Mediation is a conflict resolution process in which an unbiased mediator tries to help the people settle their dispute out of court.   These are some of the important advantages of mediation over other dispute resolution processes.

  1. Mediation is confidential.    You can tell the mediator about all the important issues in your case, and he can’t tell the other side without your permission. And when your case settles, the terms will not be part of a permanent court record.
  2. Mediation is without prejudice. Nothing said or offered during the mediation can be brought up later in Court.
  3. You are in control.  The purpose of mediation is to reach a settlement, but you, along with your attorney, make all the decisions.  No judge will be imposing a settlement on you without your agreement.
  4. If you reach a settlement, you will have certainty about your case.  Your case will be essentially over,  and you  not have to face unpleasant testimony by the other side and their witnesses. You can begin to get on with business again without a court case hanging over your head.
  5. Solutions can be creative.  The parties can make decisions based on the specific circumstances of the dispute.  A Judge is limited to specific decisions based on case law, precedents, and “cut and dry” solutions.  Mediated settlements allow for as many creative solutions as can imagined.
  6. The cost for mediation is much less than the cost of going to trial.  The longer a case drags on, the more it costs  in attorney fees and court costs – not to mention the business costs of prolonged uncertainty.
 

September 9th, 2010

by Diana Morokhovets

On August 30, 2010, the Court of Appeal unanimously decided in Keam v. Caddey, 2010 ONCA 565 to reprimand a litigating party for failure to participate in statutorily mandated mediation.

…the Court of Appeal rightfully directed its comments to the statutory duty to mediate stating that “[t]here can be no legitimate reason to refuse to participate because to elect not to participate constitutes a breach of the insurer’s statutory obligation. Accordingly, the Court concluded that despite a lack of malevolent conduct “a significant remedial penalty was required in all the circumstances.” To that effect, the Court ordered an increase of $40, 000 in the costs award. This brought the appellants’ recovery to $150, 000, up from $110, 000 representing partial indemnity costs ordered by the trial judge. This sum represents a middle ground between a partial indemnity award of $110,000 and the appellants’ substantial indemnity bill of $196, 145. This award allows the appellants to recover a significant amount of their costs and also reflects the court’s disapproval of the defendant’s actions without running the risk of opening the floodgates to a great increase in substantial indemnity claims.

See Refusal to Mediate Attracts a Remedial Penalty in Keam v. Caddey

 

The art of mediation is constantly evolving, adapting to changes in society, and integrating ideas from negotiation theory, legal practice, as well as other disciplines. Transformative Education emerged from the environmental movement into the academic field of Adult Education where it has been accepted into the prevailing adult education models and further developed. The basic precept of transformational learning is that, in order to be truly useful, education should do more than impart knowledge and skills… It should also transform the way in which learners observe and interact with the world around them. Since mediation already involves assisting people to reach agreement on difficult issues, the transformative model has been adapted to the practice of mediation by forward-thinking mediators and mediation educators. For the most part, this should be seen as positive development – but not always.

One of the reasons that I was prompted to develop The Goal Focused Way is that I felt that the prevailing mediation and negotiation model; Interest-Based, Principled Negotiation, was inadequate when one or more parties simply refused to engage with the process. While the interest-based model has mechanisms to deal with this possibility, I felt that these methods presented problems when “walking away”, or one-sided principled bargaining, or subtle (and unsubtle) methods were employed to bring the other party around. Particularly when the stakes are very high, and the parties are very antagonistic and/or unprincipled, the principled negotiating model fails completely. I have in my library a book by William Ury, one of the founders of Principled Negotiation at Harvard University, titled “The Third Side: Why We Fight and How We Can Stop “. It is an interesting book. But people are still fighting and nations are still at war. Sometimes the pie just can’t be shared. Sometimes losing is not an option. Sometimes winning is the only acceptable option, regardless of the impact on other parties. This can result in tragic consequences and is often exceptionally unfortunate… but also unavoidable.

In some cases the transformational mediation model can make a bad situation worse. One might (and should) ask, “how is it possible that a progressive model, designed from its very outset to build bridges, make peace, and make the world a better place, could possibly make a difficult situation even worse than it already is”? I can think of two examples and there are probably others.

Example 1)
Nearly every experience that human beings have can be transformative in one way or another, but in general terms, transformative education and mediation is going to take longer than less transformative, more instrumental mediation modes. In some cases this is a good thing, in some cases it does not matter, but in cases where clients are paying substantial amounts of money for professional services, spending more time than is necessary to reach a settlement is not acceptable. Lawyers can charge upwards of $400 per hour, mediators can charge as much as $3000 per day, clients are taking time away from their work and businesses. Sometimes the best interests of clients are best served by simply reaching a quick, fair agreement, and moving on.

