HomeMy WebLinkAbout2020-2914.Mohamed.22-11-10 Decision
Crown Employees
Grievance Settlement
Board
Suite 600
180 Dundas St. West
Toronto, Ontario M5G 1Z8
Tel. (416) 326-1388
Commission de
règlement des griefs
des employés de la
Couronne
Bureau 600
180, rue Dundas Ouest
Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
GSB# 2020-2914
UNION# 2021-0526-0002
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Mohamed) Union
- and -
The Crown in Right of Ontario
(Ministry of the Attorney General) Employer
BEFORE Dale Hewat Arbitrator
FOR THE UNION Adam Veenendaal
Morrison Watts
Counsel
FOR THE EMPLOYER Regina Wong
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING September 28, 2022
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Decision
[1] This case involves a Grievance filed on February 5, 2021 in which the Grievor
claimed that he had been terminated on January 21, 2021 from his employment
without just cause, willfully and in bad faith. The Grievance also alleged that the
Employer violated the Collective Agreement, including but not limited to, Articles
2, 3 and 24, the Employment Standards Act, Ontario Humans Right Code,
Occupational Health and Safety Act and any related employment statute or
principle in law that may apply including any related employment policy. In terms
of remedy, the Grievor sought reinstatement of his employment and to be made
whole including reimbursement of all lost earnings, compensation and benefits
and any other remedy deemed appropriate by an arbitrator or by the Board.
[2] The Grievor was subsequently reinstated to his position on February 22, 2021
but did not attend work. On March 31, 2021, the Grievor was again terminated
from his employment due to abandonment. He did not file a grievance in
response to the March 31, 2021 termination of his employment.
[3] The parties attended a hearing on September 28, 2022 in which the Employer
brought motions asking me to dismiss this case because the facts set out in the
Union’s revised particulars, dated August 29, 2022, do not establish a prima facie
case of discrimination on the basis or race, ethnicity, and disability. In addition,
the Employer maintains that, without the Union establishing proof of the
allegations of discrimination, this Grievance is moot, and should be dismissed
because the Grievor was reinstated to his position on February 22, 2021 and
failed to file a grievance when he was terminated for abandonment on March 31,
2021. As a result, the Employer states that there are no outstanding issues for
me to consider. Should I not uphold the motions to dismiss, the Employer asks
me to conclude that some of the Union’s revised particulars expand the scope of
the Grievance and therefore should be struck and not form part of this case.
[4] For the reasons set out below, I have determined that the facts raised in the
Union’s revised particulars do not establish a prima facie case of discrimination
based on either race, ethnicity, or disability. Because I have found that there are
no human rights issues to be considered, I have also concluded that this case is
moot because the remedy of reinstatement has been met. Given that I am
dismissing the Grievance, I have not dealt with the parties’ submissions about
expansion of scope.
Background Overview
[5] Prior to reviewing the Employer’s motions and the Union’s response, it is helpful
to outline some of the facts and timelines in this case so that the motions can be
viewed in context. The following is a summary of the Employer’s particulars in
this case, recognizing that some of the facts are not agreed to by the Union.
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[6] The Grievor began his employment with the Ministry of the Attorney General in or
around 1991. 2. He became a Category 2 Flexible Part-Time (“FPT”) Court
Service Officer (“CSO”) in or around 1998, and largely held this position until the
Employer terminated his employment on or about January 21, 2021. The
purpose of the CSO position is to provide support to presiding judiciary, maintain
court decorum, direct stakeholders, clients, jurors, and members of the public
and to provide support to the overall administration of the court. The duties of a
CSO may include completing administrative duties that contribute to the progress
of cases in the court system from beginning to conclusion, and other duties as
assigned.
[7] Prior to the onset of COVID-19, the Grievor was primarily assigned courtroom
duties as a CSO. With the onset of the COVID-19 pandemic provincial state of
emergency, many courthouses, including the Toronto Courthouse, where the
Grievor worked, suspended physical court operations, except for emergency
matters, between March 17, 2020 and July 6, 2020. As a result, CSOs were
generally not required to perform any duties during this period.
[8] On July 6, 2020, the Toronto Courthouse began a phased re-opening of in-court
operations, including both in-person and Zoom hearings. The Toronto
Courthouse scheduled Client Service Representatives (“CSRs”) and Registrars
to run Zoom hearings, not CSOs. As such, CSOs were only scheduled for in-
person hearings, and consequently were not receive the training to run Zoom
hearings.
