HomeMy WebLinkAboutP-2010-1500.Muldoon.11-11-08 DecisionPublic Service Commission des
Grievance Board griefs de la fonction
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P-2010-1500, P-2010-1501, P-2010-2469, P-2011-0942, P-2011-0943,
P-2011-0944,P-2011-0945, P-2011-0946
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Daniel Muldoon Complainant
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The Crown in Right of Ontario
(Ministry of Community Safety and Correctional Services)
Employer
BEFOREChair
Donald D. Carter
FOR THE
COMPLAINANTDaniel Muldoon
FOR THE EMPLOYERSusan Munn
Ministry of Government Services
Labour Practice Group
Counsel
HEARING
October 5, 2011.
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Decision
[1]This decision deals with a preliminary issue raised by the employer. The employer takes
the position that the Public Service Grievance Board (PSGB) has no jurisdiction to deal with any
of these complaints because the complainant had not given proper notice to his Deputy Minister
as required by section 8 of Ontario Regulation 378/07. According to the employer, because of
this failure to give proper notice to the Deputy Minister, the grievor was not entitled to file these
complaints with the PSGB since the complainant had not satisfied one of the conditions set out in
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(b) if the person gives notice in accordance with section 8 of his or her proposal to
file the complaint; and
(c) if the person complies with the filing requirements set out in section 10. O. Reg.
378/07, s. 2 (1).
(2) Subsection (1) does not affect the right of a person to file a complaint under Part
V of the Act (Political Activity) or a complaint under Part VI of the Act (Disclosing and
Investigating Wrongdoing). O. Reg. 378/07, s. 2 (2).
Complaint about a disciplinary measure
3. (1) A public servant who is aggrieved by the imposition of a disciplinary
measure under section 34 of the Act, other than dismissal for cause, may file a complaint
about the disciplinary measure with the Public Service Grievance Board,
(a) if the public servant is eligible under section 5 to file such a complaint;
(b) if the public servant gives notice in accordance with section 8 of his or her
proposal to file the complaint; and
(c) if the public servant complies with the filing requirements set out in section 10.
O. Reg. 378/07, s. 3 (1).
(2) Subsection (1) does not affect the right of a public servant to file a complaint
under Part V of the Act (Political Activity) or a complaint under Part VI of the Act
(Disclosing and Investigating Wrongdoing). O. Reg. 378/07, s. 3 (2).
Complaint about a working condition or a term of employment
4. (1) Subject to subsection (2), a public servant who is aggrieved about a working
condition or about a term of his or her employment may file a complaint about the working
condition or the term of employment with the Public Service Grievance Board,
(a) if the public servant is eligible under sections 5 and 7 to file such a complaint;
(b) if the public servant gives notice in accordance with section 8 of his or her
proposal to file the complaint; and
(c) if the public servant complies with the filing requirements set out in section 10.
O. Reg. 378/07, s. 4 (1).
(2) The following matters cannot be the subject of a complaint about a working
condition or about a term of employment:
1. The term or duration of the public servDQW¶VDSSRLQWPHQWWRHPSOR\PHQWE\WKH
Crown.
2. The assignment of the public servant to a particular class of position.
3. A dismissal without cause under subsection 38 (1) of the Act or a matter relating
to such a dismissal.
7KHHYDOXDWLRQRIDSXEOLFVHUYDQW¶VSHrformance or the method of evaluating his
or her performance.
5. The compensation provided or denied to a public servant as a result of the
evaluation of his or her performance. O. Reg. 378/07, s. 4 (2).
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(3) Subsections (1) and (2) do not affect the right of a public servant to file a
complaint under Part V of the Act (Political Activity) or a complaint under Part VI of the
Act (Disclosing and Investigating Wrongdoing). O. Reg. 378/07, s. 4 (3).
EFC
LIGIBILITY TO ILE A OMPLAINT
Eligibility generally
5. (1) Subject to subsections (2) and (3), a public servant or other person is eligible
to file a complaint if he or she was appointed by the Public Service Commission under
subsection 32 (1) or (2) of the Act to employment by the Crown. O. Reg. 378/07, s. 5 (1).
(2) If any of the following circumstances existed at the material time, a public
servant or other person is not eligible to file a complaint:
1. He or she was a member of a bargaining unit represented by a bargaining agent
under the Crown Employees Collective Bargaining Act, 1993 or under the
Ontario Provincial Police Collective Bargaining Act, 2006.
2. He or she was represented by the OntariR&URZQ$WWRUQH\V¶$VVRFLDWLRQRUWKH
Association of Law Officers of the Crown under an agreement between the
Crown and one or both of those Associations.
3. He or she was employed in a position that was classified under subsection 33 (1)
of the Act as a term classified position.
4. He or she was employed for a fixed term,
i. on a non-recurring project,
ii. in a professional or other special capacity, or
iii. on a temporary work assignment arranged by the Public Service
Commission in accordance with a program for providing temporary help.