Example 2)
Transformative Mediation is usually presented as being much more effective at reaching sustainable agreements in which the parties feel strongly vested. The process seems inherently fair and balanced. Usually I thing both of these beliefs are well-founded. But just as the Principled Negotiation model can fail miserably when one or more of the parties refuse to play ball, the transformative model can also fail to achieve agreements that are balanced or fair. The easiest way for me to demonstrate this is through a hypothetical example:

After 25 years of employment as a mid-level manager at the same company “John” is terminated without cause, and provided with 12 weeks severance pay by his US based employer. The employer believes that this is very fair given that there is an economic downtown and the amount is the maximum payable in the employer’s home state. John believes that the amount is inadequate, retains a lawyer, and the dispute is eventually mediated by a mediator using a transformative model. John’s lawyer quickly brings the employer’s offer up to the statutory minimum, but after considerable time spent in mediation John insists that his counsel accept this amount and refuse to ask for a penny more. John has been “transformed”! He now “sees the light”! Until this mediation he had no idea what a burden he had become to his employer, or how generous his employer had been to him over the years despite his poor performance, or how hard the economic downturn had been on his employer. He feels awful. He is no longer interested in a settlement that would make things any more difficult on his employer. He is simply pleased that he now is walking away with the statutory minimum. He believes it is more than fair! Everyone has been transformed. Everyone is happy. …And Hypothetical John was just screwed.

Does this mean that Transformational Mediation is a “bad idea”? Certainly not. I believe that Transformative Education is the highest possible ideal and that all mediators and negotiators should strive for opportunities to engage clients in a transformational manner whenever it makes sense to do so. Just remember that it is not the only path to sustainability, nor is it always the best path.

May 262010
 

30 Sep ’09

Mediators and lawyers are generally familiar with, and comfortable dealing with, legal issues. But my favourite law won’t be found in any legislation. It is the “law of unintended consequences”.

This is the “law” that almost always causes people the most trouble. The best clue that you may be about to become caught up in this law is when you think that you have found the “eureka” solution to a problem that has vexed everybody else. Chances are that whatever it is you’re thinking, someone else has thought about – and then thought better of it!

The example that comes to mind for me now relates to the propensity for nations to erect trade barriers to protect domestic jobs and industries. The United States sees American jobs manufacturing jobs disappearing, partly because foreign countries are selling the same products and lower prices because they have lower costs. There is a temptation to “level the playing field (sounds innocent enough) by placing a tariff on the foreign products so that they cost about the same, or more, as the domestically produced product.

…But what are the consequences? Well, the intended consequences are clear enough. Local manufacturers can continue to produce products that sell domestically at competitive prices. A side benefit (intended or otherwise) might be to send a message that America is not to be “messed with”. It’s those unintended consequences that need to be considered. First, the country that was making the cheaper product might respond with a tariff of their own against American products. Jobs in one factory are saved, but other jobs are lost in another factory (or farm). Second, the American company no longer has to innovate or control costs to compete domestically, but this will quickly result in that company becoming uncompetitive in other markets. Some of the saved jobs are then lost anyway due to declining international sales. Third, the foreign company is forced to innovate and lower costs, so that within a short time they may once again be able to offer their product in the USA at price lower than the domestic product; even with the tariff. Fourth, the foreign producer’s innovations might result in the creation of a better product that Americans will pay more for. It becomes apparent that the unintended consequences of a “simple solution” are worse than the problem that the solution was supposed to solve.

And… there is a fifth unintentional consequence that I still haven’t even mentioned. It is the most dangerous consequence of all. Why? Because it is the one that cannot be predicted!

Unintended consequences can result from nearly any decision. The trick for decision makers, negotiators, and mediators, is to recognize that unintended consequences are possible, plausible, and probable. Good decision makers and great negotiators know this, and account for it in their work. For some quick tips to increase your NQ (Negotiation Quotient) check out the free tips that I offer on the Goal Focused Way website.

ADR Down Under

 Mediation  Comments Off
May 252010
 

14 Apr ’09

Yes, they do it “down under” too!

Australia has an active ADR community, and Bond University in Queensland has a Dispute Resolution Centre as part of its Faculty of Law.  The aims and objectives of the Centre are:

  • To promote a better understanding of the need for, dynamics of and advantages of consensus-oriented procedures of dispute resolution.
  • To develop modules in negotiation, mediation, arbitration and other forms of alternative dispute resolution in the Law School programs.
  • To provide training in dispute resolution methods for lawyers and other professionals involved in this field.
  • To encourage and facilitate research and publications in the different areas of dispute resolution.
  • To provide an umbrella organisation for individuals and bodies involved in this field.

Currently it is still possible to access articles from the old Bond University ADR Bulletin at http://epublications.bond.edu.au/adr/ and tp access newer articles from the new ADR Bulletin at http://www.bond.edu.au/study-areas/law/centres/drc/adr_bulletin.html There is also a newsletter service by subscription Click here to subscribe .

 

01 Jan ’09

Below is a brief excerpt from a really good article on Mediate.com about mediator impartiality. The author, Alan Sharland, does an excellent job of differentiating between impartiality and amorality.

Impartiality is one of the more commonly recognized aspects of the role of the Mediator.

This does not mean that the Mediator should somehow become inhuman and not have a feeling of bias towards one party or another, but that they practice in a way that minimizes any manifestation of this bias.

This is an important distinction to make. No-one can genuinely claim to be impartial, but they can continually review their own feelings and thoughts about someone or a situation in order to acknowledge this and then monitor, and adjust where necessary, their practice as a mediator in the light of this awareness.