[9] In order to permit CSOs to meet their minimum daily requirements of 5.75 hours,
the Toronto Courthouse assigned all CSOs who were not in court, including the
Grievor, to administrative duties. Alternatively, CSOs had the option of requesting
vacation or requesting a leave without pay, subject to operational requirements.
In late November and December 2020, due to the deterioration of the public
health situation in Toronto, the judiciary strongly encouraged the use of virtual
hearings wherever possible. As a result, the number of in-person hearings
decreased, and consequently many CSOs were assigned administrative duties.
[10] Beginning in early December 2020, the Grievor attended at work and at times,
when no courtroom work was scheduled, he was asked by his manager to
perform some administrative duties including filing work. The Grievor took issue
with performing administrative duties and told his manager on December 14,
2020 that he would not come to work unless he was assigned courtroom duties.
On December 14, 2020, the Grievor left the workplace despite being assigned
courtroom duties at 2 p.m. that day.
[11] Between December 14, 2020 and January 21, 2021, the Grievor did not attend
work when scheduled. Further, after refusing to confirm his conversation with Ms.
Seeraj by email on December 16, 2020, the Grievor did not call into the call-in
line, or communicate with the Employer by phone, email, mail, or any other
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means. As such, the Grievor had been absent from the workplace since
December 14, 2020 without authorized leave.
[12] The Employer sent 2 emails and letters plus tried to contact the Grievor by
phone, on December 22, 2020 and again on January 6, 2021 to seek an
explanation for his absences. The Grievor was provided with a final opportunity
to contact management and explain his absence by January 20, 2021. If the
Grievor did not comply with the deadline, he was advised he would be deemed to
have abandoned his position pursuant to s.42 of the PSOA. Unfortunately, the
January 6, 2021 letter was returned to the Employer as undeliverable. Once the
letter was returned it was re-sent to the Grievor by regular mail.
[13] On January 18, 2021, the Employer sent a letter to the Grievor by email and by
regular mail to the Grievor’s home address on file. In this letter, the Grievor was
again reminded that he had a final opportunity to contact the Employer to provide
a sufficient explanation for his absence or return to work by January 20, 2021,
failing which he would be deemed to have abandoned his position.
[14] Having received no response from the Grievor to any of the communications sent
to him, a letter of abandonment was sent to him by email and regular mail
declaring in accordance with s.42 of the PSOA that the Grievor abandoned his
position with the Ontario Public Service, and this his employment was terminated
effective January 21, 2021.
[15] On January 22, 2021 the Grievor contacted the Employer and requested a
meeting about the January 21, 2021 letter he received. On January 26, 2021, the
Employer met with the Grievor and a Union representative during which it was
discovered that the manager had been sending emails to the wrong email
address. Following this meeting the Grievor filed the grievance referred to in
paragraph 1 of this decision.
[16] On February 22, 2021, the Employer provided a letter to the Grievor, without
precedent and prejudice to its decision to declare his position abandoned or any
position it would take with respect to his grievance, that he was reinstated to his
position as CSO. The Employer also informed the Grievor that the periods
between December 14, 2020 and January 20, 2021 and the period between
January 21, 2021 and February 26, 2021 would be treated as authorized leave
without pay pursuant to Article 24.1 of the Collective Agreement. The Grievor did
not return to the workplace and was deemed that he abandoned his position
resulting in the termination of his employment on March 31, 2021. He did not
grieve this termination of employment.
[17] In preparation for this hearing, the Union submitted the following revised
particulars on August 29, 2022:
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I. Background and Disabilities
1. The Grievor, Abdulkadir Mohamed, began his employment with the Ministry
of the Attorney General in or around 1991.
2. Mr. Mohamed became a Category 2 Flexible Part-Time (“FPT”) Court Service
Officer (“CSO”) in or around 1998, and largely held this position until the
Employer terminated his employment on or about January 21, 2021.
3. In or around May 2015, Mr. Mohamed was assaulted at work and suffered a
head trauma. After the brain injury, Mr. Mohamed’s mental health declined
and he experienced symptoms such as paranoia, feeling like people were
following him and trying to hurt him, and hearing voices. Mr. Mohamed’s
mental disability was undiagnosed at this time.
