HomeMy WebLinkAbout2021-1506.Decarlo 2023-01-06 DecisionCrown 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
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Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
GSB# 2021-1506
UNION# 2021-0368-0134
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Decarlo) Union
- and -
The Crown in Right of Ontario
(Ministry of the Solicitor General) Employer
BEFORE Tatiana Wacyk Arbitrator
FOR THE UNION Robert Healey
Ryder Wright Holmes Bryden Nam LLP
Counsel
FOR THE EMPLOYER Braden MacLean
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING December 8 & 13, 2022
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Decision
BACKGROUND:
[1] The Grievor has been a Correctional Officer at the Central East Correctional Centre
since September 2002.
[2] This decision deals with the Employer’s challenge of the timeliness of the Grievor’s
challenge of a 20-day suspension, and OPSEU’s request that I exercise my
statutory discretion to extend the timeline in the Collective Agreement for filing the
Grievance.
[3] The suspension was for the use of unnecessary and excessive force on two
occasions and acting in an inappropriate and unprofessional manner by using an
MK3 OC cannister to intimidate an inmate. While the Grievor initially filled out a
timely grievance form, it was never filed. More will be said in that regard below.
[4] The Grievor had a prior 20-day suspension for excessive use of force. The
Grievance regarding that prior suspension, dated September 30, 2019, is currently
before me.
[5] The Grievor’s employment was subsequently terminated on March 17, 2021. The
reasons for his termination included using unnecessary and excessive force.
[6] The Grievance challenging the Grievor’s termination is also before me.
[7] The Grievance at issue, regarding the March 5, 2020, 20-day suspension, was filed
on September 2, 2021, following a failed attempt to find a resolution regarding the
Grievor’s termination.
[8] Article 22.2.2 of the Collective Agreement requires grievances to be filed within 30
days after the circumstances giving rise to the complaint have occurred or have
come or ought reasonable to have come to the attention of the employee. It states:
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22.2 If the complaint or difference is not resolved at the local level an employee
may file a grievance, in writing, through the Union, with their manager within thirty
(30) days after the circumstances giving rise to the complaint have occurred or
have come or ought reasonably to have come to the attention of the employee,
who will in turn forward the grievance to the designated management
representative.
[9] Accordingly, in order to comply with the 30-day timeframe set out in the Collective
Agreement, the Grievance ought to have been filed on or about April 20, 2020.
(discounting Good Friday on April 10 and Easter Monday on April 13, 2020). As
the grievance was filled on September 2, 2021, there is no dispute it is untimely.
Specifically, it is just more than 16 months and one week late.
[10] Consequently, pursuant to Article 22.14.1, the Grievance shall be deemed to have
been withdrawn. Specifically, that provision provides:
22.14.1 Where a grievance is not processed within the time allowed or has not
been processed by the employee or the Union within the time prescribed it shall
be deemed to have been withdrawn.
[11] However, Article 22.14.7 of the Collective Agreement grants GSB arbitrators the
jurisdiction to exercise their jurisdiction to extend the Collective Agreement timelines
for all stages of the grievance and arbitration process. It provides:
22.14.7 … [T]he GSB has the jurisdiction to apply section 48(16) of the Ontario
Labour Relations Act to extend the timelines specified in the collective agreement
at all stages of the grievance and arbitration processes.
[12] OPSEU asks that I exercise my discretion in this instance, to extend the time for
filing the Grievance pursuant to section 48(16) of the Labour Relations Act, 1995,
SO 1995, c1, Sch A. That provision states:
48 (16) Except where a collective agreement states that this subsection does not
apply, an arbitrator or arbitration board may extend the time for the taking of any
step in the grievance procedure under a collective agreement, despite the
expiration of the time, where the arbitrator or arbitration board is satisfied that
there are reasonable grounds for the extension and that the opposite party will
not be substantially prejudiced by the extension.
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THE JURISPRUDENCE:
[13] Section 48(16) of the Labour Relations Act has been interpreted by various
arbitrators.
[14] In that regard, the Employer relied on the following: Becker Milk v. Teamsters,
Local 647, [1978] OLAA No. 71 (Burkett); OPSEU (Robbins) v. Ontario (LCBO),
2015 CanLII 36165 (ON GSB) (Lynk); OLBEU (Wicken) v. Ontario (LCBO),
GSB#2216/97 (Knopf); OLBEU (Gamble) v. Ontario (LCBO), GSB#1635/96 (Gray);
OPSEU (Berday) v. Ontario (MTO), 2008 CanLII 70540 (ON GSB), (Devins);
OPSEU (Ng) v. Ontario (MGS), GSB#2009-3379 (Mikus); OPSEU (McClelland) v.
Ontario (MCSCS), 2013 CanLII 42611 (ON GSB) (Briggs); OPSEU (Lachance) v.
Ontario (MCSCS), 2017 CanLII 30326 (ON GSB)(Briggs); OPSEU (Barker) v.
Ontario (SOLGEN), 2020 CanLII 20374 (ON GSB) (Gee); and, Ontario Public
Service Employees Union (Monk et al.) v. Ontario (Community Safety and
Correctional Services and Ministry of Children and Youth Services), 2010 CanLII
28621 (ON GSB).
