HRTO Clarifies Law on Family Status, Addresses Elder Care Responsibility

August 30, 2012
In
1,860 comments

A decision of the Ontario Human Rights Tribunal (the “HRTO”) has clarified the law on discrimination on the basis of family status and added to the sparse jurisprudence addressing elder-care responsibilities in the human rights context.

The decision, Devaney v. ZRV Holdings Ltd., 2012 HRTO 1590 (CanLII), involved an Applicant who worked as an architect for the Respondents for 27 years. He was terminated for cause as a result of his frequent absences from work, which he attributed to responsibilities in caring for his ailing mother. Aside from the absences, there were no apparent issues with the Applicant’s performance.

The Applicant proceeded to file an application under the Ontario Human Rights Code (the “Code”) alleging discrimination on the basis of family status.

i) Establishing a Prima Facie Case of Discrimination:

In order to determine whether the Code had been breached, the HRTO was first required to determine whether the Applicant had established a prima facie case of discrimination. Following a review of conflicting jurisprudence, the HRTO held that the test for prima facie discrimination required a finding that the employer’s requirements (in this case, attendance requirements) had an adverse impact on the applicant’s care-giving needs (as opposed to choices or preferences relating to care-giving).

Based on the foregoing, the HRTO concluded that the Applicant had established a prima facie case of discrimination because the Respondents’ requirement that Applicant be in strict attendance at the office each day, regardless of his care-giving responsibilities, had an adverse impact on him.

In reaching this conclusion, the HRTO rejected an earlier line of cases which applied a higher threshold to cases of discrimination based on family status. Those cases suggested that a prima facie case of discrimination would be made out when a change in a term or condition of employment resulted in a serious interference with a substantial parental or other family duty or obligation of the employee.

ii) Duty to Accommodate Procedurally Requires Meaningful Dialogue and Assessing Code-Related Needs:

Having found a prima facie case of discrimination, the onus shifted on the Respondents to establish that their attendance requirements were “reasonable and bona fide” within the meaning of s. 11 of the Code, including whether they had met their duty to accommodate procedurally and substantively.

Following a review of the evidence, the HRTO concluded because the Respondents never engaged in a meaningful dialogue or made meaningful inquiries regarding the accommodation of the Applicant’s eldercare responsibilities, they had failed to meet the procedural aspect of the duty to accommodate. As the HRTO stated:

When a respondent is notified that an individual has Code-related needs, the respondent has a duty to make meaningful inquiries about the needs to determine whether or not a duty to accommodate exists . . . While the complainant may be in a position to make suggestions, the employer is in the best position to determine how the complainant can be accommodated without undue interference in the operation of the employer’s business. . . . The duty to accommodate requires an individualized assessment of Code-related needs, including the possibility that there may be different ways to perform the job. . . .

iii) Outcome:

In addition to the above, the HRTO found that the Respondents breached their substantive duty to accommodate because they failed to establish that accommodating the Applicant’s needs (i.e. allowing the absences) would have caused them undue hardship. Having breached both the procedural and substantive aspects of their duty to accommodate, the HRTO found that the Respondents had subjected the Applicant to discrimination on the basis of family status.

The Applicant was awarded $15,000.00 in general damages. The Respondent was also ordered to develop and implement human rights policies and to provide training to all partners and supervisory staff on human rights and the duty to accommodate.

This decision is noteworthy in several respects. First, its recognition of elder care responsibility as falling under the ambit of “family status” will have important consequences for the increasing number of people dealing with aging family members (a welcome development from an employee perspective). Second, the decision places significant responsibility on employers to engage, work with and assess the needs of employees with family obligations.

Given this onus and the serious consequences of a breach, employers would be well advised to consult with counsel when faced with family status/accommodation scenarios.

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