UNION UNFAIR PRACTICES;RESTRAINT, COERCION, INTERFERENCE OR DISCRIMINATION – Other

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In determining that charging parties did not state a prima facie case of interference, Board noted union officials lacking control over the employment relationship do not have the same capacity as an employer’s agent to discourage protected activity. (Oxnard Federation of Teachers (Collins) (2012) PERB Decision No. 2266, adopting warning letter at p. 6; California Faculty Association (Hale) (1988) PERB Decision No. 693-H, adopting warning letter at p. 5; see also City of Oakland (2014) PERB Decision No. 2387-M, p. 25, fn. 5; (Hartnell Community College District (2015) PERB Decision No. 2452, p. 25.)