[15] OPSEU relied on: Becker Milk v. Teamsters, Local 647, supra; Ontario (Ministry of
Health and Long-Term Care) and OPSEU (Kaltagian), Re, 2015 CarswellOnt 5978;
and, Greater Niagara General Hospital v. O.N.A., 1981 CarswellOnt 1881.
[16] Each of the decisions is informed by the factual context in which it is made.
However, one of the most comprehensive discussions appears in Vice-Chair Lynk’s
decision in Robbins, supra:
V. The Law
[31] The starting point for the determination of whether a legal decision-maker,
operating under s. 48(16) of the Labour Relations Act, 1995, should exercise her
or his jurisdiction to relieve against an untimely filed or advanced grievance is the
1982 ruling by Arbitrator Schiff in Greater Niagara General Hospital, supra. His
award has become the touchstone for assessing timeliness claims in Ontario.
Building upon an earlier seminal award on timeliness by Arbitrator Burkett in Re
Becker Milk, supra, Arbitrator Schiff laid out six interrelated factors to assess the
worthiness of a request to relieve against the time limits in a collective agreement
so as to dismiss a grievance on the basis that it is untimely, and to not hear and
decide the matter on its merits:
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i. The nature of the grievance – The more significant the issue is to the
parties – such as a termination or the imposition of serious discipline, or a
vital collective agreement interpretation – the greater the weight that
should be given to an extension. A matter of less significance will be
accorded less weight.
ii. Whether the delay occurred at the launch of the grievance or at some
later point in the process – If the delay occurred with a failure to initiate
the grievance within the timelines, the employer will not learn what the
grievor alleges nor have an opportunity to secure its own position. A
prejudice caused by the failure to adhere to time limits may not be as
serious to the employer if the delay occurred later in the process.
iii. Whether the grievor was responsible for the delay – A stronger
presumption against any timeliness relief would exist if the grievor bore
sole or primary responsibility for the delay. Notwithstanding this, if the
responsibility for the delay fell entirely or largely on the union, this would
not become a positive feature in favour of granting the relief. Rather, it
would more likely have the effect of neutralizing the factor.
iv. The reason(s) for the delay – A finding of bad faith by the party that
failed to file or advance the grievance would be a considerable mark
against providing relief. Negligence, carelessness or disregard for the
time limits would be less unacceptable, but still a matter of some
concern.
v .The length of the delay – All things being equal, the longer the delay,
then the greater the onus on the union and/or the grievor for providing a
credible reason to explain the delay.
vi. Whether the employer could reasonably have assumed that the
grievance had been abandoned – Union inaction that lulls an employer
into a false sense of security may be given a weighty factor. This goes to
the prejudice that an employer may face: it may well be lead to believe
that no grievance is forthcoming or that the matter has been implicitly
withdrawn by the union, and it may not take steps to protect its position,
such as preserving memory, protecting evidence or marshalling
arguments.
[32] In addition to this very helpful list of factors from Greater Niagara Regional
Hospital, subsequent rulings on timeliness have issued some useful observations
that have enriched the analysis into this question:
• The sophistication of the grievor, and her or his familiarity with the grievance
process, can be an element to be considered. If the grievor is, or had been, a
local union officer, or had previously filed grievances, this may be a factor against
extending time limits: Donwood Institute and OPSEU (1997), 1997 CanLII 25132
(ON LA), 60 L.A.C. (4th) 367 (Brandt). Conversely, a grievor who had never filed
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a grievance before, and who depended on the union for guidance, may result in a
more lenient approach towards timelines: Ontario (MCSCS) (Brennan), supra.
• Arbitrators differ as to the significance of an initial failure to grieve unchallenged
prior discipline which was used to justify a subsequent termination, based on the
principles of progressive discipline. Some arbitrators have held that unchallenged
prior discipline cannot be reopened merely because the grievor is now facing
termination based in part on the prior record. There must be other, persuasive
reasons to justify timeliness relief: Ontario (MCSCS) (McClelland), supra. Other
arbitrators have said that unchallenged prior discipline which creates a ‘serious
impact’ on the grievor requires the employer to demonstrate ‘real prejudice’ in
order to thwart the operation of s. 48 (16). Real prejudice amounts to a course of
action that would not otherwise have been taken and it must be a course of
action that cannot be reversed without harm to the employer: Vale Inco
Ltd, supra. This latter observation is broadly consistent with the requirement in s.
48 (16) that the prejudice to the employer has to be substantial.
• A three month delay is not a modest delay, but nor is it, by itself, an intolerable
length of time. While no hard-and-fast rule creating a bright red line based on the
length of the delay exists, or should exist, given the other factors at play,
requests for a time limit extension in this time range have been turned down –
Ontario (MCSCS) (McClelland); British Columbia Public Service Agency, supra –
and, conversely, have been allowed to proceed in order to be heard on their
merits: Liquor Control Board of Ontario (Brennan),supra. To be sure, arbitrators
have dismissed grievances when the timeliness breaches had been shorter than
three months –Helen Henderson Care Centre,supra; and West Fraser
Electro/Mechanical Ltd., supra – and permitted time extensions when the breach
far exceeded three months: Re City of Toronto and CUPE, Local 43 (1990), 1990
CanLII 12877 (ON LA),17 L.A.C. (4th) 420 (Springate); and Re Ferranti-Packard
Transformers Ltd. and USWA, Local 5788(1993),1993 CanLII 16683 (ON LA),36
L.A.C. (4th) 307 (Haefling).
