HomeMy WebLinkAbout1983-0706.Brown.84-08-21SETTLEMENT
706/83
747183
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
Between:. OPSEU (C. M. Brown)
Grievor
- And -
The Crown in Right of.Ontario
(Ministry of Natural Resources)
Employer
Before: R. J. Roberts Vice Chairman
H. Simon Member
D. B. Middleton Member
For the Grievor: R. Nabi
Grievance Officer
Grievance Section
Ontario, Public Service Employees Union
For the Employer: W. M. Kenny, Counsel
Hicks Morley Hamilton Stewart Storie
Barristers & Solicitors
Hearing Date: June 29,.1984
7 -2-
INTERIM. DECISION
The matter before us involves two grievances in which
the Grievor grieved his suspension pending investigation into
possible misappropriation by the Griever of photographic and
audio/visual equipment belonging to the Ministry. At the out-
set of the hearing, the Ministry objected to jurisdiction on two
separate grounds. The first ground was that the suspension
was not reviewable by the Grievance Settlement Board because it
was not yet of a disciplinary nature; the second ground was
that, in any event, the second grievance was inarbitrable because
of failure on the part of the Union to observe the time limits
specified in the grievance procedure set forth in the Collective
Agreement. We proceeded to hear evidence~and argument regarding
these two preliminary objections and then adjourned the hearing
to prepare this interim award.
On October 4, 1983,th~e Grievor received the following
letter from the Office of the Deputy Minister:
"Dear Mr. Brown:
In accordance with Section 22(l) of the Public
Service Act, this is to,notify you that you
are hereby being suspended from employment for
20 days pending investigation of possible
misappropriation by you of Ministry photographic
and audio/visual equipment.
This suspension, with pay, is effective from
October, 4, 1983, and will continue up to and
including November 1, 1983. YOU are to surrender
all keys, within your possession, to Ministry
offices, file cabinets and desks to Mr. T. Coleman,
Director, Communications Services Branch forthwith,
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You will not be permitted to enter the Communications
Services Branch without the permission of Mr. Coleman,
or until further notice.
Yours very truly
'R. J. Burgar'
W. T. Foster
for Deputy Minister"
The Grievor was notified that he was suspended from employment in
accordance with Section 22(l) of the Public Service Act. This
suspension was with pay.
On October 12, 1983, the Grievor filed a grievance stating,
"I grieve that the suspension imposed on me, as set out in the
'letter of October 4, 1983,...is unfair, unwarranted and unjustified."
The settlement that was requested was "[withdrawal] of the suspension
imposed, as well as having that suspension expunged from all
records."
While the suspension which was referred to in the letter
of October 4 was for 20 days, it was periodically extended by
letter from the Deputy Minister, so that it extended up to and
beyond the date of the hearing. This procedure was necessitated,
apparently, because the suspension purported to be a suspension
"pending an investigation" pursuant to Section 22(l) of the
Public Service Act, R.S.O. 1980 C. 418. The regulations under
the Act prescribed that in such cases, "the period of suspension
shall not exceed twenty working days". Regulation 881, section 18(l).
In order for the Deputy Minister to extend the twenty-day period,
it was necessary to take action pursuant to Section 18(2) of
regulation 881, which reads as follows:
"(2) Notwithstanding subsection Cl), where in the
opinion of the deputy minister, an additional
period of time is required to complete the
investigation, the deputy minister may renew
the period of suspension for not more than
twenty working days in each case, for such
additional periods as are considered necessary."
Under this provision, the Deputy Hinister was entirled to extend
the twenty day suspension for such additional periods of time
as were, in the opinion of the Deputy. Minister, consider&
necessary to complete the investigation.
On November 29, 1983, the Deputy Minister sent the
following letter to the Grievor:
"Dear Mr. Brown.:
Further to my letters of October 4 and 27 1983, this
will advise you that in accordance with Section 22(l)
of the Public Service Act, you are hereby suspended
from employment pending,the determination of criminal
charges against you relating to the possession of
stolen ministry property. At such time as these
charges are disposed of, the ministry will review
the matter and take ,appropriate employment action.
