied by the Employer on the grounds that operational needs required
that correctional employees physically attend work. Throughout July, the Complainant
was in communication with TSDC senior managers in an attempt to find a solution. At
the end of July, the Complainant emailed the Deputy Solicitor General of Correctional
Services, Ms. Deborah Richardson, outlining her childcare problems and the need for
accommodation and requesting help (Employer Tab C). Neither Ms. Richardson nor a
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designate replied, prompting a second email on September 23, 2020. Again, there was
no proximate response.
[8] In October and November 2020, the Complainant emailed Prime Minister
Trudeau, Premier Ford, the offices of several cabinet ministers, and her Toronto city
councillor about her situation and the absence of daycare. The Complainant received a
reply from Ms. Karen Ellis, the Ontario Assistant Deputy Minister, Institutional Services,
in late November 2020 advising her to address her concerns to senior TSDC officials
(Employer Tab D).
[9] In the meantime, the Complainant’s family doctor had declared her unfit to work
due to the physical manifestations of intense stress on July 31, 2020. Subsequent
medical notes confirmed her inability to return to work. She was placed on sick leave
which reverted to unpaid leave in October 2020 when her sick leave credits ran out. The
Complainant then successfully applied for Employment Insurance until her entitlement
ran out in March 2021. In April 2021, the Complainant’s doctor advised against the
Grievor returning to the TSDC because the “toxic work environment” contributed to her
stress. The Complainant remains off work as of the date of the award.
[10] In addition to the issues surrounding childcare, accommodation, and the
Complainant’s medical fitness to work at TSDC, the Complainant has asserted that her
alleged mistreatment by the Employer is motivated by race. The complaint identified a
number of Caucasian employees who, over the years, purportedly received favourable
treatment by being accommodated for family, religious, and other reasons. In contrast,
the Complainant alleged that her requests for accommodation were treated
dismissively, demonstrating disparate treatment of a Black woman.
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[11] As a remedy, the Complainant sought placement within a suitable position
outside TSDC, compensation for lost wages and benefits, aggravated damages for
discriminatory treatment, damages for violation of her Charter rights, and
reimbursement of legal fees.
EMPLOYER ARGUMENT
[12] The Employer argued that the timelines for filing a complaint under the PSOA
and its Regulations are mandatory. Failure to adhere to the timelines must result in the
Board determining that it lacks jurisdiction to address the merits of the complaint and
therefore the complaint must be dismissed. The Employer cited the following PSGB
decisions in support of the mandatory nature of the timelines and the implications of
failure to meet those timelines: Morris and Ontario Ministry of Community Safety and
Correctional Services (2018) CarswellOnt 9734 (Nairn, PSGB) and Taylor and Ontario
Ministry of the Solicitor General (2020) CarswellOnt 6504 (Morgan, PSGB).
[13] According to the Employer, the clock for filing a complaint begins within “14 days
after the complainant becomes aware of the working condition or term of employment
giving rise to the complaint” (Regulation 378/07, section 8(4)(3)). The complaint was
filed on June 24, 2021. In the Employer’s submission, the filing was almost a year too
late. In its view, the Complainant’s request to work from home because of childcare
issues was raised and denied in July 2020 and the Complainant had been advised by
several levels of managers that she must report to work. As part of the communication,
suggestions about childcare options and scheduling options were provided by several
managers. The Complainant was dissatisfied with the responses and emailed Deputy
Solicitor General Richardson on July 29, 2020, outlining the substance of her complaint
(Form 1, paragraphs 111-112, Employer Tab C). It was clear, the Employer submitted,
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that by the end of July 2020 the Complainant was well aware of the issues giving rise to
her complaint. The 14-day clock began ticking at that time.
[14] The Employer further pointed out that, contrary to the procedural requirements,
the Complainant did not give the Deputy a Notice of a Proposal to File a Complaint or
seek a dispute resolution meeting within 30 days, as should have occurred following the
crystallization of the issues at the end of July 2020. The Notice of Proposal to File a
Complaint was not in fact provided until May 10, 2021. Even if the Complainant’s email
of July 29, 2020 could be considered “constructive notice”, which the Employer
disputed, nothing further was done until almost a year later notwithstanding the reply
from Assistant Deputy Minister Ellis on November 25, 2020 in which the ADM indicated
that the matter had been fully addressed by TDSC management and made it clear that
her office would not intervene (Employer Tab D).
