Metropolitan Life Insurance Co. v. International Union of Operating Engineers

Metropolitan Life Insurance Co. v. International Union of Operating Engineers

The Board’s certificate was quashed because the Board failed to address the statutory question whether more than 55% of employees were members for s.7(3) purposes and instead applied its own membership criteria, thereby stepping outside its jurisdiction; that jurisdictional error was not protected by the Act’s privative clauses and warranted judicial quashing of the certificate.

Citation
[1970] SCR 425
Parties
Plaintiff/appellant: Metropolitan Life Insurance Company; Defendant/respondent: International Union of Operating Engineers, Local 796
Court
Supreme Court of Canada
Jurisdiction
Canada
Judgment Date
27 January 1970
Procedural Posture
Labour Relations Certification; Judicial Review of Administrative Decision / Appeal to the Supreme Court of Canada From the Court of Appeal for Ontario
Outcome
Appeal allowed
Legal Topics
Certification Under Labour Relations Act S.7, Membership Determination, Jurisdictional Error, Privative Clause and Limits of Review
Source Language
English
Labour Law Administrative Law Judicial Review Certification Under Labour Relations Act S.7 Membership Determination Jurisdictional Error Privative Clause and Limits of Review

Case Brief

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Parties

Metropolitan Life Insurance Company

Plaintiff/appellant

International Union of Operating Engineers, Local 796

Defendant/respondent

Procedural Posture

Labour Relations Certification; Judicial Review of Administrative Decision / Appeal to the Supreme Court of Canada From the Court of Appeal for Ontario

Legal Issues

  1. 1 Whether the Labour Relations Board satisfied the statutory condition precedent in s.7(3) that more than 55% of employees were members of the union when no vote was taken
  2. 2 Whether the Board improperly declined to apply the union’s constitution in determining membership and instead applied its own membership criteria
  3. 3 Whether the Board by asking the wrong question stepped outside its jurisdiction such that privative clauses (ss.79 and 80) do not bar judicial review

Ratio Decidendi

The Board’s certificate was quashed because the Board failed to address the statutory question whether more than 55% of employees were members for s.7(3) purposes and instead applied its own membership criteria, thereby stepping outside its jurisdiction; that jurisdictional error was not protected by the Act’s privative clauses and warranted judicial quashing of the certificate.

Court Disposition

Appeal allowed

Orders

  • Orders of the Court of Appeal for Ontario and of Fraser J. set aside
  • Order issued quashing the Ontario Labour Relations Board certificate dated August 29, 1967