HomeMy WebLinkAbout2010-2473.Jeronimo et al.12-06-26 DecisionCrown Employees
Grievance Settlement
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Commission de
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GSB#2010-2473
UNION#2010-0290-0026
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Jeronimo et al) Union
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The Crown in Right of Ontario
(Ministry of Children and Youth Services) Employer
BEFORE Brian P. Sheehan Vice-Chair
FOR THE UNION Devon Paul
Ryder Wright Blair & Holmes LLP
Barristers and Solicitors
FOR THE EMPLOYER Robert Fredericks
Ministry of Government Services
Labour Practice Group
Counsel
HEARING May 24, 2012.
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Decision
[1] The issue in dispute concerns a group grievance filed by Youth Service Workers
employed in the Female Division of the Roy McMurtry Youth Centre asserting that the
Employer had improperly sought to recover a claimed overpayment of wages.
[2] At the commencement of the hearing, Mr. Fredericks, on behalf of the Employer, made a
motion that the Board should dismiss the grievance on the basis that particulars relied upon by
the Union did not disclose a prima facia case.
The Facts
[3] The relevant written particulars filed by the Union which, for the purposes of the prima
facia motion, the Employer accepted as true, were as follows:
• On June 15, 2009, the Female Division of RMYC commenced a new
yearly schedule, which was completed on June 15, 2010.
• On November 19, 2009, Bruce England, president of Local 290, attended a
meeting to discuss the then-ongoing staffing complement review. At that
meeting, and in passing, Mr. Don Poynter mentioned to Mr. England that
the schedule was producing a sixteen (16) hour deficiency every twenty-six
weeks. Mr. England acknowledged the statement, but neither agreed nor
disagreed that it was correct.
• In late May, 2010, Mr. England was contacted by Mr. Bill Mowat, Project
Manager, who informed Mr. England that HPRO would balance with the
then-current schedule.
• Between the November 19, 2009 meeting and the contact from Mr. Mowat
in late May 2010, there had been no communications between the officials
of Local 290 and any member of management regarding the deficiency in
the schedule.
• On June 2, 2010, Stephanie Hedger, then the Senior Manager of the Female
Division, sent an e-mail with the subject line “Female Division Schedule
Change” to all employees in the Female Division stating that the schedule
to be completed on June 15, 2010 had resulted in an overpayment of thirty-
two (32) hours over the entire course of the schedule.
• Ms. Hedger stated that these hours had been paid but not worked, and that
this must be rectified by June 14, 2010.
• Specifically, in the June 2 e-mail, Ms. Hedger stated “Through facility
reviews it has been identified that the Female Division schedule does not
balance to the required 1040 hours. The current schedule produces 1024
hours though the Employer has paid for 1040 (32 hours deficiency)
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(current schedule attached). The implementation of HPRO has highlighted
the timeline with which the Female Division will be through the completed
cycle of the current schedule – everyone at a zero balance – this date is
JUNE 14. Implementing a new schedule by this date will allow for a
CLEAN slate/start moving forward.” [Capitalization in original]
• Ms. Hedger notified the employees that the management of the Female
Division had decided to take action to rectify the schedule imbalance by
adding four (4) hours to four eight (8) hour shifts.
• Ms. Hedger went on to state “In the fall (approximately) we will be
negotiating a new Female Division schedule reflective of our new staffing
model. Understanding this, we still need to move forward with resolution
to our current schedule. The facility is incurring expenses for hours not
worked and all schedules must balance for HPRO to work properly.”
• This changed schedule came into effect on June 15, 2010.
• The changed schedule resulted in employees working three twelve (12)
hour shifts, four hours more than the eight (8) hours per day provided for in
Art. COR8.3.1.
• In an e-mail dated August 5, 2010, Ms. Hedger offered employees three
options to make up the overpayment: use vacation time, pay the claimed
overpayment back through a payroll deduction or work hours off.
• In the August 5 e-mail, Ms. Hedger instructed that the “balancing of hours”
was to be completed by December 31, 2010.
• It was not until August 5, 2010 that employees were notified by Ms.
Hedger that the Employer intended to recover the deficiency of hours.
• On August 16, 2010, the Female Division began a new schedule which
required a reconciliation between the hours paid and the hours worked to
that date.
• On August 20, 2010, the employees in the Female Division received an
updated “reconciliation of hours”.
