UNFAIR PRACTICE ISSUES; PROTECTED ACTIVITIES – Demands for Change in Working Conditions

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* * * OVERRULED IN PART by Walnut Valley Unified School District (2016) PERB Decision No. 2495, where the Board held that a 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. * * *

Employee’s complaints concerning the reduction of his own teaching assignment did not constitute protected activity under EERA. There are no allegations that would establish that those complaints were a logical continuation of any group activity. Rather, the charge indicates that they were undertaken alone and for the employee’s sole benefit.