UNFAIR PRACTICE ISSUES; PROTECTED ACTIVITIES – Individual/Concerted/Activities/Self-Representation

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300.04000 – Individual/Concerted/Activities/Self-Representation

* * * OVERRULED IN PART by Walnut Valley Unified School District (2016) PERB Decision No. 2495, where the Board held charging party need not allege facts demonstrating conduct or speech is a logical continuation of group activity, if acts can be reasonably characterized as representing oneself in employment relations. * * *

Bailey’s complaints on her own behalf to a supervisor about a subordinate do not rise to the level of protected activity. This is distinguished from cases in which the Board found that an employee’s complaint concerned an issue impacting employees generally and thus, was protected.