Headnote for 0201E, 608.07000 - Waiver by Union; Contract Waivers; Bargaining History Estoppel; Disclaimer; Supersession - California Public Employment Relations Board

EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; DEFENSES – Waiver by Union; Contract Waivers; Bargaining History Estoppel; Disclaimer; Supersession

Single Topic for Decision 0201E

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608.00000 – EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; DEFENSES
608.07000 – Waiver by Union; Contract Waivers; Bargaining History Estoppel; Disclaimer; Supersession

Waiver not shown simply because Union did not bargain before July 1 - date District believed it had to act to implement proposed change. Mutual agreement to postpone negotiations until after the July 1 date does not constitute waiver. District did not show "demonstrative behavior [by Union] waiving a reasonable opportunity to bargain over a decision not already firmly made by the employer;" p. 8.