EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES – In General

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No evidence that the County intended to subvert the process with obstructionist conduct. The Board held that some bad judgment and miscommunication did not rise to the level of bad faith or surface bargaining based on totality of conduct. Just because negotiations are not productive at certain points of time does not mean they are in bad faith.