• On August 24, 2010, Ms. Hedger, at that point the Deputy Youth Centre
Administrator – Operations, sent out an e-mail reiterating that the
overpayment must be either repaid or worked off. The Grievors, believing
that there would be a “clean slate” as of June 15, 2010, carried on their
individual household budgetary arrangements, not realizing that money
should be saved to repay the deficiency of hours.
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• As a result of the Grievors continuing their individual household budgetary
arrangements, many Grievors did not have sufficient funds on-hand to
repay the deficiency of hours when requested by the employer, and were
required to make use of other means, such as working additional hours or
permitting deductions from their paycheques.
[4] For those employees who chose the option of working off the outstanding hours the
December 31, 2010 deadline to achieve a zero balance owing was subsequently extended by the
Employer. Ultimately, the vast majority of employees chose the option of working the
outstanding hours they owed.
Discussion and Decision
[5] The Employer initially asserted that there would be two branches to its prima facia
motion; (1) that the particulars relied upon by the Union failed to disclose a breach of the
collective agreement and therefore the Board had no jurisdiction to hear the matter and (2) that
the particulars also failed to establish that either the doctrine of estoppel or the doctrine of
waiver, as asserted by the Union, was applicable to the facts of this case. At the hearing it,
however, became clear that the Union was not asserting that there had been a breach of the
collective agreement. Accordingly, the relevant issue was whether the Union’s particulars failed
to establish a prima facia case for the application of either the doctrine of estoppel or the doctrine
of waiver.
[6] As outlined in Re Couture et al GSB 2008-3329 (Dissanayake) the appropriate analytical
framework to be adopted by the Board with respect to a prima facia motion, is whether the facts
asserted in support of the grievance, if accepted as true, are “capable of establishing the
elements necessary to substantiate the violation as alleged”. In the context of this case the
relevant question is thus; whether the particulars relied upon by the Union, if accepted as true,
were capable of establishing the required elements for the application of the doctrine of estoppel
or the doctrine of waiver.
[7] Mr. Paul, on behalf of the Union, asserted that the decision in Re Pinazza 2002-0840 et al
(Herlich) represented a change by this Board as to the appropriate basis to evaluate a prima facia
motion. That case involved a claim of sexual harassment by a number of bargaining unit
employees against a managerial employee. That managerial employee was granted third party
status at the hearing and it was on his behalf that the prima facia motion was brought, asserting
that his actions did not constitute sexual harassment. That argument was advanced
notwithstanding the fact the employer conceded that certain of his actions constituted sexual
harassment. Vice-Chair Herlich in assessing the particulars relied upon by the union determined
he was not convinced “that it was impossible to arrive at the conclusion” that at least some of the
managerial employee’s conduct amounted to sexual harassment and on that basis he dismissed
the prima facia motion. For the Union this reference to “impossible to arrive at the conclusion”
suggested that a less rigorous standard should be utilized in evaluating whether a party has
established a prima facia case.
[8] In my view, the Union’s argument on this point places far too much significance on a
simple turn of phrase. In dismissing the prima facia motion, Vice-Chair Herlich did not, in any
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way, delve into an analysis as to the appropriate test to be adopted by the Board with respect to a
prima facia motion. In this regard, I view his usage of the phrase “impossible to arrive at the
conclusion” as nothing more than his way of rephrasing the traditional analytical framework and
did not suggest that a less rigorous standard should be employed when evaluating whether a
party has established a prima facia case.
[9] The Union’s primary argument is that the Employer should be estopped from seeking to
recover the outstanding hours owed by employees. The required elements associated with the
application of the doctrine of estoppel, were set out by this Board, in Re Brown 0513-86
(Barrett) as follows:
i. The party with the contractual right makes a representation to the other
party that it will not be insisting on strict compliance with that right.
The representation need not be expressed but can be implied from the
conduct of the party making it. The conduct gives rise to an estoppel
only where it leads the promissee reasonably to believe that an
undertaking was being given.
ii. The representation relied upon must be clear and unequivocal. Conduct
which is ambiguous or subject to a number of conflicting
interpretations cannot form the basis of an estoppel.
iii. The promise must be one that is voluntarily given; not extracted by
force or coercion.
iv. The promise must be one which was intended, or was reasonably
construed as being intended, to affect the legal relations between the
parties. A person may well grant an indulgence without ever intending
to forego his strict legal rights. The promisor is not estopped from
relying on terms which in the past have not been enforced through error
or inadvertence.
v. The person relying on estoppel must show that he altered his position
on the strength of the promise or representation that was made. An
alteration of position may take the form of a positive act or that of an
omission. It is sufficient if the promissee has been induced to conduct
himself differently than he otherwise would have done. Such conduct
must be shown however to have been in reliance on the promise. In the
labour relations context reliance may take the form of forebearing to
raise an issue at the bargaining table which but for the promise would
otherwise have been raised.
vi. It must be shown that the alteration of position by the promissee was to
his detriment or prejudice.