5. He or she was employed for a fixed term for fewer than 14 hours per week,
employed for a fixed term for fewer than nine full days in four consecutive
weeks or employed for a fixed term on an irregular or on-call basis.
6. He or she was employed for a fixed term during his or her regular school,
college or university vacation period or was employed for a fixed term under a
co-operative educational training program. O. Reg. 378/07, s. 5 (2).
(3) Subsections (1) and (2) do not affect the right of a public servant or other person
to file a complaint under Part V of the Act (Political Activity) or a complaint under Part VI
of the Act (Disclosing and Investigating Wrongdoing). O. Reg. 378/07, s. 5 (3).
Restrictions, complaint about dismissal for cause
6. A person is eligible to file a complaint about dismissal for cause only if,
immediately before his or her dismissal,
(a) he or she had been employed continuously for at least 12 months for a fixed
term or a succession of fixed terms under subsection 32 (1) or (2) of the Act; or
(b) he or she was employed otherwise than for a fixed term and was not on
probation. O. Reg. 378/07, s. 6.
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Restrictions, complaint about a working condition or a term of employment
7. (1) A public servant is eligible to file a complaint about a working condition or a
term of employment only if he or she had been employed continuously for at least six
months before the deadline for giving notice in accordance with section 8 of his or her
proposal to file the complaint. O. Reg. 378/07, s. 7 (1).
(2) Despite subsection (1), the following public servants are not eligible to file a
complaint about a working condition or a term of employment:
1. A public servant employed in a position that is classified under subsection 33 (1)
of the Act as a position within the Senior Management Group.
2. A public servant who is employed as a Branch Director or as a Hospital
Administrator.
3. A public servant who is employed in a position with headquarters located
outside Ontario.
4. A public servant who is employed by the Crown as a lawyer. O. Reg. 378/07, s.
7 (2).
FC
ILING A OMPLAINT
Notice of proposal to file a complaint
8. (1) A person who proposes to file a complaint shall give notice of the proposal to
the following person or entity:
1. A complainant who, at the material time, worked in a ministry shall give the
notice to his or her deputy minister.
2. A complainant who, at the material time, worked in a Commission public body
shall give the notice to the chair of the Public Service Commission. O. Reg.
378/07, s. 8 (1).
(2) Subsection (1) does not apply with respect to a complaint under Part V of the
Act (Political Activity) or a complaint under Part VI of the Act (Disclosing and
Investigating Wrongdoing). O. Reg. 378/07, s. 8 (2).
(3) The notice must set out the reasons for the complaint. O. Reg. 378/07, s. 8 (3).
(4) The notice must be given within the following period:
1. For a complaint about dismissal for cause, within 14 days after the complainant
receives notice of the dismissal.
2. For a complaint about a disciplinary measure, within 14 days after the
complainant receives notice of the imposition of the disciplinary measure.
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. O. Reg. 378/07, s. 8 (4).
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Period for dispute resolution
9. (1) A complainant is not entitled to file a complaint with the Public Service
Grievance Board until expiry of the period provided under this section for dispute
resolution. O. Reg. 378/07, s. 9 (1).
(2) Subsection (1) does not affect the right of a public servant or other person to file
a complaint under Part V of the Act (Political Activity) or a complaint under Part VI of the
Act (Disclosing and Investigating Wrongdoing). O. Reg. 378/07, s. 9 (2).
(3) If the complainant was required to give a deputy minister notice of the proposal
to make the complaint, and if the deputy minister or his or her delegate meets with the
complainant within 30 days after the deputy minister receives the notice, the period
provided for dispute resolution expires on the earlier of,
(a) the day that is 30 days after the meeting; or
(b) the day on which the deputy minister gives written notice to the complainant of
his or her decision about the proposed complaint. O. Reg. 378/07, s. 9 (3).
(4) If the complainant was required to give the chair of the Public Service
Commission notice of the proposal to make the complaint, and if the chair or his or her
delegate meets with the complainant within 30 days after the chair receives the notice, the
period provided for dispute resolution expires on the earlier of,
(a) the day that is 30 days after the meeting; or
(b) the day on which the chair gives written notice to the complainant of his or her
decision about the proposed complaint. O. Reg. 378/07, s. 9 (4).
(5) If the deputy minister or chair of the Public Service Commission, as the case
may be, or his or her delegate does not meet with the complainant within 30 days after
receiving the notice, the period provided for dispute resolution expires 30 days after the
notice was given to the deputy minister or chair. O. Reg. 378/07, s. 9 (5).
Filing a complaint
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. O. Reg. 378/07, s. 10 (1).
(2) The complaint must set out the reasons for the complaint and must include the
notice of the proposal, if any, to make the complaint and such other information and
documents as the Board may specify. O. Reg. 378/07, s. 10 (2).
