EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; UNILATERAL CHANGE (FOR NEGOT OF SPECIFIC SUBJECTS, SEE SEC 1000, SCOPE OF REPRESENTATION) – Impact and Extent

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* * * OVERRULED IN PART ON OTHER GROUNDS by County of Sacramento (2013) PERB Decision No. 2315-M. * * *

The addition, without notice or opportunity to bargain, of the Realtime reporting requirements in the job description for court reporters which mandated use of additional equipment and software, technical knowledge, and customizing the Realtime dictionary, where prior job description required only use of a stenograph machine, constituted a unilateral change within the scope of representation. These Realtime reporting requirements had a generalized effect given they impacted the terms and conditions of all court reporters hired after approval of the job description. However, because we have determined that the change was non-negotiable under the Trial Court Act’s scope of representation provisions, the Court’s implementation of the change is not an unlawful unilateral change.