• Unions and employees owe a general obligation of due diligence to employers
and the industrial relations process in ensure the timely filing and advancement
of grievances: (Ontario (MCSCS) (Mazara). However, this must be balanced with
the long-standing industrial relations rule that, as much as possible, workplace
differences should be resolved on their substance rather than on technical or
procedural issues: Blouin Drywall Contractors Ltd. and UBC (1975),1975 CanLII
707 (ON CA),8 O.R. (2d) 103 (C.A.);Vale Inco Ltd.
• While the ultimate legal source governing the issue of timeliness in Ontario is s.
48 (16), adjudicators should pay attention to the intentions of the parties, as
expressed by the language governing time limits in the collective agreement. If
the parties have chosen mandatory language, even if they have decided not to
preclude the operation of s. 48 (16), this should be a consideration in the
decision-making: (Ontario (MCSCS) (Mazara); Liquor Control Board of Ontario
(Gamble), supra; Helen Henderson Care Centre.
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PARTY POSITIONS:
[17] The Employer submitted the only factor which weighed toward my exercising my
discretion to extend the time for filing the Grievance was the seriousness of the
Grievance. The Employer submitted this should not overtake other factors and has
not done so in other cases.
[18] OPSEU submitted the essential test was set out in Becker Milk, supra, and none of
the cases following are a significant departure from a simple assessment of the
circumstances leading to the delay and whether there exists an absence of prejudice.
[19] OPSEU maintained that the cases relied upon by the Employer are distinguishable,
and that in this instance there are compelling reasons for the delay and no
substantial prejudice to the Employer. Accordingly, I ought to exercise my discretion
to extend the timeline for filing the Grievance.
DETERMINATION:
[20] In this instance, I find the conglomeration of factors to be considered lead me to
decline to exercise my discretion pursuant to section 48(16) of the LRA, to extend the
timelines negotiated and agreed to by the parties. My analysis and reasons are set
out below.
ANALYSIS AND REASONS:
[21] I accept what Arbitrator Lynk characterized as the “six interrelated factors to assess
the worthiness of a request to relieve against the time limits in a collective
agreement”, laid out by Arbitrator Schiff in Greater Niagara General Hospital, supra,
as the appropriate starting point. I will deal with each in turn.
The Nature of the Grievance
[22] As indicated above, while the Employer conceded the seriousness of the discipline
weighed in favour of granting the extension, it submitted the other factors outweighed
this element of the analysis.
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[23] The Employer asked that I not be swayed by the fact that the suspension at issue, at
the time unchallenged, was a consideration in the Grievor’s subsequent termination.
In that regard, the Employer relied on Vice-Chair Briggs decision in McClelland,
supra, in which she accepted, at paragraphs 62 and 63, that the three-day
suspension the grievor, in that instance, wished to challenge was “not insignificant”,
and that, as in this instance, it was an “underpinning” for the grievor’s later
termination. However, she stated at paragraph 63:
[63] The Union also asked this Board to take into account the
fact that this grievance is an underpinning for the grievor’s later
termination. While that suggestion has some initial attraction, I must
decline the Union’s invitation in this regard. If an individual is
terminated after a long but unchallenged disciplinary history, should
an arbitrator agree to hear newly filed grievances regarding the
entire disciplinary history merely because it culminates in a
termination? I think not. While that might be the extreme example
of what the Union is suggesting, it illustrates the difficulty with the
argument. An individual cannot ask this Board to re-visit or re-
open their previously unchallenged disciplinary history merely
because they are ultimately faced with a termination of
employment. [emphasis added]
[24] Vice-Chair Briggs rejected the Union’s submission that the three-month delay in that
instance was “relatively insignificant” and refused to exercise her discretion to extend
the time for filing a grievance challenging the three-day suspension.
[25] OPSEU, on the other hand, argued that consideration ought to be given not only to
the serious nature of the discipline itself, but the role it now plays in the progressive
discipline administered by the Employer, resulting in his termination.
[26] Indeed, the Union submitted that allowing the 20-day suspension to remain
unchallenged on the Grievor’s record, may result in his termination being upheld on
the basis of the progressive discipline, whereas the underlying basis for his
termination alone would not be sufficient to support that level of discipline.
Analysis
[27] There is no dispute the 20-day suspension constitutes a serious discipline, and in
isolation weighs in favour of exercising my discretion to allow the Grievance to
proceed. The fact it played a role in the progressive discipline resulting in the
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Grievor’s termination, adds to the weight to be given to this factor. However, I agree
with Vice-Chair Briggs that it cannot be determinative, as the other factors must be
considered.
Whether the Delay Occurred at the Launch of the Grievance or at Some Later
Point in the Process
[28] The Employer pointed out that in this instance, the delay occurred at the very start-
point of the grievance process. As stated at paragraph 35 in Robbins, supra, this left
the Employer understandably assuming it would not have to defend its decision to
impose the 20-day suspension on the Grievor through the grievance process, which
the Employer maintains weighs against granting an extension.