[2] At the outset of the hearing, the employer presented full argument to support its
SUHOLPLQDU\REMHFWLRQWRWKH36*%¶VMXULVGLFWLRQRYHUWKHVHFRPSODLQWV7KHHPSOR\HU¶V
position, simply put, was that section 8 of ReJXODWLRQ
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Deputy Minister and indeed had not been delegated as evidenced E\WKH0LQLVWU\¶V'HOHJDWLRQRI
Authority Framework Human Resources document. Given that the complainant had not
provided notice to his Deputy Minister in respect of any of these complaints, the employer
argued that these complaints should be dismissed for lack of jurisdiction since, by virtue of
section 4 of Regulation 378/07, notice to the Deputy Minister was an essential precondition of
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[3] In reply, the complainant conceded that he had not given notice to the Deputy Minister in
respect to any of these complaints. HoweveUKHDUJXHGWKDWWKHHPSOR\HU¶VSUHOLPLQDU\
REMHFWLRQVKRXOGEHGLVPLVVHGEHFDXVHLWKDGQRWFRPSOLHGZLWKWKH36*%¶VSURFHGXUDOGHFLVLRQ
dated March 30, 2011. That decision provided as follows:
These grievances came before the Board on March 30, 2011 in order to schedule them.
The parties agreed to consolidate the grievances for the purposes of dealing with
preliminary motions of the employer on October 5, 2011.
Further, the parties have undertaken to provide each other with the following:
1.The Employer will notify the complainant of the number of
preliminary motions to be argued on October 5, 2011 including
a summary statement of each motion by July 29, 2011.
2.The Employer will provide any and all documents it intends to
rely on in the motions by July 29, 2011.
3.The Complainant will advise the Employer and the Board by
September 16, 2011, whether he intends to oppose the motions
or not.
[4] In particular the complainant pointed out that he had not received the Delegation of
Authority Framework Human Resources document that the employer had referred to in its
argument. However, any failure by the employer to comply with this undertaking by not
providing this document in advance of the hearing could not give the PSGB jurisdiction over
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these complaints if in fact Regulation 378/07 did not give it jurisdiction in the first place. At
most any failure of the employer to comply with the undertaking gives rise to a requirement to
provide the complainant with an opportunity to respond to it once it is provided. As a result, in
OLJKWRIWKHHPSOR\HU¶VIDLOXUHto provide Delegation of Authority Framework Human Resources
document to the complainant by July 29, 2011, the Board ruled that it would be appropriate and
consistent with the rules of natural justice to provide the grievor with the opportunity to make
ZULWWHQVXEPLVVLRQVRQWKLVGRFXPHQW¶VUHOHYDQFHDnd to make any further written submissions to
the Board provided that these submissions were made within 30 days of the hearing date of
October 5, 2011.
[5] On November 3, 2011, the Board received a letter from the complainant requesting a 60-
90 day extension of the deadline for submissions. The gist of this request was that 30 days was
QRWVXIILFLHQWWLPHWRSUHSDUHDGHTXDWHOHJDODUJXPHQWLQUHVSRQVHWRWKHHPSOR\HU¶VSUHOLPLQDU\
objection. The Board has considered this request and has determined that it should not be
granted. At the hearing, the complainant had thHEHQHILWRIKHDULQJWKHHPSOR\HU¶VFRPSOHWH
legal argument. This argument was not complex and one that almost exclusively related to the
interpretation of Regulation 378/07. The employer only referred to the Delegation of Authority
Framework Human Resources document to make the point that it had not in fact delegated the
power of the Deputy Minister to receive notice of a complaint. The Board considers that the
complainant has been given more than adequate time to respond fully toDOORIWKHHPSOR\HU¶V
arguments.
>@7KH%RDUGQRZWXUQVWRWKHHPSOR\HU¶VSUHOLPinary objection. In an earlier decision, the
Board dealt with the legal implications of the requirement to give notice of a complaint to the
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Deputy Minister. In Jackson v. Ontario (Ministry of Community Safety and Correctional
Services) [2011] O.P.S.G.B.A. No. 8 the Board made it clear that notice to the Deputy Minister
was an essential precondition for it to take jurisdiction over a complaint. At paragraph 38 of that
decision, the Board stated:
Furthermore, there was no suggestion that the Board can simply ignore the fact that the
preconditions in sections 8 and 9 were bypassed, or that there is power in the Board to
treat the matter as if those preconditions had been met. Nor am I aware of any authority
to that effect. In the result, it would appear that the complainant was not eligible to file
the grievance under s. 9 because none of the pre-conditions as to notice and allowance of
opportunity for the dispute resolution process occurred. If the complainant was not
eligible to file the grievance, there is no grievance properly before the Board, and it must
be dismissed.
[7] The Board notes that this decision was made available to the complainant at the hearing
and he had full opportunity to make submissions on its implications. The Board also notes that
the complainant at the hearing conceded that he had not given notice to the Deputy Minister in
respect to any of the complaints dealt with in this decision.Given that the required notice was
not given by the complainant in respect of any of these complaints, the legal consequences are
that the complainant was not eligible to file these complaints with the Board so that these
complaints are not properly before the Board.
[8] For these reasons all of these complaints must be dismissed.
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Dated at Toronto this 8 day of November 2011.
Donald D. Carter, Chair