[15] For these reasons, the Employer submitted that its preliminary objection must be
sustained, a declaration made that the Board lacked jurisdiction to address the merits,
and the complaint dismissed as untimely. In support of its position, the Employer cited
the following additional cases: Paul and Ontario (Ministry of the Solicitor General) 2021
CanLII 26625 (Tremayne, PSGB); Ashdown and Ontario (Ministry of Community Safety
and Correctional Services) 2017 CanLII 25422 (Nairn, PSGB); Hamilton and Ontario
(Ministry of Community Safety and Correctional Services) 2019 CanLII 42439
(Tremayne, PSGB); and, Bazger and Ontario (Ministry of the Solicitor General) 2021
CanLII 71621 (Smeenk, PSGB).
COMPLAINANT ARGUMENT
[16] The Complainant advanced several arguments as to why the complaint should
not be barred by any alleged timeliness violations. One argument related to the implicit
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obligations of Deputy Solicitor General Richardson after the Complainant emailed her
on July 29, 2020 outlining the issues in detail and seeking assistance. It was submitted
that the email should have been accepted as a constructive “Notice of Proposal to File a
Complaint” and that Deputy Solicitor General Richardson had failed to appropriately
advise the Complainant how to address the matter through the PSGB. The Complainant
elaborated as follows (Complainant brief, paragraphs 17 – 19):
The Deputy Solicitor General was in a position to appreciate that this complaint was a matter for
the PSGB and to take action accordingly, including advising Ms. Gregory to pursue such a
remedy. Instead, Ms. Gregory’s concerns were substantially ignored.
It is therefore submitted that the timeliness issue raised by the Employer is without grounds, the
Employer having been substantially and constructively notified of the complaint at least as early
as July 29, 2020.
Moreover, it is submitted that it would be neither fair nor just for Ms. Gregory’s claim to be barred
on the basis of delay of her Application following the giving of constructive notice, bearing in mind
the Employer’s consistent lack of transparency and refusal to provide an accommodation nor aid
as to the process, despite having been notified of the complaint.
[17] A second argument alleged waiver by the Employer. This position was based on
the agreement by the Employer to engage in two mediation sessions and to defer a
response to the HRTO complaint. In the Complainant’s view, these steps signified that
the Employer accepted the jurisdiction of the Board to arbitrate the merits of the PSGB
complaint.
[18] The Complainant’s main argument, however, was that even if the Board
concluded that the complaint was untimely, it could not be barred by the statutory
timeline requirements under the PSOA and its Regulations because the complaint was
grounded in the Charter of Rights and Freedoms. The Complainant reasoned as follows
(Complainant brief, paragraphs 20 – 25):
The Ontario Court of Appeal has held that Charter claims against state actors should not be
subject to the same statutory or regulatory limitations rules as other claims, being grounded in
fundamental constitutional rights which the state cannot escape by creating statutory timelines.
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Prete v. Ontario (1993), 18 C.C.L.T. (2d) 54, 18 C.R.R. (2d) 291, 16 O.R. (3d) 161 (Ont. C.A.)
leave to appeal to Supreme Court of Canada refused 110 D.L.R. (4th) vii, 87 C.C.C. (3d) vi, 20
C.C.L.T. (2d) 319 dealt with an action for Charter damages under ss. 7 and 24(1) following an
unsuccessful prosecution for murder. The case raised the issue of whether a Charter action
under s. 24(1) could be barred by the relevant limitations period, in that case, a six-month
limitation period contained in section 11(1) of the Public Authorities Protection Act.
The Court, in holding that the claim could not be so barred, based its analysis on reasoning which
applies to all limitation periods. Essentially, the Court concluded that a judge at trial should be
able to decide if a case is brought too late for pursuing a Charter remedy rather than by applying
a statutory limitation period.
