EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; REFUSAL TO BARGAIN IN GOOD FAITH (FOR SPECIFIC SUBJECTS, SEE SCOPE OF REPRESENTATION, SEC 1000) – In General, Per Se and Totality of Conduct; Prima Facie Case
Single Topic for Decision 2109H
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601.01000 – In General, Per Se and Totality of Conduct; Prima Facie Case
* * * OVERRULED ON OTHER GROUNDS by City of Culver City (2020) PERB Decision No. 2731-M. * * *
Pleading or raising a bare allegation without sufficient supporting facts is insufficient for purposes of alleging a prima facie case. Where the charge alleged the employer violated past practice regarding sick leave verification and approval for vacation leave, a bare allegation that the relevant practices were “well established” was insufficient. The charge must allege facts to demonstrate the past practice.