[29] Further, in Barker, supra, at paragraph 70, Arbitrator Gee, affirmed that delay at the
beginning of the grievance procedure is “the most problematic stage for delay to
occur”…
[30] OPSEU submitted that no one factor was determinative, and maintained the primarily
consideration was the reason for the delay and the existence of prejudice.
Analysis
[31] There is no dispute that a delay at the beginning of the arbitration process i.e., the
failure to file a grievance, is most problematic. One of the primary reasons parties
agree to fairly stringent timelines for bringing disputes forward is that it allows for
early resolution, and when that is not possible, it enables both parties to turn their
mind to gathering and preserving evidence. Those opportunities are lost and
diminished further as time goes by if neither the Employer nor Union is aware a
dispute exists.
[32] As Vice Chair Briggs stated at paragraph 68 in Lachance, supra, where the delay
was 2-3 months but occurred at the front end of the grievance process:
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[68] Turning first to the matter of the length of the delay. In
considering this factor I have taken into account that the delay at
issue is at the outset of the grievance procedure. That is to say that
the Employer would have had at least a two-month period and
perhaps as long as a three-month period where it thought Mr.
Lachance was not advancing a complaint under the grievance
procedure of the Collective Agreement. A delay at the front end of
the grievance procedure is more problematic for an Employer
because it has not been put on notice – in any way – that there is a
live dispute. Memories can fade and documents simply not kept
which in hind sight might have been important. Vice Chair Gray
in Re Mazara said, at paragraph 59, that “a delay at the initial stage
weighs more heavily against an exercise of discretion to extend
time limits, all other things being equal, than a delay at the later
stages of the grievance process”.
[33] The fact the delay was at the beginning of the process is troubling in this instance as
well, and weighs against granting an extension. This is particularly the case when
the length of the delay is considered, as seen further below.
Whether the Grievor was Responsible for the Delay
[34] The Grievor testified that in December 2017, his family was threatened by an inmate,
but the Employer was unresponsive to his requests for assistance. Rather, the
Grievor was simply told to avoid the inmate.
[35] The Grievor testified tensions were also high in the institution and that he and the
other front-line staff felt bullied and intimidated by management, who took issue with
trivial and minor infractions. The tensions escalated over the winter of 2018, and in
the spring of 2019, the front-line staff refused overtime. This heightened tensions
further and resulted in out-side managers being brought into the institution.
[36] As a result of the continued tensions, on March 30, 2019, the Grievor posted five
Ministry anti-violence and anti-bullying posters in the workplace, including in the
administration area. The posters were subsequently removed by the Grievor
approximately two weeks later.
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[37] In the summer of 2019, the inmate who had threatened the Grievor’s family returned
to the institution. When the inmate was moved back into the Grievor’s unit, the
Grievor again expressed his concerns. While the Grievor was initially reassigned to
shifts which took him out of the unit, he was subsequently reassigned to his usual
unit, at his request.
[38] While the Grievor was again advised to avoid that inmate, he testified the situation
made him anxious, as he knew that inmate was going to cause problems for him.
[39] The Grievor testified it was demoralising to know the Employer, whose duty it was to
keep him safe from dangerous people, refused to support him when he asked for
protection.
[40] It was the Grievor’s interaction with this inmate that resulted in his first 20-day
suspension without pay on September 30, 2019. The suspension was immediate.
[41] On October 31, 2019, the Grievor’s third day back following the suspension, he
received an allegation letter regarding his having posted the anti-bullying poster in
the administrative area on March 30, 2019, without authorization.
[42] The Grievor testified the suspension he had just served, as well as this new
allegation, brought after such a long delay, made him feel targeted and that the
Employer was “coming after him” for his job. As a result, at the subsequent
November 6, 2019, allegation meeting, he suffered a panic attack, resulting in an
inability to communicate.
[43] Consequently, the allegation meeting was adjourned, and the Grievor was directed to
Staff Services to start an application to the Workplace Safety and Insurance Board
(“WSIB”) for an occupation stress injury. However, this claim was unsuccessful, at
least in part because his physician indicated she did not feel comfortable signing the
WSIB documentation advising that he take time off due to what she saw as a
workplace dispute. Consequently, the Grievor testified he “just went back to work”.
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[44] However, the environment remained the same, with management working against
the front-line workers. He heard nothing more regarding his March 30, 2019 posting
in the administrative area.
[45] The Grievor maintained he decided to keep his “head down and not give the
Employer reason to pull the trigger”.
[46] No pay had been deducted during the time the Grievor was serving his suspension in
September 2019. Rather, near the end of November 2019, the Grievor was advised
he would not receive his next two pays, to satisfy the outstanding wages from his
suspension. As this was the time period immediately before Xmas, the Grievor
raised the matter with OPSEU. Although an installment plan was worked out with
OPSEU’s assistance, the Grievor felt the Employer had deliberately waited to “stiff”
him at Xmas.
[47] The Grievor testified that his personal life had been tumultuous during his period, as
he and his wife had separated in 2017. However, by the end of 2019 they were
reconciling. He indicated this was “good but tense”.
[48] The incident resulting in the subsequent March 5, 2020 20-day suspension at issue
occurred on December 13, 2019. The Grievor testified that he did not understand
why he had been disciplined, and that the inmate involved was very strong and
aggressive, and he had used a “straightforward use of force”. While he was truthful
in his reports that he did strike the inmate, he was told he was not forthcoming and
was lying. Consequently, the Grievor testified that as he had already told the truth,
he did not know what else he could do.