4. These symptoms became prevalent again in or around March 2020, when he
experienced the circumstances outlined in these particulars. These
circumstances caused his mental health to decline. Mr. Mohamed was unwell
and suffering from an undiagnosed mental illness at this time.
5. Through its interactions with Mr. Mohamed, the Employer knew, or ought to
have known, that Mr. Mohamed suffered from a mental disability since at
least March 2020 – particularly from December 2020 onwards.
6. On or about December 31, 2021, after experiencing anxiety, depression,
paranoia, hearing voices, and exhibiting bizarre behaviour, Mr. Mohamed
was admitted to the emergency department of the Centre for Addiction and
Mental Health. Mr. Mohamed was referred to a psychiatrist, when he was
diagnosed with symptoms of psychosis, schizophrenia, and dementia with
psychotic features. Mr. Mohamed is currently being treated for his mental
health conditions.
I. Circumstances leading to alleged absences
7. The Grievor, Abdulkadir Mohamed, began his employment with the Ministry
of the Attorney General in or around 1991.
8. Mr. Mohamed became a Category 2 Flexible Part-Time (“FPT”) Court Service
Officer (“CSO”) in or around 1998, and largely held this position until the
Employer terminated his employment on or about January 21, 2021.
9. Per Appendix 32 of the Collective Agreement, FPT workers are guaranteed
to work a minimum of five 5.75-hour shifts per week, 57.5 hours biweekly, or
1500 hours per annum.
10. Prior to March 2020, FPT CSOs attended work daily from Monday to Friday
to work a minimum of 5.75 hours per day. Mr. Mohamed worked far more
than the minimum hours of a Category 2 FPT at this time.
11. From March 2020 onwards, the Employer greatly reduced Mr. Mohamed’s
hours of work, and Mr. Mohamed worked far less than the minimum hours
guaranteed to a Category 2 FPT worker.
12. Upon arriving to work for his regular shifts, Mr. Mohamed was often
instructed to go home because work was not available. Mr. Mohamed carried
the cost of commuting and parking. He was not paid for work on most of
these occasions.
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13. On December 14, 2020, Mr. Mohamed attended work for his regular shift.
Satie Seeraj, a Supervisor of Court Operations, informed Mr. Mohamed that
courtroom work was unavailable and that Mr. Mohamed would be placed on
an unpaid leave of absence until CSO duties resumed in or around January
2021.
14. On December 14, 2020, Ms. Seeraj emailed Mr. Mohamed at
abdul.mohamed@ontario.ca and abdulkmohe@gmail.com, copying Chris
Samac, a Supervisor of Court Operations, and Michael Valerio, Manager of
Court Operations, to summarize her characterization of the conversation. In
the email, Ms. Seeraj asked Mr. Mohamed to confirm that he would not be
coming to work unless he was assigned courtroom duties; that he would not
be performing assigned administrative duties; and as such agreed to have
the time noted as a leave without pay when there were no courtroom duties.
15. Mr. Mohamed replied to Ms. Seeraj’s email on December 16, 2020 from his
personal email address: abdulkmohe@gmail.com. Mr. Mohamed stated that
he would not confirm Ms. Seeraj’s characterization of events. Mr. Mohamed
did not agree with the Employer’s decision to place him on an unpaid Leave
of Absence.
16. Mr. Mohamed did not refuse to perform administrative duties. However, it
was painful for Mr. Mohamed to perform the specific administrative duty of
filing work due to psoriasis. The Employer was aware of this condition. At the
time, the parties were proceeding through the arbitration process regarding a
grievance, which alleged that the stress from the workplace exacerbated Mr.
Mohamed’s psoriasis.
17. Mr. Mohamed understood that other employees were performing courtroom
work via Zoom. Mr. Mohamed viewed the Employer’s decision to place him
on an unpaid leave of absence – while allowing other employees to perform
courtroom work via Zoom – as discrimination on the basis of race and/or
ethnicity and/or disability.
II. Employer’s first email alleging that Mr. Mohamed was absent from work
18. On December 22, 2020, Mr. Samac emailed Mr. Mohamed at
abdul.mohamed@ontario.ca and abdulmohe@gmail.com, copying Ms.
