REMEDIES FOR UNFAIR PRACTICES; MISCELLANEOUS REMEDIAL PROVISIONS – Attorneys Fees and Costs

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Union awarded reimbursement of legal expenses it incurred in opposing employer’s frivolous reconsideration request was not entitled to an award of “fees on fees,” viz. reimbursement for time union spent on its attorney fee motion, where union had not yet had to perform work beyond drafting an initial set of declarations and supporting brief. (Sacramento City Unified School District (2020) PERB Decision No. 2749, pp. 19-20.) Additional sanctions may become appropriate if union is required to expend additional attorney time and resources to recover its attorneys’ fees awarded pursuant to Board order to prevent dissipation of value of award. (Id. at p. 19, citing Graham v. DaimlerChrysler Corp. (2004) 34 Cal.4th 553, 580.)