Federal Circuit and Family Court of Australia
(DIVISION 2)
Fair Work Ombudsman v S & L Lenz Pty Ltd [2022] FedCFamC2G 763
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- Case
- [2022] FedCFamC2G 763
- Decision Date
CaseChat Overview and Summary
The primary legal issue before the Court was the determination of an appropriate penalty for S & L Lenz's contravention of section 716(5) of the FW Act. The Court had to consider various factors, including the need for deterrence, the absence of contrition, and the company's status as a first-time contravener. The Court also needed to determine the maximum penalty applicable under section 539 of the FW Act and apply the principles of proportionality and totality to arrive at a penalty that was both appropriate and proportionate to the conduct.
In its decision, the Court noted that while deterrence was a key consideration, the complete lack of contrition and limited cooperation from S & L Lenz warranted a penalty lower than the maximum. The Court took into account S & L Lenz's agreement to enter into a Statement of Agreed Facts and their status as first-time contraveners. Ultimately, the Court determined that an appropriate deterrent penalty was one set at 65% of the maximum penalty, amounting to $21,450. The Court concluded that the appropriate penalty, considering all circumstances, was $21,450. The Court ordered S & L Lenz to comply with the Compliance Notice, pay the relevant penalties, and make appropriate payments to the affected employee. Additionally, the Court granted the FWO liberty to apply for further orders if S & L Lenz failed to comply with the penalty order.
Orders
Orders of the court
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Background
Background to the litigation
Evidence
Evidence Before The Court
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Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
As indicated at [4] above S & L Lenz filed no written materials in these proceedings. At hearing Counsel for S & L Lenz submitted that:(a)this was not a case where S & L Lenz had wantonly done the wrong thing and needed to be punished at the higher end of the spectrum of potential consequences on the basis that they had deliberately and blatantly chosen to disregard the Compliance Notice; and(b)S & L Lenz had not accepted, in the Statement of Agreed Facts, that the things happened as the FW Inspector said that they had, but that the FW Inspector had a proper basis for forming the view that she did, and that it was still disputed to this day whether or not the employee concerned had an entitlement to payment in lieu of notice.CONSIDERATIONPrinciples relevant to determination of penalty The appropriate steps to be considered in fixing an appropriate penalty were summarised in Fair Work Ombudsman v NSH North Pty Ltd trading as New Shanghai Charlestown [2017] FCA 1301; (2017) 275 IR 148; (2017) 69 AILR 102-890 (“New Shanghai Charlestown”) (citing Commonwealth v Director, Fair Work Building Industry Inspectorate [2015] HCA 46; (2015) 258 CLR 482 (2015) 90 ALJR 113; (2015) 255 IR 87; (2015) 326 ALR 476; (2015) 67 AILR 102-494 (“Agreed Penalties Case”) at [64] per French CJ, Kiefel, Bell, Nettle and Gordon JJ, Kelly v Fitzpatrick [2007] FCA 1080; (2007) 166 IR 14 (“Kelly”) at [30] per Tracey J and Australian Ophthalmic Supplies Pty Ltd v McAlary-Smith [2008] FCAFC 8; (2008) 165 FCR 560; (2008) 165 FLR (560); (2008) 246 ALR 35: (2008) 60 AILR 100-809 (“Australian Ophthalmic Supplies”) at [23] per Gray J, [71] per Graham J and [102] per Buchanan J. This case involves a single contravention. It is therefore unnecessary to consider grouping of courses of conduct under s 557 of the FW Act. Of the five steps set out, only the first, fourth and five steps are relevant here, and consequently the appropriate steps are:(a)first, to identify each separate contravention involved. A contravention of each separate obligation imposed by the FW Act is a separate contravention of a civil remedy provision for purposes of s 539(2) of the FW Act;(b)second, to consider the appropriate penalty in respect of the contravention; and(c)third, to consider the overall penalty arrived at and apply the totality principle, to ensure that the penalty is appropriate and proportionate to the conduct viewed as a whole, making such adjustments as are necessary.Maximum Penalties Section 539 of the FW Act sets out the maximum penalties that may be imposed for contraventions of civil penalty provisions by reference to penalty units. Section 4AA of the Crimes Act 1912 (Cth) defined a “penalty unit’ as $222 at the time the Respondents failed to comply with the Compliance Notice. Penalty units are defined by s 12 of the FW Act to have the same meaning as in s 4AA of the Crimes Act 1912 (Cth). Section 546(2)(a) of the FW Act provides that the maximum penalty for an individual is the maximum number of penalty units referred to in the relevant item in column 4 of the table in section 539(2) of the FW Act. Item 33 relates to s 716(5) of the FW Act, providing in column 4 that the maximum penalty is 30 penalty units. Section 546(2)(b) of the FW Act provides that the maximum penalty for a body corporate is 5 times the maximum number of penalty units referred to in the relevant item in column 4 of the table in s 539(2) of the FW Act, which in this case is therefore 150 penalty units. Accordingly, the maximum penalty for S & L Lenz is $33,300.