Seeraj. In the email, Mr. Samac stated that Mr. Mohamed was scheduled to
work since December 14, 2020 and has not attended work. Mr. Samac
informed Mr. Mohamed that he was required to request approval for time off
from management in advance of being absent, barring exceptional
circumstances.
19. Mr. Mohamed did not receive the December 22, 2020 email from Mr. Samac,
as Mr. Mohamed’s personal email address was spelt incorrectly. His correct
personal email address is abdulkmohe@gmail.com. Mr. Mohamed was not
monitoring his work email address at the time, as he was not working.
20. Despite Mr. Mohamed’s understanding that the Employer did not have work
available for him and placed him on an unpaid leave of absence, Mr.
Mohamed wanted to work and called the Employer to inquire if work was
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available. For example, Mr. Mohamed called the telephone system to inquire
if work was available on January 4, 2021.
III. Employer’s second email alleging that Mr. Mohamed was absent from work
21. On or about January 6, 2021 Mr. Samac emailed Mr. Mohamed at
abdul.mohamed@ontario.ca and abdulmohe@gmail.com, indicating that a
letter would be sent to his house that day, and if he did not respond by
January 20, 2021, the Employer would deem Mr. Mohamed to have
abandoned his position.
22. Again, Mr. Mohamed did not receive the January 6, 2021 email from Mr.
Samac.
23. Mr. Mohamed also did not receive the January 6, 2021 letter. The letter
was returned to the Employer as “undeliverable” by Purolator on or around
January 11, 2021.
IV. Employer’s third email alleging that Mr. Mohamed was absent from work
24. On January 18, 2021, Mr. Samac again emailed Mr. Mohamed at
abdul.mohamed@ontario.ca and abdulmohe@gmail.com, and mailed a
letter by regular mail to Mr. Mohamed’s home address on file.
25. In this email and letter dated January 18, 2021, Mr. Samac provided Mr.
Mohamed with a “final opportunity” to contact him to provide a sufficient
justification for his absence or return to work by January 20, 2021. Mr.
Samac stated that Mr. Mohamed will be deemed to have abandoned his job
position, pursuant to s. 42 of the PSOA, if the deadline was not complied
with.
26. Again, Mr. Mohamed received neither the January 18, 2021 email nor the
letter from Mr. Samac.
V. Employer issues abandonment letter and Mr. Mohamed files grievance
27. On January 21, 2021, Ms. Samac sent a letter of abandonment to
abdul.mohamed@ontario.ca and abdulmohe@gmail.com, and further mailed
the letter by regular mail to Mr. Mohamed’s home address on file.
28. In the letter, the Employer advised that Mr. Mohamed had been absent from
the workplace without approved leave since December 14, 2020, and as
such it was declaring that Mr. Mohamed abandoned his position with the
Ontario Public Service. His employment was terminated effective January 21,
2021.
29. Mr. Mohamed received the January 21, 2021 letter by mail, and not by email.
30. On or about January 22, 2021, Mr. Mohamed emailed Mr. Samac stating that
he received the January 21, 2021 letter, and that he would like to schedule a
meeting to discuss it.
31. Mr. Mohamed and Local President Suzette Maxwell met with Mr. Samac and
Supervisor of Court Operations Katarina Lesko on January 26, 2021 to
discuss the alleged attendance and job abandonment issue. The parties
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discovered that Mr. Samac did not spell Mr. Mohamed’s personal email
address correctly in his past emails. However, the issue was unresolved
during this meeting.
32. On or about February 5, 2021, Mr. Mohamed filed a grievance, stating:
“I, Abdulkadir Mohamed, grieve the employer, The Ministry of
the Attorney General, for violating the Collective Agreement,
including but not limited to Articles 2, 3, 21, 24 and/or any other
related article within the Collective Agreement, the
Employment Standards Act, Ontario Human Rights Code,
Occupational Health and Safety Act, and any related
employment statute or principle in law that may apply, as well
as any related employer policy.
The employer, without just cause, willfully and in bad faith
terminated my employment.
N.B. In advance of all related meetings, I request full
disclosure of all documents that the employer is/will be relying
upon in this matter.’
VI. Employer unilaterally reinstates Mr. Mohamed’s employment
33. In or around February 2021, the Employer drafted a Memorandum of
Agreement in an effort to resolve the above-noted grievance and reinstate
Mr. Mohamed’s employment. This Memorandum was not executed.