The Court, citing Lamer J in Nelles v. Ontario, [1989] 2 S.C.R. 170, explained at para. 6 that "a
statutory enactment cannot stand in the way of a constitutional entitlement" and further stated at
para. 13, “The purpose of the Charter, in so far as it controls excesses by governments, is not at
all served by permitting those same governments to decide when they would like to be free of
those controls and put their houses in order without further threat of complaint.”
Accordingly, the Court concluded that both section 5(6) of the Proceedings Against the Crown Act
and section 11 of the Public Authorities Protection Act had no application in a Charter
infringement case. However, while the case pertained to these specific statutory provisions, it is
clear from the Court’s reasoning that the issue before the Court was a broad one, being "the
present consideration of statutory limitations to be imposed on a Charter remedy" in general.
The holding in Prete therefore establishes that statutory limitations periods do not per se bar
claims for damages under the Charter. Prete remains good law in Ontario and has not been
overturned, with leave to appeal refused by the Supreme Court of Canada. The Complainant’s
claim is such a case, and is therefore not barred by ss. 10(1) or 8(4)(3) of Regulation 378/07
made under the Public Service of Ontario Act as asserted by the Employer. There is no reason
why a limit on the time to file such complaint should bar a Charter infringement complaint any
more than a limitation period should bar an action.
[19] In advancing this argument, the Complainant pointed to the broad and important
social issues being raised by the complaint – anti-Black racism, family status
accommodation, and the intersection of race and gender. These are issues, it was
submitted, that are central to Canada’s evolution as a just society and the right to have
these matters adjudicated should not be stymied by a mere technicality. The
Complainant elaborated (Complainant brief, paragraphs 35 & 36):
Ms. Gregory has alleged that the treatment of her case was informed by anti-Black racism,
implicit bias and/or racial stereotyping. The jurisdictional issue asserted by the Employer should
not be allowed to function as a means to foreclose her ability to challenge the discrimination she
has experienced, thereby helping to see that anti-Black racism be “confronted, mitigated and,
ultimately, erased…” as called for in Morris. In such cases, where the Charter is being invoked, a
full hearing of all relevant, necessary evidence to illuminate the facts of the case becomes even
more crucial than it may otherwise be.
In all of this, access to justice is key. The Supreme Court have recognized that ensuring “access
to justice is the greatest challenge to the rule of law in Canada today.” (Hryniak v. Maudlin, 2014
SCC 7)
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[20] The Complainant acknowledged that a human rights complaint on the same
matters had been filed with the HRTO but took the position that the PSGB remained the
most appropriate forum for the complaint given the PSGB’s central role in addressing
public service work disputes and the specialized expertise of its adjudicators on
precisely the kind of issues being raised in the complaint. This type of expertise had
been recognized by Ontario courts: Rivers v. Waterloo Regional Police Services Board
(2019) ONCA 267; and, Donovan v. Waterloo (Police Services Board) 2022 ONCA 199.
[21] In short, the Complainant urged the Board to find that there was no jurisdictional
bar to hearing and ruling on the merits, characterizing the Employer’s position as
unreasonable and unjust.
EMPLOYER REPLY
[22] The Employer responded that the Charter does not operate to enable arbitrators
to ignore statutorily established mandatory timelines. It accepted that PSGB arbitrators
may have the authority to apply Charter values as appropriate to the merits of a case
over which the arbitrator has jurisdiction but submitted that the Charter values could not
be applied to confer jurisdiction where none existed – “if the Regulation’s mandatory
timelines are not met, the PSGB is without jurisdiction to entertain the complaint”
(Employer reply, paragraph 5). In the Employer’s submission, conforming to the
timelines was a precondition to the PSGB assuming jurisdiction. Once jurisdiction was
confirmed, only then, the Employer argued, could the complaint be examined in light of
the Charter. In the current case, the Complainant had failed to meet the time
requirements for filing her complain leaving the Board without jurisdiction to consider the
merits of the complaint, whether through a Charter lens or based on other criteria. The
Employer cited St. Amant v. Ontario (Ministry of Community Safety and Correctional
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Services), 2013 CarswellOnt 1025 (Carter, PSGB) for the proposition that failure of a
complainant to comply with the mandatory timelines left the Board without jurisdiction.