[10] The Union’s estoppel argument is factually straightforward. It is asserted that Ms.
Hedger’s June 2 e-mail constituted a representation to the staff that the Employer would not be
seeking recovery for the overpayment of wages. Specifically, the absence of any reference to the
Employer seeking recovery for the identified overpayment combined with the statement that the
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implementation of the new schedule effective June 14 “will allow for a Clean slate/start date
moving forward” constituted a clear representation that any overpayment associated with the
prior schedule would not be pursued by the Employer.
[11] It is acknowledged that that the grievors may well have perceived that the Employer,
through Ms. Hedger’s e-mail, had made a commitment that it would not be seeking recovery for
the overpayment of wages. In fact, it could be suggested that such a belief was arguably a
reasonable view of the Employer’s position at that particular point in time. At the same time, it
could be suggested that another plausible reading of Ms. Hedger’s e-mail was that its primary
focus was on addressing the implementation of the new agreed-to schedule. In that context, the
reference to “Clean slate/start” was related to confirming that, as of June 14, all relevant
employees would have completed the cycle of the current schedule; accordingly that date, would
be a fresh jumping off point for the parties to move forward under the new revised schedule.
[12] As suggested in Re Brown supra, statements, or conduct, which are open to possible
conflicting interpretations are inimical to a finding of an estoppel; for a party to be estopped,
there needs to be evidence of a clear and unequivocal representation to forego one’s legal rights.
The Union’s particulars come up short in establishing that Ms. Hedger’s e-mail constituted such
a clear and unequivocal representation by the Employer that it was not going to rely on its legal
rights to pursue recovery of the overpayment of wages.
[13] Even if it could be suggested that Ms. Hedger’s June 2 e-mail constituted a clear and
unequivocal representation by the Employer that it was not seeking to recover the overpayment,
the Union’s particulars fall well short of establishing the fundamental required element of
detrimental reliance.
[14] Detrimental reliance, for the purposes of an estoppel argument, suggests that a party is in
a worse off position, either by failing to act, or by acting, as a result of reliance on the
representation that the other party would not be enforcing its legal rights. As stated in Re Carter
2291/86 (Knopf):
Detrimental reliance connotes lost opportunity and lost potential.
….Taken at its best, the evidence establishes the grievors were slightly
inconvenienced. …. There is no evidence that the Union acted to its
detriment or indeed relied upon the course of conduct. Thus, there is no
evidence that the Union, as a party to the collective agreement, was
induced to act to its detriment. Since detrimental reliance is a
fundamental element in the doctrine of estoppel, the absence of the
underlying facts to support the detrimental reliance is fatal to a claim
based upon estoppel.
[15] Mr. Paul submitted that the reasoning of the Supreme Court of Canada in Ryan v. Moore
[2005] 2 S.C.R. 53 constituted a change in the judicial treatment of the concept of detrimental
reliance. Specifically, it was asserted that decision stands for the proposition that the party that
relied upon a representation, no longer necessarily had to establish that they actually experienced
any detriment, as in being in a worse off position. It was enough for the party to establish that it
would be unfair or unconscionable to not allow for the enforcement of the representation made
by the other party.
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[16] The facts of Ryan v Moore supra, involved a motor vehicle accident where a claim of
negligence was commenced against the defendant and his insurer some twenty-three months
from the date of the accident. Unbeknownst to the plaintiff, the defendant passed away some
thirteen months after the accident. The action was timely under the two-year period limitation
period set out by Newfoundland and Labrador’s Limitations Act but was outside the six-month
limitation period under that province’s Survival of Actions Act. The basis for the estoppel by
representation argument was the suggestion that the insurer was obligated to notify the plaintiff
of the death of the defendant during discussions the parties had prior to the formal
commencement of the action.
