EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; DEFENSES – Management-Rights Clause; Management Prerogative

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

Court’s requirement that newly hired court reporters sign an agreement to provide Realtime reporting services, which was added to the job description, was not an unlawful unilateral change, but rather an assignment of work which falls within the Court’s management prerogative under City & County of San Francisco (2004) PERB Decision No. 1608-M (San Francisco). PERB’s holding in San Francisco under the Meyers-Milias-Brown Act applies equally to the Trial Court Act given that they have the same “scope of representation” provisions.