[23] Citing section 24(1) of the Charter, the Employer emphasized that anyone
alleging a violation of Charter rights had the ability to apply to “a court of competent
jurisdiction” to obtain an appropriate remedy. This meant, according to the Employer,
that only if a court or tribunal’s jurisdiction could be established could Charter values be
considered. The Employer cited several court decisions in support of the proposition
that the Charter could not confer jurisdiction where none existed: R v. Mills [1986] 1
SCR 863; R v. Conway [2010] SCC 22; and, Ontario v. 974649 Ontario Inc. [2001] SCC
81. The Employer argued, in short, that the Charter “does not operate to expand the
PSGB’s pre-existing statutory jurisdiction, fixed by the Legislature, and does not imbue
the Board “with the power to alter the jurisdictional consequences” of a failure to comply
with Regulation’s mandatory timelines” (Employer reply, paragraph 23).
[24] The Employer submitted that the Ontario Court of Appeal’s decision in Prete,
relied on by the Complainant as a basis for overcoming of the PSGB’s statutory time
limits in Charter cases, was distinguishable. In its submission, Prete turned on the
inherent jurisdiction of the provincial court in the matter before it and could apply
equitable principles (in that case, the doctrine of laches) to overcome statutory
guidelines. In contrast, the Employer argued, the Board had no inherent jurisdiction “and
must stay within the limits derived from its enabling statute”, the PSOA (Employer reply,
paragraph, 29). The PSGB had no jurisdiction, in the Employer’s view, to alter the
statutory time limits. Furthermore, according to the Employer, a more recent decision of
the Ontario Court of Appeal (Alexis v. Darnley, 2009, ONCA 847) expressly suggests
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that Prete “has been overtaken” and that it no longer can provide a basis, if it ever did,
for overturning statutory or regulatory time limits (Employer reply, paragraph 33).
[25] Finally, the Employer rejected the other arguments advanced by the
Complainant. It noted that in agreeing to mediation, the Employer had expressly
reserved the right to advance its preliminary position on timeliness and this position had
been well known, and documented, when mediation had been undertaken. There had
been no waiver. The fact that the Complainant’s HRTO case had been deferred pending
mediation could not alter that fact. With respect to the view that the PSGB is the best
forum for the merits of the complaint, there is no basis in law, the Employer contended,
to use that fact, even if true, to claim jurisdiction. The Employer noted that the
Complainant still had a human rights complaint that she could pursue, but even if none
had been filed, the fact that the PSGB was an appropriate forum could not somehow
serve as platform to create jurisdiction.
[26] The Employer reiterated its request that the complaint be rejected as being out of
time.
TIME LIMITS UNDER PSAO REGULATION 378/07
Section 8(4)(3)
For a complaint about a working condition or a term of employment, within 14 days after
the complainant becomes aware of the working condition or term of employment giving
rise to the complaint.
Period for dispute resolution
9(1) A complainant is not entitled to file a complaint with the Public Service Grievance Board
until the expiry of the period provided under this section for dispute resolution.
…
9(5) If the deputy minister or chair of the Public Service Commission, as the case may be, or
his or her designate does not meet with the complainant within 30 days after receiving the
notice, the period provided for dispute resolution expires after the notice was given to the
deputy minister or chair.
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10(1) Within 14 days after the expiry of the period, if any, provided for dispute resolution
under Section 9, the complainant may file the complaint with the Public Service Grievance
Board by delivering it to the chair of the Board.
DECISION
[27] I am sympathetic to the Complainant’s circumstances but nevertheless have no
choice but to conclude that I lack jurisdiction to hear and decide the merits of her
complaint. The complaint was filed out of time and the PSAO does not allow PSGB
adjudicators the discretionary authority to waive timelines as do some labour relations
statutes (including the Ontario Labour Relations Act). For reasons set out below, neither
the Charter argument nor any of the other arguments advanced by the Complainant
allow me to conclude that the timelines under which the PSGB operates should not
apply.