This suspension will be without pay and :is effective
from December 1, 1983 up to and including December
30 1983. During this period or until further
notice you will not be permitted to enter the
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Communications Services Branch without the permission
of Mr. T. Coleman.
While recognizing the criminal nature of the charges
against you, if you believe that you have information
of these circumstances that should be considered by
the Ministry, you should advise Mr. T. Coleman,
Director of the Communications Services Branch.
Yours very truly,
'W. T. Foster'
W. T. Foster
Deputy Minister"
The impact upon the Grievor of this action was to deny him pay
during the remainder of the suspension period. The nature of' the
.suspension did not change. It still purported to be a suspension
pending investigation pursuant to Section 22(l) of the Public
Service Act.
For some reason which was not made clear to this Board,
the Grievor initiated a second grievance in response to the above
letter. The grievance was in essentially the same form as the
first one that was filed. The only material difference rested
in the addition of the phrase, "with no pecuniary and benefits loss",
to that part of the grievance form headed, "Settlement Required".
This grievance went to step 1 of the grievance procedure set forth
in the Collective Agreement; however, the Union did not refer it
to step 2 within the required time limit. Instead, on December
-6-
19, 1983, the grievance was referred directly to the Grievance
Settlement Board. By letter dated January 24, 1984, the
Ministry advised the Registrar of the Grievance Settlement
Board that it "intends to take the position that this grievance
is not arbitrable as it has not been processsed in accordance
with the mandatory grievance procedure set out in Article 27
of the Collective Agreement."
We now turn to consideration of the two grounds of
preliminary objection which were raised at the hearing. The
first ground of preliminary objection rested upon a submission
from Counsel for the Ministry that so long as the Deputy Minister
suspended the Grievor pursuant to Section'22(1) of the Public
Service Act, the Grievance Settlement B,oard lacked jurisdiction
to review the suspension. This submission was based upon a
sophisticated analysis of the operation of Sections 22(l) and
22(2) of the Public Service Act in conjunction with Sections 18
.and 19 of the Crown Employees Collective Bargaining Act, R.S.O.
:1980 c. 108.
The essence of the argument turned upon an interpretation
of Section 18(2)(c) of the Crown Employees' Collective Bargaining
Act. This -
" (2 1 In addition to any other rights of grievance
und le r a collective agreement, an employee claiming...
provision reads as follows:
(c) that he has been disciplined or dismissed or suspended from his employment without
just cause, may process such matter in
accordance with the grievance procedure
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provided in the collective agreement, and
failing final determination under such
procedure, the matter may be processed
in accordance with the procedure for final
determination applicable under section 19."
Counsel ably argued that jurisdiction to review suspensions pursuant
to this provision was limited to disciplinary suspensions, and not
suspensions for investigation.
Turning to the provisions of the Public Service Act, Counsel
submitted that the non-disciplinary nature of a suspension for
investigation under Section 22(l) could be highlighted by contrast-
ing its wording with that of Section 22(2). The latter provision
reads as follows:
"22(2) .A deputy minister may for cause remove from
employment without salary any public servant in his
ministry for a period not exceeding one month or
such lesser period as the regulations prescribe."
The attention of the Board was drawn to the emphasis in this
provision upon removal for cause, and the absence of any similar
wording in Section 22(l). It was contended that this difference
between the two provisions indicated that under Section 22(l),
the Deputy Minister had authority to suspend without cause;
otherwise there would have been no need for the legislature to
enact Section 22(l).
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The Union did not respond at length to the matters of
statutory interpretation which were addressed in the foregoing
argument: rather, the thrust of'the Union's submission went to
the question whether the suspension of the Grievor was a Section
22(2)-type'kemoval for cause"masquerading as a Section 22(l)
%uspension pending investigation". Counsel for the Union submit-
ted that either from the outset or at some point during the
lengthy period of suspension of the Grievor, the character of
the suspension became disciplinary, and not investigatory in
nature, thereby rendering the merits of the suspension reviewable
by the Grievance Settlement Board.
