Quality control technician claims PTSD after harassment affected decision-making ability
Ontario's Superior Court of Justice recently dealt with a case involving a worker who signed a release after being terminated, but later sought to challenge its validity.
The worker argued that he lacked capacity to sign the release, was under duress, and that the agreement was unconscionable.
The case raised important questions about the enforceability of releases in employment terminations, especially when a worker claims to be experiencing mental health issues.
Background of the case
The worker was employed by a large company for about two years as a quality control technician, earning approximately $50,000 per year. During his employment, he alleged that he experienced workplace harassment from a colleague.
The harassment culminated in an incident on June 12, 2015, where the colleague allegedly grabbed the worker by the hips and simulated intercourse in front of other employees. The worker reported this to management on June 18, 2015, but was told to ignore and avoid the harasser.
Following this incident, the worker claimed he began suffering from panic attacks and other symptoms. In May 2016, he was hospitalised for heart-related issues and placed on short-term disability. He returned to work on July 18, 2016.
On August 3, 2016, the worker was unexpectedly terminated due to a company reorganisation. The employer provided him with a termination package that included two months' salary and a full release covering all possible claims, including those related to the alleged harassment. The worker signed this release on August 16, 2016, without seeking legal advice.
Worker challenges validity of the release
Later, the worker started legal proceedings to challenge the validity of the release. He argued that:
- He lacked the capacity to sign it due to his mental state
- He was under duress when signing
- The release was unconscionable
The worker claimed he suffered from post-traumatic stress disorder (PTSD) as a result of the harassment, which affected his decision-making ability when signing the release.
Worker’s PTSD claims
The court examined the evidence presented and the legal principles surrounding capacity, duress, and unconscionability in contract law. The judge noted the lack of admissible medical evidence to support the worker's claims of PTSD:
"I have no evidence from a properly qualified medical expert that would enable me to find that [the worker] suffered from PTSD, or any other medical problem, other than [the worker's] own self-diagnosis."
Regarding duress, the court also found no evidence of improper pressure from the employer:
"The evidence is that [the employer] made representations that one would typically expect at a termination meeting, and nothing more. In other words, [the employer] imposed no 'illegitimate pressure' upon [the worker]."
Validity of the release
The court dismissed the worker's claims and upheld the validity of the release. The judge said:
"[The worker's] evidence, therefore, does not reach the levels described in Sanzone v. Schechter whereby [the worker] has shown that there is a genuine issue for trial in the face of a presumptively enforceable settlement as described in Deschenes v. Sylvestre Estate."
The court also noted:
"While [the worker] was on short-term disability, was hospitalised for heart issues, and suffered [the harasser's] conduct more than a year prior, nothing in the evidence filed suggests that [worker] lacked capacity when he signed the release."
This decision underscores the importance of providing strong, admissible evidence when challenging a signed release in an employment context. It also highlights that experiencing difficult circumstances doesn't automatically invalidate a signed release.