[28] I begin by asking when did the 14-day clock start with respect to the current
complaint. The complaint alleges that the Complainant has been subject to
discrimination based on family status, mental health, and race, colour, ancestry, and
ethnic origin. The starting point is the date the complainant “becomes aware of the
working condition or term of employment giving rise to the complaint” (Regulation,
section 8(4)(3)). Throughout spring and early summer 2020, the Complainant
communicated her concerns, particularly related to childcare and her recovery from
surgery, with TSDC management. Dissatisfied with the responses she was receiving,
the Complainant then emailed Deputy Solicitor General Richardson on July 29, 2020
(Employer document C). In the email, the Complainant outlined her struggles with the
aftermath of the surgery, childcare challenges, her need for accommodation, and the
impact of these matters on her mental and physical health. Given her childcare needs,
she wished to work remotely and her managers consistently rejected this proposal.
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From my own reading of this email, I am satisfied that as of July 29, 2020 the
Complainant was aware of the working conditions and terms of employment that form
the essence of her complaint. The Notice of Proposal to File a Complaint was not filed
until May 10, 2021 and the complaint was not filed until June 24, 2021. Thus, if the clock
started July 29, 2020, the complaint is untimely by more than 9 months.
[29] I am aware that the Complainant did not receive a reply to her July 29th email
from Ms. Richardson (or her surrogate) until November 24, 2020 when a response was
received from Assistant Deputy Minister Ellis (Employer document D). Ms. Ellis advised
the Complainant that her concerns were to be addressed through senior management
at TSDC. Even if I accepted 1 that it was not until the letter from Ms. Ellis that the
Complainant’s knowledge crystallized that her working condition and terms of
employment concerns would not be addressed by officials more senior than TSDC
management, the complaint is still untimely. If the 14-day clock started on November
24, 2020, it was still many months before the Notice of Proposal and formal application
were filed. This remains true even if the Complainant’s letter to Ms. Richardson on July
29, 2020 can be characterized as “constructive Notice of Proposal to File a Complaint”2
because 30 days following such notice, if no reply is received, the clock for formally
filing a complaint resumes under section 9(5) of the Regulation.
[30] Accordingly, whether July 29, 2020 or November 24, 2020 is the starting point, or
the July 29th letter can be construed as a constructive Notice of Proposal, the complaint
was filed out of time. The PSGB case law is unambiguous that the statutory time limits
are mandatory and that the failure to file a complaint within the specified time limits
1 It is unnecessary for me to determine whether the 14-day clock started on July 29, 2020 or November 24, 2020 as
the outcome is the same.
2 For the same reasons indicated in the previous email, it is unnecessary for me to make a ruling as to whether the
July 29, 2020 letter amounts to constructive notice.
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leaves the adjudicator without jurisdiction over the merits of the complaint. In decision
after decision, adjudicators have concluded that the Board has “no discretion to extend
the time lines, regardless of the validity, importance or controversial nature of the
complaint” or how “reasonable or sympathetic” might be the reasons for not meeting the
time limits (Bazger, paragraphs 27 & 29). As stated by Vice-Chair Tremayne in Paul, “if
the notice is filed outside of that time limit, the Board is without jurisdiction to deal with
the complaint” (paragraph 46). The Complainant was unable to point to any case law
that suggested a different result from failure to meet the timelines set out in the PSAO
and its regulations. On its face, therefore, I must conclude that I lack jurisdiction to
address the merits of the current complaint.
[31] This does not end the matter, however, as the Complainant advanced several
arguments as to why, even if I determined that the mandatory timelines were violated, I
should still find that I did have jurisdiction over the merits. Before turning to the primary
submission based on the Charter, I will address three ancillary positions.