Based upon these submissions, it appears that the
Board does not have jurisdiction to review the merits of a
suspension "pending an investigation" under Section 2211) of the
'Public Service Act. Even so, however, the mere declaration
by or on behalf of the Deputy Minister that a suspension is
"pending an investigation" within the.meaning of Section 22(l),
would be insufficient to oust the jurisdiction of the Board.
Under Section 19(l) of the Crown Employees Collective Bargaining -
Act, the Grievance Settlement Board has jurisdiction to determine -
"whether a matter is arbitrable". Pursuant to this jurisdiction,
the Board has the duty, in proper cases; to determine whether
a particular suspension actually was or continued to be "pending
an investigation" within the meaning of Section 22(l) Of the
Public Service Act. If, in such an inquiry, it was found that
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this was not the case, then it would seem that the Board would
have jurisdiction to review the.merits of a claim that the
suspension was without just cause.
As we understood the arguments at the hearing, it did
not-seem that Counsel for the Ministry disagreed with this point.
He did, however, submit that in enquiring whether a suspension
actually was or remained "pending an investigation" within the
meaning of Section 22(l), the standard of review. permitted to the
Grievance Settlement Board would be narrowly circumscribed. In
support of this submission, Counsel referred to Section 18(2)
of regulation 881 under the Public Service Act. He pointed
out that this regulation left to the "opinion of the deputy
minister" the question whether "an additional period of time is
required to complete the investigation;? Counsel sub-
mitted~ that the power of the Grievance Settlement Board to
review the question would be limited to determining
whether the opinion of the Deputy Minister that additional time
was required was reached in good faith. The regulation would
constitute a bar to full-scale review of the correctness of
the decision.
At this point in time, it does not seem convenient to
make a ruling upon the foregoing submission. The submission
does not go to the merits of the preliminary objection. Upon
these merits, we conclude that the preliminary objection succeeds,
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to the following extent: that at the moment at least, our
jurisdiction is limited to determining whether the suspension . .._
of the Grievor actually was and continued to be under Section 22(l)
of the Public Service Act. It would seem most appropriate to
defer making any ruling upon the standard of,review to be applied
with respect to this issue until after the Board has heard evidence
and argument upon the matter.
At this point, it seems that without the assistance of
agreement.between the parties, the Board will not yet be in a
position to hear evidence and~argurnent upon the merits of the.
suspension. The determination that the Board must make upon the
above jurisdictional issue is not analogous to that in “release
versus dismissal" cases. In those cases, as is well known,
the question of jurisdiction usually falls to be decided upon
the same evidence as the merits. As a result, it is common to
hear evidence of the merits before determining the jurisdictional
issue. In this case, this is not so. The evidence bearing
upon the issue of jurisdiction differs from that bearing upon
the merits of the suspension. with respect to jurisdiction,
for instance, evidence relating to the existence of on-going
investigative efforts would seem to be of primary importance.
Of primaryimportance on the merits, however, would be
evidence relating to the existence of just cause for the
suspension.
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Turning to the second ground of preliminary objection,
i.e., the failure of the Union to refer the second grievance
to step 2 of the grievance procedure in a timely manner, Counsel
for the Ministry made an extensive submission which seemed
principally designed to induce the Board expressly to resile
from or alter its holding in Re Keeling, G.S.B. No. 45/78 (Prichard).
This holding was summarized as following:
' In [Re Keeling]... the grievance violated the
mandatory time limits in the collective agreement
between the parties. Th,e Board held that the
mandatory time limits were inconsistent with
section 17(2) of the Crown Employees' Collective --- Bargaining Act and could not therefore act as an
absolute bar to the processing of the grievance.
The Board did make clear, however, that this
decision did not eliminate the relevance of
delay in processing grievances but rather made
delay a matter going to the merits of the case
as opposed to the Board's jurisdiction. The
employer sought judicial review of that decision
in the Divisional Court but in an unreported
decision dated April 14, 1980 the court denied the
employer's application. The employer then sought
leave to appeal to the Court of Appeal and was
again unsuccessful. . ..' Re Clements and L.C.B.O.,
G.S.B. No. 112/80 (Prichard),~ at 7.
