EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; OTHER PER SE VIOLATIONS – Outright Refusal to Bargain

Single Topic for Decision 1030E

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*** CLARIFIED by County of San Diego (2026) PERB Decision No. 3006-M and County of Riverside (2013) PERB Decision No. 2307-M: A union cannot challenge an operative collective bargaining agreement setting the number of employees released for bargaining or the quantity of allowable release time, as those topics are bargainable. In contrast, the right to receive release time without loss of compensation or other benefits is a non-waivable minimum statutory guarantee.***

The District's failure to discuss in any meaningful way its position to keep the status quo regarding released time constitutes a refusal to bargain in good faith; p. 12.