[49] The Grievor indicated an OPSEU grievance officer prepared a grievance form for him
regarding the suspension. While he could not specifically recall doing so, the
Grievor testified he must have printed and signed the grievance form, and returned it
to the grievance officer.
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[50] However, while the grievance officer subsequently called a few times, the Grievor
testified he “dodged” the calls. When he listened to the messages the grievance
officer left for him, he would get overwhelmed. The Grievor described this as feeling
“like a panic attack”. All he could think about was taking on management, and giving
them more reasons to target him. He indicated he simply wanted to keep his head
down and get back to work. He felt he just couldn’t face the situation, and had to set
the whole matter aside.
[51] Consequently, the Grievance was not filed. When asked why he did not reactivate
the Grievance at the time of his termination on March 17, 2021, the Grievor testified
he understood that he had abandoned it. Consequently, he only discovered he could
pursue it after the failed mediation session between the parties which occurred at the
end of August 2021.
[52] The Employer submitted that to the extent OPSEU was suggesting the delay in filing
the Grievance was the result of a fear of reprisal by the Employer, Vice-Chair Gray in
his decision in Monk, supra, had indicated that while this may justify a modest delay,
this would not be the case when the delay was significant. Vice-Chair Gray stated,
in part, at paragraph 20:
[20] An allegation that the employer threatened or intimidated
an employee into not filing a grievance could itself be raised
as a grievance (discrimination on the basis of union activity
contrary to Article 3.2), which would be subject to the very time
limits in issue here. Extending the time for filing a grievance
because of such employer misconduct is analogous to
providing a remedy for that misconduct. Should a request for
a remedy for employer misconduct be entertained despite the
delay in complaining of it? That question has to be addressed
in accordance with the considerations already described. It
cannot be said that an explanation for a grievor’s multi-year
delay in complaining of such gross employer misconduct is
self evident, not when it would be well known to the grievor
that her or his trade union stands ready, willing and able to
challenge any perceived threat to its members’ rights. While
an allegation that the employer threatened reprisal if a
grievance was filed might, if true, afford reasonable grounds
for some modest extension of the time for filing the grievance,
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it must be otherwise when years unexplainedly pass before
the complaint about alleged threats of reprisal is raised.
[53] In any event, the Employer pointed out that if the Grievor did have a bona fide fear
of reprisal if he grieved the 20-day suspension, the Grievor gave no compelling
reason for not reactivating the Grievance when his employment was terminated.
Rather, he conceded he had abandoned it.
[54] OPSEU, while not denying the Grievor was to blame for the delay, again pointed out
this is not determinative. Rather, all factors identified in the jurisprudence must be
considered in determining whether it is appropriate to extend the timeline for filing
the Grievance.
[55] OPSEU further submitted that all the decisions relied upon by the Employer are
distinguishable, as none involve a highly tense and difficult workplace such as
experienced by the Grievor.
Analysis
[56] In this instance, it is apparent the Grievor was solely responsible for the delay, as
he knowingly and deliberated abandoned the initial grievance.
[57] As stated in Robbins, supra, at paragraph 31. iii set out above in paragraph 16, this
results in a stronger presumption against any timeliness relief.
[58] While such a presumption can be overcome by the reasons for the delay, I find that
is not the case in this instance, as dealt with below.
The Reason(s) for the Delay
[59] The Employer submitted no reason exists for granting an extension of the time for
filing the grievance. It pointed out there was no question the Grievor was
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knowledgeable regarding the process for filing timely grievances, as he had done so
with regard to his earlier 20-day suspension, as well as his termination.
[60] Further, to the extent OPSEU wished to rely on medical reason for the delay, the
Employer submitted it ought to be held to Vice-Chair Brigg’s decision in Lachance,
where at paragraph 71, she noted that medical evidence must be tendered for that
purpose. The Employer submitted that in the absence of such evidence there was
no objective basis on which to conclude the Grievor failed to file a timely grievance
because of medical difficulties, which diminishes the weight such assertions could
attract.
[61] OPSEU pointed out there was no indication the Grievor failed to file the Grievance
out of negligence or was blameworthy in some manner. Rather, his uncontroverted
evidence was that he felt targeted, was afraid for his job, and felt it best to keep his
head down and not antagonize the Employer further.
[62] OPSEU submitted there was no authority to support the Employer’s position that no
weight ought to be given to the Grievor’s evidence regarding his feelings of stress
and being overwhelmed, and that only medical evidence in that regard was
acceptable.
[63] Rather, OPSEU encouraged me to consider all the facts, including the Grievor’s
historic feelings of being unsupported by the Employer when his family was
threatened, and of being targeted, and come to my own conclusion regarding
whether there were compelling circumstances for exercising my discretion to extend
the timeline for filing the grievance.
Analysis
[64] I am persuaded the Grievor was experiencing stress and feeling overwhelmed by
the overall situation he found himself in. These feelings are not unusual when an
Employee is faced with a significant discipline, and other conflicts at work.
However, while the Grievor also relied on his personal circumstances at the time
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and described things as “good but tense”, it appears his reconciliation with his
partner gave him some reason to feel more positive.
