REMEDIES FOR UNFAIR PRACTICES; REMEDIES AGAINST UNION – In General

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* * * OVERRULED IN PART ON OTHER GROUNDS by California State Employees Association (Hard et al.) (1999) PERB Decision No. 1368-S, p. 28. * * *

Posting is sufficient remedy; p. 33, proposed dec; Attorney's fees and costs of litigation, including lost time and wages, were not awarded because PERB has held that such remedies are not appropriate unless there is a showing that the respondent's unlawful conduct has been repetitive and that its defenses are without arguable merit. (Modesto City Schools and High School District (1985) PERB Decision No. 518.); pp. 34-35, proposed dec.