Complete article: Impartiality

May 242010
 

10 Aug ’08

From an article in the New York Times of August 7. 2008 by Jonathan D. Glater:

Note to victims of accidents, medical malpractice, broken contracts and the like: When you sue, make a deal.

That is the clear lesson of a soon-to-be-released study of civil lawsuits that has found that most of the plaintiffs who decided to pass up a settlement offer and went to trial ended up getting less money than if they had taken that offer.

Helping people to negotiate fast, fair settlements is what professional mediators are trained to do. It makes sense financially, emotionally, and practically – and the evidence supporting its efficacy continues to accumulate.

Link to the full article

 

The Reflective Action Cycle combines Solution-Focused and Interest Based Narrative theories into a model for understanding the negotiating process. It is a negotiating tool that is useful for understanding and managing conflict.

The Reflective Action Cycle is partly based on the scientific method. The scientific method is commonly used in the physical and life sciences, where a hypothesis is formed based on observed phenomena, an experiment is designed and conducted to test the hypothesis, and finally conclusions are drawn.

  • Observations:  “I heard them say…” (Consequences)
  • Hypothesis: “I think they said that because…” (Reflective Narratives)
  • Planning: “I will respond by saying or doing…” (Projective Narratives)
  • Experiment: “I said… and they responded by…” (Action/Event)
The Reflective Action Cycle, 2005 Version

Reflective Action Cycle, 2005 Version

The Reflective Action Cycle is a systemic tool that can be used to manage negotiations, multi-party disputes, and both external and internal conflicts.

Note: The Reflective Action Cycle was revised in 2010. The revised version is below:

Reflective Action Cycle, 2010 Version

New Reflective Action Cycle

Apr 102010
 

Listening is perhaps the most underused and underestimated negotiating skill we can master. But how can one learn to listen? Nearly every book and article we read about negotiation or communication tells us that we need to listen more than we do. Many of these books and articles also provide some advice about how to look like you’re listening; things like maintaining eye contact, not interrupting, and acknowledging the speaker through body language (head nods) or brief verbal affirmations (like “yes” or “I see”). There are also more sophisticated techniques that are offered to make it seem like you are listening; things like rephrasing and reflecting what the speaker said back to the speaker (“so, what I am hearing you say is…”). What is missing from all of the above advice is information about what it is you should be listening for, or how to actually listen rather than how to just appear to be listening.

Here is one of the techniques that I use to make sure that when I am listening to somebody, I am actually paying attention to, and absorbing what they are trying to say to me. I try to take the time to ask myself these three questions about what is said:

1. What did the speaker say?
- Repeat to myself the actual words (as closely as I can) that the speaker said
2. What did the speaker mean?
- Try to understand what the speaker wanted to communicate
3. What did what the speaker say mean to me?
- Try to see how what the speaker said relates to my role in the conversation
- Think about possible responses and solutions
- It is critical that questions 1 and 2 be asked first! Most of us tend to jump immediately to step 3, which means that we are not responding to what the speaker actually said and meant, but only to what we guess was meant.

The questions that I use are adapted ideas from one of my grad school professors, Laurent Leduc.

Apr 102010
 

Mediation is a powerful tool for conflict resolution. The irony of this power is that the power of mediation is largely due to the fact that the mediator has no power. But by virtue of the fact that the mediator cannot impose a settlement, mediation permits the parties to a dispute a last chance to resolve their conflict before a judge or arbitrator imposes a settlement.

So, if the parties are resolving their differences on their own, and the mediator has no power to impose a settlement, what exactly is the mediator there for?

Mediation offers the parties to a dispute the opportunity to work out for themselves exactly what it is that they expect and hope to get out of a settlement in a neutral forum guided by a skilled professional neutral person, the mediator. The core advantages to employing a mediator to assist with dispute resolution are:

1. Mediation is confidential
- Whatever is said in the mediation sessions is not shared outside of, or after mediation
- Since the mediator is not empowered to enforce a decision he is not subject to being prejudiced by disclosures made during mediation
2. Mediation is conducted “without prejudice”
- Offers put forward during mediation are not binding if the mediation process does not result in a settlement, and the dispute moves forward to arbitration or the courts
- Disclosures made in mediation cannot be used directly in later proceedings
- If mediation fails, the parties are never any worse off, the formal legal or grievance process can continue as if mediation had not occurred
3. The mediator does not need to be convinced of anything by either party because the mediator does not decide the outcome
- The mediator guides the process but does not direct the outcome
- The mediator is neutral from beginning to end, never “chooses sides”
4. Mediation is flexible
- Solutions can be put forward that are outside of the scope of jurisprudence or collective agreements
- Creative solutions that allow for unorthodox win/win collaborations or unusual compromises can be obtained
- Settlements achieved through mediation are likely to be satisfactory to all parties, not just one or the other
5. Mediation can save time, money, and “face”
- The alternatives to a negotiated agreement are seldom better for any of the parties
- The alternative to a negotiated agreement is almost always bad for one of the parties, and there is no guarantee that you will not come out of an imposed decision holding the short straw!

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