Headnote for 2485E, 601.01000 - In General, Per Se and Totality of Conduct; Prima Facie Case - California Public Employment Relations Board

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 2485E

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601.00000 – EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; REFUSAL TO BARGAIN IN GOOD FAITH (FOR SPECIFIC SUBJECTS, SEE SCOPE OF REPRESENTATION, SEC 1000)
601.01000 – In General, Per Se and Totality of Conduct; Prima Facie Case

Although charging party alleged several recognized “indicia” of bad faith, the charge failed to state a prima facie case that the public school employer had engaged in surface bargaining where the charge allegations demonstrated that the charging party’s own conduct of refusing to meet for negotiations unless employee observers were permitted to attend so frustrated negotiations that it precluded consideration of whether the public school employer had bargained in good faith.