[65] While I agree medical documentation is not necessary in all instances, I cannot
ignore the fact that in this instance, the Grievor’s own physician did not see the
stress he was experiencing at the time sufficient to recommend he remain off work.
In the face of that assessment, the Grievor did not seek additional medical
assistance or an alternative assessment. Rather, he simply returned to work.
[66] Further, this is not a case where the Grievor was unaware regarding the need or
process for filing a grievance. Indeed, he took the initial step of doing so.
However, he was also fully aware he needed to work with the Union in bringing the
matter forward and to the Employer’s attention. Yet he made no effort to
communicate with the Union regarding his challenges and how he was feeling, to
see if it could offer assistance. Rather, by his own account he “dodged” the Union’s
attempt to contact him and instead knowingly “abandoned” the Grievance. While he
now regrets this decision, I am not persuaded the reasons for the delay weigh in
favour of my exercising my discretion to extend the timeline for filing the grievance.
The Length of the Delay
[67] The Employer submitted the delay in this instance borders on extreme. It pointed
out that in Wicken, supra, Vice-Chair Knopf refused to exercise her discretion to
allow a discharge grievance to proceed when the delay was 16 months, as is the
case here. While she also gave weight to the other factors from Greater Niagara
General Hospital, supra, she pointed out, at the last paragraph of page 12:
The length of the delay is a very significant factor in this case. In
none of the cases cited by the Union was there a delay of over 16
months. The cases dealing with delay often talk about the
importance of having discharge cases heard on their merits despite
delays of a matter of months. In the case at hand, we have a delay
of well over one year. This very lengthy delay is the very type of
thing that labour arbitration and the grievance process were
designed to avoid.
17
[68] However, the Employer pointed out that in other instances arbitrators have refused
to exercise their discretion in instances where the delay has been less that 16
months.
[69] In Lachance, supra, as indicated, Vice Chair Briggs was dealing with a delay of 2-3
months. She stated at paragraph 69:
[69]…[T]he Board jurisprudence – much of which was put before
this Board and cited above - has made clear that a two-month delay
– particularly at the outset of the grievance procedure – is a
“significant” or “substantial” delay. Vice Chair Gray, in Re Smith et
al was considering an allegation of an improper level of pay for a
group of employees. He stated, beginning at paragraph 17:
As I have already noted on the view most favourable to the grievors
the delay is about three months beyond the already ample time
frame provided by the collective agreement for bringing a complaint
to the grievance process. This is a substantial delay. A bar based
on such a delay should not be described as merely “technical”.
These grievances are objectively more important to the grievors
than a grievance about a day’s pay or minor discipline would be,
but less important than a discharge grievance would be.
[70] In Barker, supra, at paragraph 70, Arbitrator Gee, refused to exercise her discretion
to extend the time limits when the delay at issue was, at its highest, nine and a half
months.
[71] In Berday, supra, Arbitrator Devins found, at paragraph 24, that the non-renewal of
the grievor’s contract was “comparable if not identical to cases involving discharge”.
However, she refused to exercise her discretion to allow the grievance in light of the
delay which she found, at paragraph 25, to be at least 4 months but more likely to
be 7.5-month delay.
[72] In Ng, supra, Vice Chair Mikus, at paragraph 16, dealt with an untimely grievance of
three suspensions, which she found were significant in the spectrum of progressive
discipline which resulted in the grievor’s ultimate termination. While she found this
militated in favour of the exercising her discretion she chose not to as she found the
delay to be unreasonable and lengthy.
18
[73] She described the delays as follows in paragraph 15:
The length of the delay in the instant case is significant. The first
suspension began on June 16th, some 6 months after the grievance
was filed. The second suspension began on August 6th, some 4
months before the grievance. Even the last suspension, which
began on October 8, 2009 preceded the grievance by 2 months.
The length of the delays does not assist the grievor’s request for an
extension.
[74] Also, as noted above, in McClelland, supra, Vice-Chair Briggs, accepted the three-
day suspension the grievor wished to challenge in that instance was “not
insignificant”, and that it was “an underpinning” for the grievor’s later termination.
However, Vice-Chair Briggs rejected the Union’s submission that the three-month
delay in that instance was “relatively insignificant” and refused to exercise her
discretion to extend the time for filing a grievance challenging the three-day
suspension.
[75] Further, the Employer noted that while Vice-Chair Lynk chose to grant the extension
in Robbins, supra the delay was significantly less that in this case, i.e., approximately
3 ½ months.
[76] Finally, Vice-Chair Gray, in his decision in Gamble, supra, refused to exercise his
discretion to allow for a termination grievance to proceed. He found the two-year
delay was simply too great, notwithstanding the lack of demonstrable prejudice that
would be suffered by the Employer, to warrant relief under s. 48 (16).
[77] OPSEU, on the other hand, submitted that all the decisions relied on by the Employer
are distinguishable as none involved the highly tense and difficult workplace
experienced by the Grievor. Nor did any involve investigations where the details
were recorded in such meticulous detail, as discussed below.