[17] The Supreme Court’s comments in Ryan v. Moore supra, regarding detrimental reliance
were obiter; as the Court determined that the insurer’s silence regarding the death of the
defendant did not constitute a representation for the purposes of an estoppel by representation as
the insurer was not under a legal duty to inform the plaintiff of the passing of the defendant. It is
also noted that the discussion of detriment that the Union relied upon arose in the context of
whether there existed, on the facts, an “estoppel by convention”. Moreover, a reading of the
decision as a whole, suggests that the Court’s view of detrimental reliance, was in fact
completely consistent with how that concept has been traditionally defined in arbitral
jurisprudence. In particular, the Court offered the following observation:
Detrimental reliance encompasses two distinct, but interrelated,
concepts: reliance and detriment. The former requires a finding that
the party seeking to establish the estoppel changed his or her course
of conduct by acting or abstaining from acting in reliance upon the
assumption, thereby altering his or her legal position. If the first step
is met, the second requires a finding that, should the other party be
allowed to abandon the assumption, detriment will be suffered by the
estoppel raiser because of the change from his or her assumed
position.
[18] In the case at hand, the Union suggested that detrimental reliance arose as a result of the
passage of time between Ms. Hedger’s June 2 e-mail and her August 5 e-mail, when the
Employer went on the record advising employees of various available options to repay the
outstanding wages owed. It was suggested that during this passage of time, the grievors
continued on with their normal household budget arrangements not realizing that money needed
to be put aside to repay the overpayment of wages.
[19] It is not disputed the amount of money owed constituted a significant amount of money
for the grievors. That being said, based on the particulars filed, there is no basis to suggest that
any of the grievors were in a worse off position as a result of the purported representation by Ms.
Hedger that as of June 2, 2010 the Employer would not be seeking to recover the overpayment of
wages. None of the grievors materially altered their position as a result of the Employer’s
purported representation. This is not a case where the grievors were claiming they undertook
significant financial commitments as a result of being of the belief that the Employer would not
be seeking to recover the overpayment of wages. The Union’s argument may well have had
more traction if in fact the Employer in its August 5 e-mail took the position that the grievors had
to immediately, or within a relatively short time frame, repay the outstanding monies owed and
that certain of the employees as a result of such an immediate demand for repayment had to take
certain measures, that placed them in a worse off position, to obtain the necessary money to
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repay the debt. The grievors, however, were given three options, including working off the
hours owed over an extended period of time. The overwhelming majority of the grievors took
advantage of that option.
[20] In the alternative, the Union submitted that the doctrine of waiver was applicable to the
actions of the Employer. The framework of this argument was that the Employer, by way of Ms.
Hedger’s June 2 e-mail, and the implementation of the new revised schedule, waived its claim to
the overpayment. Specifically, by taking the “fresh step” of introducing the new schedule
without alerting the grievors and the Union that the Employer would be seeking recovery for the
overpayment of wages, the Employer, in fact, waived its right to claim the overpayment.
[21] As with its estoppel argument, the Union’s reliance on the doctrine of waiver runs into a
number of insurmountable obstacles. It is clear that the recovery of the overpayment of wages
from the employees involved, constituted a substantive right of the Employer. There is a
significant question in the arbitral jurisprudence, as to whether the doctrine of waiver is
applicable with respect to a substantive, as opposed to a procedural, right of a party. At a
minimum, the jurisprudence suggests that an arbitrator should be extremely careful in resorting
to the doctrine of waiver to nullify a party’s substantive rights. Re Canada Post Corporation and
C.U.P.W (1991) 22 L.A.C. (94th) 430 (Jolliffe)
[22] Even if the Union could get over the “substantive right” hurdle, the doctrine of waiver
suggests that the waiving of the right must be informed and direct. Re Board of Governors of the
Riverdale Hospital and C.U.P.E.(2000) 93 L.A.C. 4th 195 (Surdykowski) There is no basis to
suggest that the Employer, by implementing the new revised schedule, was knowingly and/or
directly waiving its right to claim for the overpayment of wages.
[23] In conclusion, the particulars relied upon by the Union failed to establish a prima facia
case for either the application of the doctrine of estoppel or the doctrine of waiver. Accepting
the facts asserted by the Union as true, the grievance would not succeed. In the circumstances,
the Employer’s motion is upheld, and the grievance is hereby dismissed.
Dated at Toronto this 26th day of June 2012.
___________________________
Brian P. Sheehan, Vice-Chair