Counsel sought to persuade us that this decision was wrong and
should, in effect, be overruled.
We must, however, decline this invitation. .-This case
does not appear to be an appropriate vehicle for making such an
important determination. While it seems evident that
subsequent pan&s of the Grievance Settlement Board have, k
dictum, retreated from the ratio of Re Keeling, e.g.,,
- 12 -
Re Lam and Ministry of Transportation and Communications, G.S.B. ----
No. 377/83 (Jolliffe); Re McGregor and Liar Control Board ---
of Ontario, G.S.B. No. l/80 (Weatherill), it would seem that full-
blown reconsideration of Re Keeling should await strong facts
which necessitate determination of the issue: This would accord
with the policy of the Grievance Settlement Board that one panel
of the Board should be hesitant to refuse to follow the decisions
of other panels. See.Re Bateman, G.S.B. No. 2/77 -
In the present case, the facts do not require consideration
of Re Keeling. In our view, it would not be inconsistent with
the holding in that case to refuse jurisdiction of the second
grievance,by virtue of the failure to comply with the mandatory
time limits set forth in the Collective Agreement. The thrust
of Section 18(2) (c) of the Collective Agreement appears to be
to provide the employee with an opportunity to place "the matter"
before the Grievance Settlement Board for final determination.
In the present case, "the matter" undoubtedly is the suspension
of the Grievor. The first grievance, which was processed in
accordance with the grievance procedure of the Collective Agreement,
sufficed to place this suspension before the Board.
The second grievance was not at all necessary. As
indicated earlier in this interim award, the most that the
second grievance did was to add to the requested remedy a claim
for lost wages and benefits. The second grievance did not
alter the continuing nature of the first. It was common ground
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between the parties that it was unnecessary for the Grievor to
file a new grievance every time'he was notified that his suspension
was being extended for another 20 days.
There seems to be little doubt that it also was unnecessary
for the Grievor expressly to add to the matter the specific remedial
request that was made in his second grievance. By virtue of the
legislative framework of the Crown Employees Collective Bargaining
Act, the Board already possessed implied remedial authority to -
grant such relief under the first grievance. The crown Employees:
Collective Bargaining empowers the Board to make a final and
binding decision upon the matter before it. In addition, there
is provision for substituting a lesser penalty in discipline and
dismissal cases, where.it is considered t-o be just and reasonable
to a0 SO. 'In Re Polymer Corporation Limited (19591, 10 L.A.C.
51 (Laskin), affd. 26 D.L.R. (2d) 609 (Ont. H.C.X), affd, 28 D.L.R.
(2d) 81 (Ont. C.A.), affd. 33 D.L.R. (2d) 124 (S.C.C.), a.similar
type off legislative framework was recognized as an arbitral mandate
for fashioning-effective remedies. Moreoever "following the
reasoning in the Polymer decision, arbitrators have generally
refused to conclude that their power to grant a remedy is precluded
by the absence of a specific remedial request in a grievance or
submission to arbitration." Brown & Beatty, ,Canadian Labour
Arbitration, 2nd edition, at 60-61. Accordingly, it was unnecessary
for the Grievor to file a second grievance to place before this
Board his specific remedial request for lost wages and benefits.
The first grievance sufficed to place this aspect of "the matter"
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within our reach. ., : ,, :
The first ground of preliminary objection is allowed to
the extent already indicated in this interim award. The second
ground of preliminary objection is allowed, and the second
grievance is dismissed for want of jurisdiction thereof, The
parties are directed to contact the Registrar of the Grievance
Settlement Board for the purpose of setting down a second day
of hearing in this matter at the earliest possible moment.
.DATED at I,ondon, Ontario this 21st day of' August,
1984.
2 ,/Y, /5&;-l&4/~
D. B. Middleton, Member
,: