EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; UNILATERAL CHANGE (FOR NEGOT OF SPECIFIC SUBJECTS, SEE SEC 1000, SCOPE OF REPRESENTATION) – Impact and Extent

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Employer’s changes to union release time policies and practices had more than a de minimis impact on employees’ and their representatives’ representational rights. (p. 12.) Because of its relationship to employer-employee relations and its direct impact on employees’ wages and hours of employment, the employer’s changes, unlike in Claremont Police Officers Assn. v. City of Claremont (2009) 39 Cal.4th 623, resulted in denials of paid release time employees would have otherwise received under the employer’s past practices. (pp. 11-12.)