An Employer’s Rights in Tough Times: New Decision on Temporary Lay-offs

The Ontario Superior Court recently released a case that could have a significant impact on employers and employees alike when it comes to temporary layoffs.  Trites v. Renin, 2013 ONSC 2715, was released in early May, 2013, and articulates a somewhat new take on an employer’s rights to impose a temporary layoff without an express contractual term allowing the employer to do so.  

Sandra Trites had worked for Renin Corp. for approximately 6 years prior to being temporarily laid off by the company in November of 2011.  Renin began to experience significant financial strain in 2008, and began a “temporary lay-off program” that same year.  Lay-offs were imposed on a rotating basis; a group of employees were laid off for a time, with many of them recalled within 35 days.  This timeframe ensured accordance with the Employment Standards Act (the “ESA”), which states that temporary lay-offs can last not more than 13 weeks of lay-off in any consecutive period of 20 weeks.  The company held that this was the only way that they could keep the company viable.  The employees that were not brought back were paid out their ESA entitlements or whatever was dictated by their employment contracts.

Ms. Trites’ situation was unique; the company sent her a letter in January of 2012 that requested she return to work in July, 2012, thereby extending her lay-off period to seven months.  This was not a financially feasible situation for her, so she sought out other employment and accepted work on a contract basis that began in July of 2012.  The new position paid less and was not permanent, but Ms. Trites felt that she had little choice, as she treated her lay-off by Renin was a constructive dismissal.  She brought forward this claim prior to receiving her recall notice from Renin. 

Justice Moore recognized in this case that the company was not acting in bad faith, and had legitimate financial reasons for making the decisions it did with respect to Ms. Trites.  Moore was also aware that Renin’s decision to operate how they did resulted in a wildly different version of the terms of Ms. Trites’ employment.   However, the necessary determination remained whether or not the lay-off had been undertaken in compliance with the ESA.

Justice Moore held that “there is no more room remaining at law for a common law claim for a finding of constructive dismissal in circumstances where a temporary layoff has been rolled out in accordance with the terms of the ESA”.  This significantly limits earlier arguments, such as that made successfully in Martellacci v. CFC/INX Ltd., that absent an explicit contractual agreement that the employer is entitled to layoff the employee, the employer was precluded from placing an employee’s employment status on hold without pay and benefits without it constituting a constructive dismissal.

Although the layoff Renin imposed on Ms. Trites was within the 35 week window, she did not receive any payments or supplementary unemployment benefits from the company, and nor was she offered ongoing entitlement to benefits.  This placed her outside of the definition of temporary layoff as proscribed by the ESA, and led Justice Moore to conclude that Ms. Trites had been constructively dismissed.  Taking into account all of the relevant factors, Ms. Trites was awarded approximately $50,000 in damages. 

This decision is important as it signals a potential shift in the common law regarding an employer’s right to institute temporary lay-offs.  The argument that a temporary lay-off is by its very nature vulnerable to an argument of constructive dismissal is tempered by Justice Moore’s findings, and this should be taken into account with respect to these kinds of cases.

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