If It Looks Like It and It Smells Like It… Lay-off or Dismissal, under Ontario Law --It All Amounts to the Same Thing

Somehow, it has a better ring to it. For mostBoard”) provides for a 13 week lay-off period
Employees being “Laid-off” is a great dealduring which a moratorium is imposed upon the actions
easier to swallow after long and faithful years ofof Employment Standards Officers from seeking
service than a pink slip with the wordscompensation under the Act. However, this only
“Terminated”, “Dismissed” orapplies to the minimum statutory termination and
“Fired”. Certainly, the term “Laid-off” hasseverance rights set out in the legislation. The
connotations that the decision was reached due toimportant thing to remember is that the Employee’s
circumstances beyond the control of the EmployerCommon Law entitlements to claim for wrongful
and with no fault of the Employee. The lack of cashdismissal based on age, length of service and status
flow and shortage of work are the causes of doom,override the minimums under the Employment
not the Employee’s performance, or so the story isStandards Act, 2000. For example, a mid-management
told. However, this cloud has so silver lining. In fact,Employee, age 50 with 12 years seniority, is entitled to
many Employers prefer to characterize the termination8 weeks under the Employment Standards Act, 2000,
of employment as a “lay-off” out of genuinebut would be entitled to 12 months at common law.
sincerity and an attempt to lessen the emotional painIn fact, an Employee who is “Laid-off’ without
of losing one’s job.recall may have greater rights than the circumstances
However, there is often a darker hidden agenda to thisof an ordinary dismissal. In recent decision of Cagigal v.
characterization, designed to guard the Employer’sMill Dining Lounge Ltd. a Manager of a restaurant with
interests at the expense of the Employee’s rights:three (3) years of service sued for wrongful dismissal.
On the one hand, there is a subtle message. If theHe had been laid off in March but only told by the
Employee toughs it out, accepts the situation, keepsEmployer in August that there was no longer a job for
the peace and above all, does not seek legal help, thehim. The Ontario Court of Justice found that the
situation may be temporary and there will be a chanceEmployer did not act reasonably in failing to inform the
of recall, at which time the status quo will beEmployee that he would be dismissed during the
re-instated. It is only natural to hope that the upheavalperiod of lay-off. Accordingly, the five (5) months of
is only temporary. Especially after long service, no onelay-off were added to the three (3) months of normal
wants to set out on the unknown of a newseverance for a total of eight (8). The court, in effect,
relationship.said that it is unfair to lead someone along when there
When the weeks melt into months, and no recallis little or no possibility of recall. This notion was
arrives, the Employee slowly realizes that he or sheexpanded upon by the Supreme Court of Canada in
has been duped into a false expectation. In thethe famous Wallace decision. Taking its lead , in
meantime, a precious opportunity has been lost inOntario and other Canadian jurisdictions the Courts
seeking alternate permanent employment and mosthave gone even further. In the leading case of
importantly, severance entitlements.Martellacci v CFX Inc. * for example, the Court
With regard to the latter, the Employer’s messagedefinitively upheld the principal that the 13 week rule is
is much less subtle. Call the “Labour Board”no bar to wrongful dismissal and decisively penalized
Then an Employee is told after enquiring aboutan Employer for refusing to provide any compensation
entitlements “We can lay you off for 13 weeks andwhen it refused to return the laid off Employee (a
we don’t have to pay you a dime”. In the interim,Purchasing manager) to her pre “lay off”
as the bills mount, the Employment Insurance wanesposition.
and nothing positive is done to obtain his/her rights, theIn summary, Employers must inform their laid-off
Employee waits like a hopeful jilted lover. Of courseEmployees of their true intentions so that the
the call never comes. If the Employer had been upEmployees can get on with life and find suitable
front enough to tell it like it is, being indefinitely laid off isalternate employment, if not, the consequences will be
a euphemism for being fired without cause, a bitter pillan enhanced severance package for “ bad faith
with a sugar coating.“ dismissal.
There is a light at the end of the tunnel. In Ontario as inA rose by any other name smells as sweet, except in
all Provinces in Canada, every Employee who isEmployment Law. If the Employer’s intentions are
terminated without just cause is entitled to reasonableto lessen the psychological blow of a dismissal, the
notice of termination, or severance In lieu of notice. Theway not to do it is by trying to mislead the Employee
amount of notice is based primarily on 3 main factorsinto believing that a lay-off has some special status
established over 30 years of judicial decisions knownand thereby avoiding its obligations. If the Employer
as Common Law: age, position and length of service.must reduce the workforce for legitimate financial
There is no special status for “Lay-off” underreasons, most Employees will understand. What they
Common Law; a lay-off is a breach of thecannot understand and the Courts will not tolerate, is
Employee’s unwritten contract. Any non-unionizedsome less than straight-forward attempt to
Employee can claim compensation for wrongfulcharacterize a lay-off as anything else than what it is,
dismissal from the day he receives an indefinite lay-offa termination of employment for which the Employee
notice and the Employer refuses or is unable tois entitled to notice or compensation on termination
provide the date of recall. What about the 13 weekwhen they need it most.
rule? It is true that the Employment Standards Act,* the writer was Counsel for the Employee in this
2000 (The Ministry of Labour “The Labourmatter.