EMPLOYER INTERFERENCE, RESTRAINT, COERCION; THREATS OR PROMISES – Express or Implied Threats

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* * * OVERRULED IN PART ON OTHER GROUNDS by Trustees of the California State University (Northridge) (2019) PERB Decision No. 2687-H. * * *

Both statement to union steward conducting union investigation into alleged misconduct by a supervisor for a potential grievance that she could find herself under investigation for impeding employer’s investigation and issuance of cease and desist order constituted at least “slight harm” to employee organizational rights. In balancing competing interests, interference with employee organizational rights outweighs business justification proffered by employer for its conduct.