[32] First, the Complainant argued that Ms. Richardson ought to have advised the
Complainant to seek a remedy through the PSGB when she received the July 29, 2020
email from the Complainant asking for help. It was pointed out that no such advice was
given and there was no reply to the email for almost four months. I share the
Complainant’s dismay at the length of time for a reply (even accepting the disruptive
impact of the initial months of COVID) nor do I disagree that a prompt response along
with information about the PSGB complaint process would have been desirable in the
circumstances. The Complainant’s email was a cry for help that was ignored.3
3 In making these statements I am accepting for purposes of the preliminary submission only that no one from senior
management reached out to the Complainant and drew her attention to the PSGB complaint process. If the evidence
would have proved otherwise, this would lead to very different inferences about the senior management response.
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[33] That said, I find nothing in the PSAO, the Regulations, or case law that requires
senior officials to draw the PSGB complaint system, with its time limits, to the attention
of eligible employees who may have an employment related concern. While there was
no submissions or evidence on this point, I am satisfied that ultimately it is up to
employees who wish to file complaints to know the rules or educate themselves about
the rules. The complaint system is not a secret and information was available on the
PSGB website, including information about the mandatory time limits. The fact that Ms.
Richardson (or others) did not direct the Complainant to the PSGB complaint process
does not provide a basis for disregarding the complaint process time limits.
[34] A second position advanced by the Complainant is that the Employer had waived
any timeliness or procedural defects in the complaint process by agreeing to mediation
on the merits of the complaint. I reject this position as it was made abundantly clear at
the time by the Employer that, in agreeing to mediation, it retained the right to pursue its
preliminary objection on timeliness that it had initially raised in its Form 2 response to
the complaint. This is clear from the discussions that occurred at the time the parties
agreed to mediate and is reflected in a summary email from me that was sent to the
Complainant and counsel following a case management conference call on August 23,
2021. In the email, I wrote that the “Employer has served notice that it has a preliminary
objection based on the timeliness of the complaint. Should mediation not result in a full
settlement of the dispute, the Employer intends to argue that the arbitrator lacks
jurisdiction to address the merits of the complaint because the complaint was filed too
late” (Employer document D). No response was received from the Complainant or her
counsel objecting to these terms under which mediation was undertaken on November
29, 2021 and January 13, 2022. There is absolutely no basis for the claim that the
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Employer waived its right to make a preliminary objection on timeliness by participating
in mediation over the merits of the complaint. I add that if such a position prevailed, that
would effectively end the mediation of the merits of many labour and employment
disputes.
[35] Third, it was submitted that upholding the Employer’s timeliness objection would
deprive the Complainant of having the merits of her case heard before the PSGB, the
tribunal created for the express purpose of adjudicating such disputes and with unique
expertise on such matters. It may well be that the PSGB is the ideal forum for
adjudicating the Complainant’s allegations but that fact, in and of itself, is insufficient to
overcome an untimely application. In creating the PSGB, the legislative and regulatory
scheme places tight windows on when complaints could be filed. Whether or not the
PSGB is the ideal forum for the current complaint cannot create a basis for overturning
the regulatory time limits.
[36] I now turn to the heart of the Complainant’s submission, the argument that
upholding the time limits is contrary to the Charter of Rights and Freedoms. The
essence of this position is that because the complaint raises discrimination issues
protected by the Charter and lies at the intersection of gender and race, statutory time
limits must be set aside in order to allow these critical Charter issues to be addressed.
Denying the Complainant the right to have her case heard by the PSGB would have the
effect of denying her Charter rights, a result contrary to the basic underpinning of
Canadian constitutional law. In advancing this position, the Complainant relies primarily
on Prete, a 1993 decision of the Ontario Court of Appeal.
[37] There is no question that discrimination in all its manifestations is abhorrent. I
accept that effectively rooting out discrimination remains an elusive goal and, as
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demonstrated by the submissions of the Complainant, racialized communities continue
to suffer the consequences of discrimination. Governments at all levels have made the
stamping out of discrimination, whether systemic or overt, an essential objective. The
Charter, in cases where it applies, is one tool towards helping to achieve this objective.
With these observations as a context, I now turn to Prete.
[38] Prete arises from a criminal case in which the plaintiff filed a claim against the
Crown for alleged malicious prosecution and sought section 24(1) Charter remedies.