[78] OPSEU conceded the length of delay is an important consideration because it is a
yardstick for measuring prejudice, in terms of the impairment of memories as time
passes. However, in this instance, OPSEU submitted no such prejudice existed,
given the substantial documentation, and in particular witness statements in the form
19
of Occurrence Reports which were acquired in the course of the Employer’s
investigation. Accordingly, OPSEU submitted the Employer was in precisely the
same position to defend its decision in September 2021 as it would have been in
March 2020, had the Grievance been processed and referred to arbitration in a timely
manner.
[79] In support of its argument that the length of delay must be determined within the total
circumstances it occurred, OPSEU relied on the following from Arbitrator Schiff’s
decision in Greater Niagara General Hospital, supra:
18 Perhaps more than all others, this factor [length of delay] is
conditioned by the total circumstances. We see from some
previous awards that, in particular circumstances, two months’
delay in filing a grievance (albeit a discharge grievance) is not too
long: Re Becker Milk Co. Ltd. and Teamsters Union, supra. Nor is
a delay of two and a half months in referring the grievance to
arbitration: Re Scarborough General Hospital and Ontario Nurses’
Assoc. (1980, unreported (Scott)). The delay here is about two and
a half months, a not inconsiderable length of time but nevertheless
the same as that excused in Scarborough General Hospital. For
what it is worth, the delay here is much less than the nine and a half
months in Re City of Toronto and C.U.P.E., supra, where the board
refused to invoke s. 37(5a) under a reading that required the union
to establish due diligence and a reasonable excuse for the delay.
[Emphasis added]
Analysis
[80] I find that, as submitted by the Employer, the more than 16-month delay is
substantial, and borders on the extreme. It exceeds the delays in Ng, supra,
McClellan, supra, and Berday, supra, all cases in which the Vice-Chair refused to
extend the time limit for filing, and is considerably longer that 3-month delay forgiven
in Robbins, supra. Rather, the delay is closer to the more than 16 months described
as “very lengthy” in Wicken, supra, and the 24-month delay in Gamble, supra,
described as “extreme” at paragraph 29.
[81] I note, that at paragraph 29 of Gamble, supra, Vice-Chair Gray did state that on the
facts in that instance, there would have been reasonable grounds to relieve against a
roughly 19-month delay, had the grievance had been filed at that time. This was due
20
to the grievor having, until that point, received erroneous legal advice. However, as I
find below, there is no similar mitigating aspect of the case in this instance.
[82] Further, as discussed below, I do not find the extensive investigative record relied on
by OPSEU ameliorates the prejudice experienced by the Employer because of the
substantial delay.
[83] While I agree that delay is only one factor to be considered in determining whether to
exercise my discretion to extend the timeline for filing the grievance, and that it must
be assessed within the total circumstances of its occurrence, I find the substantial
delay in this instance weighs heavily against exercising my discretion to do so.
Whether the Employer Could Reasonably Have Assumed That the Grievance Had
Been Abandoned
[84] The Employer pointed out there was no suggestion the Grievor’s intention to
challenge the suspension was brought to the Employer’s attention. Rather, the
Grievor conceded he had abandoned it. Accordingly, it was entirely reasonable for
the Employer to assume the suspension was unchallenged.
[85] The Employer pointed out that both prior suspensions were referenced in the
Grievor’s March 17, 2021 termination letter, which indicates the Grievor’s
“employment record” was relevant in the decision to terminate his employment. Yet
the Grievor further delayed more than five months to challenge his March 5, 2020
suspension.
[86] The Employer further pointed out that in Gamble, supra, Vice-Chair Gray held that
where the delay is long enough, no proof of prejudice is necessary. He stated:
[26] The prejudice caused by delay may also be more subtle and,
by its nature, difficult to demonstrate. The memories of witnesses
who are still available will nevertheless have faded, particularly if
there has been no notice that they may have to testify about those
memories. As a result, their testimony may be or may seem less
reliable, and thence less persuasive, than it would have if there had
21
been timely notice of the dispute. Those now concerned with the
dispute may not be able to determine what testimony or documents
would have been discovered and preserved earlier, had there been
timely notice of the dispute. They may not know what statements
would have been given at the time by those witnesses whom they
can now identify, nor what might have been found in documents
known to have existed then that have since been destroyed.
Indeed, they may not now know of or discover helpful witnesses or
relevant documents whose existence would have been discovered
had timely assertion of the dispute triggered an earlier search for
them. It is in the nature of these forms of prejudice that their precise
effects and perhaps even their existence in a particular case cannot
be demonstrated.
[27] It must be remembered that subsection 48(16) of the LRA
identifies the existence of reasonable grounds for an extension is a
question distinct from whether the opposite party would suffer
substantial prejudice if an extension were granted. A defaulting
party who lacks a reasonable excuse for delay cannot claim the
benefit of the more liberal view of the reasonable grounds test,
which treats the length of the delay as a distinct consideration in
assessing reasonable grounds, and then invite the arbitrator or
arbitration board to ignore the delay because it has not resulted in
specific, demonstrable prejudice to the opposite party’s ability to
defend its position if the grievance is allowed to proceed.