34. On February 22, 2021, the Employer wrote to Mr. Mohamed and informed
him that his employment was reinstated, effective January 21, 2021.
35. At this time, Mr. Mohamed was suffering a reoccurrence of his mental illness,
resulting in him losing critical documents, such as his identification, and
access to his vehicle.
36. Despite being aware of Mr. Mohamed’s mental illness at this time, the
Employer did not inquire about Mr. Mohamed’s ability to return to work before
unilaterally reinstating his employment.
[18] The Union maintains that by failing to recognize and/or inquire about the
Grievor’s psoriasis in relation to his ability to perform filing duties, and/or by
failing to recognize and/or inquire about his mental health condition upon
unilaterally reinstating his employment, the Employer discriminated against the
Grievor on the basis of his disabilities and failed to accommodate him, in violation
of sections 5(1) and 17 the Ontario Human Rights Code and Article 3 of the
Collective Agreement. Furthermore, by placing the Grievor on an unpaid leave of
absence and refusing to provide him with work via Zoom when other employees
were provided with this work, the Employer discriminated against him based on
race and/or ethnicity in violation of section 5(1) of the Ontario Human Rights
Code and article 3 of the Collective Agreement. Lastly by terminating the
Grievor’s employment in violation of the Collective Agreement, and the Ontario
Human Rights Code, the Employer breached its management rights, per article
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2, as it did not dismiss the Grievor for just cause, per Article 21 of the Collective
Agreement.
Has the Union established a Prima Facie Case of discrimination on the grounds of race
ethnicity or disability with respect to the Grievor’s assignments of administrative duties
and unpaid leave?
[19] The parties agree on the general legal principles for the determination of
establishing what constitutes a prima facie case. As noted in OPSEU (Martin et
al) v. Ministry of Community and Social Services (Anderson) CanLII 60499 at
paragraph 3:
“In order to succeed, the moving party, in this case the Ministry, must
establish that the “facts asserted in support of a grievance, if accepted as
true, are not capable of establishing the elements necessary to
substantiate the violation alleged”: Couture, 2011 CanLII 100922 (ON
GSB), (Dissanayake). Arguments or conclusions do not constitute
allegations of fact. Accordingly, they need not be accepted as true for the
purposes of a no prima facie case motion.”
[20] Further at paragraph 6 of the Martin decision Arbitrator Anderson explains that:
“What matters for the purposes of the no prima facie case motion is whether the
party responding to the motion, in this case the Union, has articulated a legal
theory which, on the facts it has particularized, could reasonably support a
conclusion that there is a violation of the collective agreement. Therefore, the
particulars are to be assessed against the responding party’s theory of the case.
Whether that theory is correct need not be determined at this stage in the
proceedings. Provided the responding party’s theory is reasonable and it has
provided particulars which, if true, would result in a finding of a breach on the
application of that theory, the motion should be dismissed.”
[21] The Union does not dispute that during the pandemic, in 2020, that CSOs were
only scheduled for in-person hearings and were not trained to run virtual court
hearings using the Zoom platform and that CSO hours were often reduced. The
Union also does not dispute that in late November and December 2020, due to
the deterioration of public health in the City of Toronto, that the number of in-
person hearings decreased resulting in many CSOs being assigned
administrative duties or being offered the option of taking vacation or an
approved unpaid leave of absence.
[22] The Employer submits that the Union’s revised particulars do not disclose that
the Grievor was subject to any adverse treatment in either the type of duties he
was assigned or in the amount of work for which he was scheduled. In that
regard, the Employer notes all CSOs were subject to the same reduction of in-
person courtroom work, were not performing courtroom work via Zoom and were
either offered administrative duties or the option to take vacation or an approved
unpaid leave of absence when work was reduced or unavailable. The Employer
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also notes that in paragraph 14 of the Union’s revised particulars, that the
Grievor’s Supervisor sent an email summarizing her characterization of a
conversation they had on December 14, 2020, in which the Grievor was asked to
confirm that he told her that he would not attend work unless assigned courtroom
duties, that he would not perform administrative duties and, as such, he agreed
that he would be on a leave without pay if no courtroom duties were available.