The claim was filed some 18 months after the plaintiff had been acquitted of murder by
a jury. The Public Authorities Protection Act (“PAPA”) contained a six month time limit
for filing such claims and a lower court ruled that the plaintiff was barred by the PAPA
time limits from pursuing his claim. The Court of Appeal disagreed. Citing Nelles v.
Ontario [1989] 2 SCR 170, the court determined that Charter remedies arising from a
common law cause of action provided the right to access to a court of competent
jurisdiction. It elaborated as follows (paragraph 8):
The reasons of Lamer J., standing alone, are strongly persuasive that a statutory enactment
cannot stand in the way of a constitutional entitlement. Section 32(1)(b) of the Charter provides
that the Charter applies to the legislature and government of each province. The remedy section
of the Charter would be emasculated if the provincial government, as one of the very powers the
Charter seeks to control, could declare itself immune.
The Court of Appeal then found that PAPA “should be read as not applying to relief
claimed under s. 24(1) of the Charter” noting that there is “no valid comparison between
procedural rules of court and statutory limitation periods” (paragraph 14). On the basis
of Prete, the Complainant has submitted that the time limits under the PSAO and its
regulations cannot bar the Board from addressing the merits of her claim, raising as it
does section 24(1) Charter remedies.
[39] The Employer disagrees that Prete opens the door to ignoring the regulatory time
limits for filing complaints embedded in the PSAO, citing Alexis, a 2009 Ontario Court of
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Appeal decision that, in its view, supersedes Prete. Also a case arising from criminal
law, Alexis involves a s. 24(1) Charter claim by the plaintiff that she was unlawfully
detained by police and a physician under the Mental Health Act. Her claim was filed
more than two years after the event and a lower judge dismissed the claim on the
grounds that the two year statutory filing period under the Ontario Limitations Act (which
had replaced PAPA) had been exceeded.
[40] The Court of Appeal upheld the lower court ruling that Prete does not support the
“far broader proposition that s. 24(1) claims, brought by an individual and seeking
personal remedies, cannot be subject to any statutory limitation period” (paragraph 15).
The Court reviewed how courts elsewhere in Canada, including the Supreme Court of
Canada, had followed or distinguished Prete and concluded that “the Supreme Court’s
reasons4 clearly signal that the limitation periods of general application apply to claims
made under s. 24(1) of the Charter that are ’brought as an individual as a personal
remedy’” (paragraph 17). In particular, it wrote (paragraph 16):
……Prete has been distinguished by courts of other jurisdictions on the basis that the six month
limitation period being addressed was an exception to the six year limitation period of general
application that was available only to the Crown. This more favourable treatment of the
government by the government was, with respect to Charter claims, found to be unfair.
[41] The Court then went on to describe Prete “as standing for the proposition that the
Crown cannot insulate itself from s. 24(1) claims through uniquely short limitation
periods” (paragraph 19). It concluded that because PAPA had been repealed and
replaced by the Limitations Act that did not contain uniquely short time limits, but rather
contained time limits consistent with norms elsewhere, the time limits were enforceable
even for s. 24(1) claims. The Court reasoned as follows (paragraphs 21 & 22):
A plain reading of the Limitations Act makes it apparent that, in adopting the new Limitations Act,
the legislature intended that the 2 year limitation would apply to claims brought as an individual
4 Kingstreet Investment Ltd. v. New Brunswick (Department of Finance) [2007] 1 SCR 3
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for personal remedy under s. 24(1). Section 4 states that "Unless this Act provides otherwise, a
proceeding shall not be commenced in respect of a claim after the second anniversary of the day
on which the claim was discovered." The exclusions set out in the Act are listed in ss. 2 and 16.
Among the exceptions is a class of constitutional claims. Section 2(1)(e) excludes claims based
on aboriginal and treaty rights recognized and affirmed in s. 35 of the Constitution Act, 1982.
