EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; OTHER PER SE VIOLATIONS – Other
Single Topic for Decision 1030E
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605.00000 – EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; OTHER PER SE VIOLATIONS
605.05000 – Other
605.05000 – Other
*** 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.***
Use of comparative data unnecessary as Board finds a per se violation of the duty to bargain in good faith; p. 12.