While the Grievor responded by email on December 16, 2020 stating that he did
not agree with the Supervisor’s characterization of events and did not agree with
being placed on a leave of absence, the Employer submits that this email does
not provide any evidence alleging discriminatory conduct toward the Grievor.
[23] The Employer also submits that the Union’s revised particulars do not disclose
discrimination based on disability regarding the Grievor’s claim that he did not
refuse to perform administrative duties of filing work and that the reason he could
not perform the work was due to his condition of psoriasis. The Employer
maintains that not only did the Grievor ever raise any hesitancy to perform the
work due to his medical condition, but also, he never asked for an
accommodation.
[24] In support of its arguments that there is no nexus to the either race, ethnicity or
disability, the Employer provided the following cases: OPSEU (Morgan) v.
Ministry of Children and Youth Services (Tims) 2014 CanLII 3027, Khalii 2019
HRTO 1248 CanLII, Lepine 2011 HRTO 2283 CanLII and OPSEU (Poblete) v.
Ministry of Government and Consumer Services (Herlich) 2017 CanLII 0709.
[25] In order to find discrimination based on race or ethnicity, it is necessary for the
Grievor to establish that he is a member of an identified group and that he was
subject to adverse treatment because he is a member of that group. Having a
belief or feeling of being subject to discrimination is not sufficient to establish a
nexus. In this case, the Union’s revised particulars do not meet the test of
establishing a prima facie case of discrimination on the ground of race or
ethnicity. Given that the Union agreed, during the hearing, that all CSOs were not
running Zoom court work and that they were subject to reduced in-person
hearing work, I cannot conclude that the Grievor was treated any differently than
his colleagues. There is no dispute that all CSOs, particularly in late November
and December 2020, when in-person courtroom work was significantly reduced,
were offered the option of administrative duties or the option to take vacation
days or unpaid leave of absences. Again, the Grievor was treated no differently
as he was offered administrative duties where no courtroom work was available
and received an email on December 14, 2022 from his Supervisor seeking
confirmation that if he would not perform administrative duties if no courtroom
work was available that he would be placed on a leave of absence. The
Employer also tried to reach the Grievor on December 22, 2020 to advise that he
had been scheduled for work since December 14, 2020 but had not been in
attendance and then reached out again on January 6 and 18, 2021 to warn the
Grievor that he was required to contact the Employer to explain his absence from
work. Unfortunately, the Employer misspelled the Grievor’s email address
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resulting in him not receiving these emails, however the emails show that the
Employer was trying to contact the Grievor as he was scheduled for work and
that he was at risk of losing his job due to abandonment. While the Grievor
claimed to have called the telephone system, on January 4, 2020, to inquire if
work was available, there are no additional facts presented to show any
connection between this phone-call and whether there was a response from the
Employer and the Union’s theory of the case that the Grievor suffered
discrimination based on race or ethnicity.
[26] I also find that the Union’s revised particulars do not meet the test of establishing
a prima facie case of discrimination with respect to the claim that the Grievor
could not perform administrative duties due to psoriasis and that he was
discriminated on that basis. The Union’s revised particulars state that it was
painful for the Grievor to perform filing work due to psoriasis and that the
Employer was aware of this condition because the Grievor had filed another
grievance alleging that stress from the workplace exacerbated his psoriasis.
Reading the particulars, there is nothing to suggest that the Grievor either told
the Employer that it was painful for him to do the work in question or that he
asked for an accommodation because of the psoriasis. Furthermore, while there
may have been another grievance relating to workplace stress and the
exacerbation of the Grievor’s condition, it does not follow that the Employer knew
or ought to have known that the task of performing administrative filing duties
was physically painful for the Grievor.
[27] Even assuming the Employer knew about the Grievor’s psoriasis and allegations
of it being exacerbated by workplace stress, there is nothing in the Union’s
particulars to suggest that the Employer should have made any inquiries about
whether the Grievor required an accommodation to perform the filing tasks. While
an Employer may have a duty to inquire even where there has not been a
specific accommodation request, the duty generally only arises in situations
where it is readily apparent that an individual is having difficulty performing a task
because of personal characteristics cover by the Code, (Khalii supra, at para 31).
In this case, the particulars do not establish that the Employer had any reason to
be aware that the Grievor’s psoriasis had any impact on his ability to physically
perform the work and therefore there can be no basis for a finding a liability of
discrimination based on disability.