There is however no exclusion for claims brought under s. 24(1) of the Charter, and certainly
none such as the one brought by the appellant as an individual claim for a personal remedy. It is
apparent in my view that, at a minimum, the Act was intended to apply to such claims. Nothing in
the statute or in the legislative debates surrounding the adoption of the Act suggests otherwise.
In conclusion, therefore, I agree with the motion judge that the Limitations Act applies to claims
such as the one advanced by the appellant. No challenge to the constitutionality of the Limitations
Act was brought and I do not accede to the appellant's submission that the Prete decision
renders any statutory limitation period inapplicable to Charter claims brought as an individual for
personal remedies until specifically overruled by this court. Once the Public Authorities Protection
Act limitation was repealed and the new Limitations Act was adopted, Prete, in my view, was
overtaken.
[42] How do Prete and Alexis apply to the current case? First, there is little question
that the time limits in the PSAO and its regulations are very short. Once an employee
has knowledge of the working condition or term of employment giving rise to the
complaint, filing must occur within 14 days. While this type of time limit may appear out
of the norm and could fit the bill as a “uniquely favourable treatment by the government
for the government” that was criticized in both Prete and Alexis, short time limits are
common in a labour relations context. Most collective agreements contain limits for the
filing of grievances or taking disciplinary action and these limits may be a short as 10
days and are frequently mandatory. The cases are legion in which arbitrators have
upheld preliminary objections for failure to file a grievance within the specified time limit,
even in cases of discharge and alleged discrimination, or have overturned disciplinary
action by an employer because time limits for imposing discipline had been violated. I
am satisfied that viewed through the lens of commonplace labour relations practices a
14-day period for filing a complaint, while on the shorter end of the continuum, does not
run afoul of the principles set out in Prete and Alexis.
[43] In reaching this conclusion, I am cognizant that many, but not all, provincial
labour relations statutes and the federal Canada Labour Code give arbitrators the
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discretion to waive time limits. Criteria, both specified in the statute or developed
through case law, include duration and explanation for the delay and prejudice if the
out-of-time matter is allowed to proceed on its merits. The PSAO and its Regulation do
not offer such discretion to PSGB adjudicators; this might be seen as an attempt to treat
the government more favourably under the PSAO than is true elsewhere. There are in
fact no time limit exceptions under the PSAO and its regulations for Charter issues or
any other matters. At the same time, not all provincial labour relations statutes provide
the discretion to adjudicators to waive time limits – if such discretion was a universal
principle there might be firmer footing for determining that the mandatory time limit in
the PSAO is an unreasonable outlier that cannot stand. But that is not the case.
Furthermore, the Limitations Act also does not establish time limit exceptions for section
24(1) Charter claims. Thus, the lack of time limit exception for section 24(1) issues
under the PSAO is not inconsistent with the Limitations Act. Bearing in mind the Ontario
Court of Appeal’s conclusion in Alexis that “I do not accede to the appellant's
submission that the Prete decision renders any statutory limitation period inapplicable to
Charter claims” I conclude that there is an insufficient basis for setting aside the PSAO
time limits and addressing the merits of the current complaint. I simply lack the grounds
for accepting jurisdiction.
[44] I take no pleasure in reaching this conclusion. As pointed out by the
Complainant, this case raises important issues about family status and the intersection
of race and gender. There is little doubt that the Complainant was faced with daunting
personal challenges as a single parent during COVID who had just undergone surgery
for a serious illness. Addressing the merits would have permitted an assessment
through evidence of whether the Employer’s duty to accommodate had been met,
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whether being physically present at work was a BFOR, whether the Complainant had
met threshold requirements of establishing family status or other discrimination
allegations, whether management’s response to her claims was unduly unsympathetic,
and whether any improper motives may have impacted decisionmakers. Unfortunately, I
cannot address any of these important matters.
AWARD
[45] The Employer’s preliminary objection is sustained. I conclude that the complaint
is untimely under the PSAO and its Regulations. Accordingly, I lack the jurisdiction to
address the merits of the complaint and must dismiss the complaint.
Dated at Toronto, Ontario this 12th day of July, 2022.
“Allen Ponak”
________________________
Allen Ponak, Vice-Chair