Back
to database description
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
* UNJUST DISMISSAL *
* *
* Produced by : Human Resources Development Canada *
* Provided by : Canadian Centre for Occupational Health and Safety *
* * * * * * * * * * * * * * * * * * * * * * * (99-1) November 1998 *
ADJUDICATION DECISION REFERENCE NUMBER : 0721-NFLD
INDUSTRY TYPE : 12 Mining and Mineral Processing
EMPLOYER'S NAME : SEDPEX INCORPORATED
LOCATION OF EMPLOYMENT : St-John's, Newfoundland
COMPLAINANT'S NAME : DEVEREAUX, John
COMPLAINANT'S SEX : Male
COMPLAINANT'S OCCUPATION : Assistant Driller
COMPLAINANT'S DATE OF EMPLOYMENT : 1983/07/01
COMPLAINANT'S DATE OF DISMISSAL : 1986/03/31
COMPLAINANT'S LENGTH OF SERVICE : 2 years and 8 months
HRDC OFFICE WHERE THE COMPLAINT WAS FILED :
ASA NEWFOUNDLAND REGION
Newfoundland Region
STAGE AT WHICH COMPLAINT WAS RENDERED INACTIVE :
110 Reviewed by Federal Court of Appeal
REASONS FOR DISMISSAL :
3.1200 Lack of work
COURT OF FIRST DECISION : Adjudicator
PRELIMINARY OBJECTIONS :
61.5311 LACK OF WORK
DISPOSITIONS :
0.0210 Preliminary objection - Dismissed
NUMBER OF WEEKS AWARDED : 0 Weeks
DOLLAR AMOUNT AWARDED : 0 $
END DATE OF FIRST DECISION : 1988/01/01
COURT OF SECOND DECISION : Federal
NUMBER OF WEEKS AWARDED : 0 Weeks
DOLLAR AMOUNT AWARDED : 0 $
END DATE OF SECOND DECISION : 1988/11/18
AWARD SUMMARY :
FACTS:
- The Complainant had been off work due to a non work-related accident.
- The Complainant had received several evaluations which highlighted deficiencies in his work. His performance was rated as the lowest of those in the same position.
- Another individual with experience was hired from within the Employer's parent company and eventually preferred over the Complainant when one Employees was to be laid off.
- The Complainant was given two weeks' pay in lieu of notice and six days severance pay upon termination.
PRELIMINARY OBJECTION: Lack of Jurisdiction - "Laid off due to lack of work"... Dismissed...
ADJUDICATOR'S COMMENTS AND FINDINGS ON PRELIMINARY OBJECTION:
- The burden was on the Employer to establish a lack of work.
- Where an Adjudicator cannot decide on a balance of probabilities whether a lack of work exists, the employee must be given the benefit of the doubt.
- The lack of work must be established by objective evidence.
- There was no discontinuance of a function and no position had been abolished.
- There was no evidence of a slow-down in the area in which the Complainant had worked. He was the only Employee affected.
- The termination based on a lack of work was a sham.
- The Adjudicator retained jurisdiction to hear and rule on the substantive issue at a later date.
DECISION OF FEDERAL COURT (TRIAL DIVISION): November 18, 1988.
- Emloyer sought a writ of prohibition to preven adjudicator from hearing merits of complaint since adjudicator's finding that Complainant not dismissed due to lack of work involved errors of fact and law.
- Adjudicator must have opportunity to hear all evidence and make final decision before that decision can be reviewed by Federal Court of Appeal pursuant to s.28 of Federal Court Act.
- Inconsistent with purposes of s.61.5 (now s.240) if Federal Court were to make de novo & routine factual decisions as to whether lay off due to lack of work prior to Adjudicator making final decision.
- Adjudicator has jurisdiction to hear complaint since he committed no reviewable error of law or of fact.
- See discussion on Scope & Criteria for Judicial Review (pp. 5-9).
SPECIAL ISSUES DISCUSSED :
3.5010 Sick leave - Position Filled While Absent
5.2100 Nature of employer
1.3000 Burden of proof
12.0100 Employer's section criteria used to lay-off employees
Damage to employer's image
ADJUDICATOR'S NAME : BROWNE, Dennis M.