Has the Union established a Prima Facie case of discrimination based on disability with
respect to terminating the Grievor for abandonment or in reinstating the Grievor’s
employment?
[28] The Employer claims that the decision to dismiss the Grievor for abandonment or
to reinstate his employment on February 22, 2021 did not relate to the Grievor’s
mental health, and in fact, claims that it never received any information from the
Grievor concerning his mental health and how it might have been impacting his
workplace behaviour. In this regard, the Employer points out that there is nothing
in the Union’s revised particulars that establish that they knew or ought to have
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known about the Grievor’s mental health either prior to or post grievance. The
Union submits that during the meeting between the Employer, Grievor and the
Union on January 26, 2021 to discuss the January 21, 2021 termination letter, it
should have been obvious to the Employer that the Grievor was unwell. In
addition, the Union suggests that the Employer knew about the Grievor having
mental health issues possibly dating back to 2015, but most likely by March
2020, and therefore, would have had general knowledge about his disability.
[29] Having reviewed the Union’s revised particulars, I do not find any basis that
would establish a prima facie case of discrimination based on a mental health
disability. Although the Union claims that the Grievor’s mental health instability
should have been obvious to the Employer in the January 26, 2020 meeting, the
particulars do not disclose any facts to support the Union’s claim as they only
note that a meeting was held and that it was discovered that the Grievor’s email
address had been incorrectly spelled. The Union’s particulars also refer to the
Grievor suffering a head trauma in 2015 resulting in an undiagnosed mental
health decline, symptoms of paranoia and delusions occurring in March 2020 and
an admission to the Centre of Addiction and Mental Health’s emergency
department on December 31, 2021, followed by a referral to a psychiatrist and
diagnosis of various mental health conditions. While not questioning that the
Grievor experienced these events and while he may have believed that the
Employer knew about his mental health challenges, the revised particulars do not
provide any facts that might establish the Employer's knowledge. In addition,
although the Union’s revised particulars refer to the fact that the Grievor was
experiencing a recurrence of his mental health issues around the time that he
received his February 22, 2021 reinstatement letter, there are no other facts
submitted to suggest that the Employer had any knowledge about his condition.
While no doubt these mental health challenges have significantly impacted the
Grievor’s personal life, on the particulars provided, I cannot conclude that the
Employer either knew or should have know about his disability.
[30] In a claim for discrimination based on disability, in order to show a prima facie
case of discrimination, the Union must demonstrate that the Grievor has a
disability, that he experienced restrictions and limitations related to his disability
that need to be accommodated and that the Employer failed in its duty to
accommodate the limitations and restrictions. This case is like the circumstances
in Mohamid-Amin v. Book4Time inc. 2020 HRTO CanLII 367, in which the
Tribunal found that the Applicant failed to establish that she advised her
employer of a disability or any needs for accommodation. In that case, the
Applicant submitted that she had tremors arising from her PTSD and therefore
the Respondent employer should have known she had a disability and should
have inquired about it. This is no different than the Grievor in this case claiming
that the Employer should have know about his mental health challenges or make
inquiries either before issuing the January 21, 2021 letter of termination or the
February 22, 2021 letter of reinstatement when there is nothing in the particulars
to show that the Employer knew anything about the Grievor’s mental health
status.
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Is this Grievance Moot?
[31] The Employer argues that this Grievance should be dismissed for mootness
because the Grievor’s employment was reinstated, thereby fulfilling the remedy
sought by the Union and because there are no other issues to be considered.
The Employer notes that the doctrine of mootness involves a determination of
whether a live controversy exists that is arbitrable. While recognizing that there is
discretion in declaring that a case is moot, the Employer argues that I should not
apply my discretion in this case, as the Grievor not only received the remedy of
reinstatement on February 22, 2021 but also failed to file a subsequent grievance
when he was terminated again for abandonment on March 31, 2021. In support
of its arguments the Employer relies on the following cases: Borowski v. Canada
(Attorney General), [1989] 1 SCR 342. Thames Emergency Medical Services Inc.
v. Ontario Public Service Employees' Union Local 147 (Management Conduct
Grievance), 2006 CarswellOnt 11579, [2006] O.L.A.A. No.202 (P. Knopf) OPSEU
(Lobraico) v. The Crown in Right of Ontario (Ministry of Health), GSB
No.2934/91, October 7, 1993 (Gorsky), OLBEU (Berry) v. LCBO, GSB#2001-
0453 (Johnston).
[32] While the Union does not dispute the test for mootness, it states that the
Employer could not unilaterally reinstate the Grievor in order to impose a
settlement of his grievance and that, in any event, reinstatement did not
encapsulate all the remedies that the Grievor sought in his Grievance, which
included a remedy for human rights damages and a remedy for compensation for
his unpaid leave of absences. Therefore, the Union argues that a live controversy
still exists particularly with respect to remedy, even if I were to find that the issue
of reinstatement is moot. Alternatively, the Union asks that I exercise my
discretion to hear this case given the Grievor’s long service as Ontario Public
Service (OPS) employee and the lack of prejudice to the Employer in terms of
witnesses and the production of evidence.
[33] In support of its position that this Grievance should be arbitrated, the Union also
referred to a few labour arbitration cases in which it was found that an employer
could not avoid arbitration by unilaterally imposing a settlement of a grievance
by, for example, rehiring an employee or by paying out sick pay that was claimed
thereby denying an employee a right to adjudication for specific relief; see; Hall
Lamp Co of Canada Ltd v UAW Local 1620, 1972 Carswell Ont 1428, Misawa
Homes Ltd. v. C.A.I.M.A.W., 1974 Carswell Man 161, U.S.W.A. v. International
Nickel Co. of Canada Ltd., 1972 Carswell Ont 1493, Union Gas Co. of Canada v.
I.C.W., Local 741, 1973 CarswellOnt 1436.
[34] Having reviewed Counsels' thorough and thoughtful submissions and the
caselaw presented, together with my findings that the Union has not established
a prima facie case of discrimination either based on ethnicity, race, or disability, I
have concluded that no live controversy or issues exist that require a decision.
As a result, I find that the Grievance is moot. In my view, the Grievor was
reinstated to his employment on February 22, 2021 which was the key remedy
- 14 -
that was sought in the Grievance. Reinstating the Grievor to his position was not
a unilateral imposition of a settlement because the Employer acknowledged that
the reinstatement was without prejudice to any position it might take with respect
to the Grievance, in effect, acknowledging that it was not removing the Grievor’s
right to pursue his Grievance. As noted by Counsel for the Employer during reply
submissions, she emphasized that when the Employer reinstated the Grievor it
did not expect that he was withdrawing all his allegations or requested remedies
in his Grievance. Therefore, as I understand it, the Employer has not taken the
position that the Grievance was settled by the act of reinstatement. Instead, the
Employer maintains that by reinstating the Grievor on February 22, 2021 the
main remedy for his termination grievance was met and that no other issues
would remain outstanding if I agreed that there is no basis for a finding of
discrimination on the Code grounds alleged by the Grievor.
[35] Since reinstatement of the Grievor is not an available remedy and because there
is no basis to consider any of the human rights allegations raised in the Union’s
revised particulars no other remedies are available. In this regard, the Grievor’s
claim to be compensated for unpaid leaves of absence or for human rights
damages were related to his allegations that he was subject to discrimination
when he was asked to perform administrative filing work, when he received less
work and when he was placed on unpaid leave of absences. Based on my
findings of no prima facie cases of discrimination, there is no basis for the
Grievor to seek a remedy for human rights damages or wages related to either a
reduced workload, requests to perform administrative work, or unpaid leaves of
absence. In addition, since I have found no nexus between the Grievor’s
allegations of discrimination based on his mental health and the Employer’s
conclusion that he abandoned his position and therefore was terminated from
employment on January 20, 2021 or his reinstatement on February 22, 2021,
there is no outstanding claim for human rights damages. In terms of deciding
whether to exercise my discretion to hear this case, I agree with the Employer
that since the Grievor received the remedy of reinstatement on February 22,
2022, his decision not to file a subsequent grievance for his March 31, 2021
termination prevents him from raising a live issue to be arbitrated. Despite, the
Grievor’s long service with the OPS, I cannot find any basis for allowing this
Grievance to continue.
[36] As a result, this Grievance is dismissed.
Dated at Toronto, Ontario this 10th day of November 2022.
"Dale Hewat”
Dale Hewat, Arbitrator