[28] The possibility that delay may have had more subtle prejudicial
effects, effects that may not be detectable or demonstrable, is one
reason why the length of the delay is an appropriate consideration
in assessing whether there are “reasonable grounds” for an
extension, even when the respondent cannot demonstrate actual
prejudice. …
[29] Even when the opposite party cannot demonstrate
substantial consequent prejudice, delay that is due to lack of
due diligence on the part of the grievor or someone acting on
his or her behalf can be so extreme that the importance of a
discharge grievance will not be sufficient basis for using the
power in subsection 48(16) of the LRA to override agreed-upon
time limits for filing a grievance. The delay here was that
extreme. Indeed, the delay from the date of discharge until April
1996, when the grievor says he first contacted the union on the
advice of his second lawyers, was that extreme. Most of the
decisions relied upon by the union involved delays of several weeks
or a few months. … [emphasis added]
[87] This view was echoed by Arbitrator Gee in Barker, supra:
[75] Turning to the question of prejudice, I do not agree that
prejudice is not to be assumed but rather must be proven by the
Employer. The jurisprudence establishes that there is an inherent
22
labour relations interest in having grievances brought within a
reasonable time frame and a failure to do so is prejudicial to the
conduct of a fair hearing and workplace harmony. The case of Sault
College, supra, relied upon by the Employer, is a recent decision
that considers the issue in the context of a grievance alleging
harassment. The quote from Sault College set out at paragraph 19
above is instructive. As stated by the arbitrator, the harm caused by
delay in the labour relations context has long been recognized:
37. In my view, when striking a balance, an arbitrator should also
keep in mind the time honoured principle of labour relations that
grievances about alleged violations of the collective agreement
should be brought within a reasonable time after the matter in issue
arose (see U.E. v. Canadian General Electric Co. (Davenport
Works) (1952), 3 L.A.C. 980 (Ont. Arb.)(Laskin)
[88] While acknowledging the seriousness of the 20-day suspension, the Employer
submits this too is a case where the delay is so extreme that prejudice need not be
demonstrated.
[89] OPSEU points out the “presumption of prejudice” in instances of extreme delay is
merely a presumption, which can be overcome based on the circumstances. The
reasons for the delay, and the Employer’s ability to defend must still be assessed.
[90] In this instance, OPSEU submitted the Employer engaged in a thorough investigation
of the incident leading to the suspension at issue. This included the Grievor’s
detailed Use of Force Occurrence Report, as well that of ten others, some of which
were quite detailed.
[91] OPSEU further submitted the Notice of Allegation letter sent to the Grievor made
clear the Employer had a detailed set of allegations, and a detailed position regarding
the policies and documents on which it relied in determining the Grievor’s conduct
was worthy of discipline.
[92] OPSEU again maintains the facts in this case can be distinguished from those relied
on by the Employer, as none involve a similar meticulously recording of details.
23
Analysis
[93] While OPSEU is correct that the presumption of prejudice can be overcome based on
specific circumstances, I find OPSEU has not succeeded in doing so in this instance.
[94] The Employer bears the onus to demonstrate it had just cause to issue the
challenged discipline. While the Occurrence Reports provide a context for that
decision, any challenge to their contents will have to be met by the viva voce
evidence of their authors. This would, of course, rely on their recollection of the
events. The nature of the dispute i.e., unreasonable use of force, is such that the fine
details of what occurred can be critical. The passage of more than 16 months
beyond what would have been the designated time for filing the grievance,
particularly without any notice that such details must be retained, persuades me that
the presumption of prejudice remains intact in this instance.
DETERMINATION:
[95] At paragraph 19, Arbitrator Gee in her decision in Barker, supra, referenced Arbitrator
Mullin’s decision in Sault College and OPSEU, 2019 CarswellOnt 9458 where he
states:
37. In my view, when striking the balance, an arbitrator should also
keep in mind the time honored principle of labor relations that
grievances about alleged violations of the collective agreement
should be brought within a reasonable time after the matter in issue
arose (see: U. E. v. Canadian General Electric Co. (Davenport
Works) (1952), 3 L. A.C. 980 (Ont. Arb.) (Laskin)).
As Professor Laskin put it so eloquently in General Electric, supra,
the proper administration of the collective agreement requires “…
mutual recognition by the parties of a principle of repose as to all
claims under the Agreement not asserted within a reasonable time.”
There is a real danger to present relations by permitting a grievance
to drag up ghosts from the past when the Employer is either
unaware of the matters of concern at the time they arise (and
therefore unable to address them) or where the employer believes
that concerns have been addressed and the matter concluded. ….
24
[96]While Arbitrator Mullins was dealing with allegation of harassment, I find his
comments of equal application in this instance.
[97]In order to reflect the need for timely resolution of disputes, the time limits agreed to
by parties to a collective agreement are, in most instances, expressed in days rather
than weeks or months. They are important and ought to be respected except for
instances where there are compelling reasons not to do so. I find there are no such
compelling reasons in this instance.
[98]Rather, while acknowledging the seriousness of a 20-day suspension, for all the
reasons set out above, I find the preponderance of factors to be considered in
deciding whether to extend such timelines pursuant to Article 48(16) of the LRA lead
me to decline to exercise my discretion in this instance.
[99]The Employer’s Motion is granted.
[100] The Grievance dated September 2, 2021, challenging the Grievor’s 20-day
suspension of March 5, 2020, is dismissed.
Dated at Toronto, Ontario this 6th day of January 2023.
“Tatiana Wacyk”
Tatiana Wacyk, Arbitrator