REMEDIES FOR UNFAIR PRACTICES; REINSTATEMENT; BACKPAY BENEFITS – Back Pay; Interest

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In 2010 the NLRB began including daily compound interest in all monetary relief. (Bellflower Unified School District (2022) PERB Decision No. 2544a, p. 41, fn. 23 [judicial appeal pending] (Bellflower), citing Kentucky River Medical Center 356 NLRB 6, 6.) The Board declined to reach that issue in Bellflower due to an agreement between the parties to apply simple annual interest. (Ibid.) Although the Board similarly did not reach the issue in this matter in light of the parties’ request to withdraw, it noted the possibility of considering whether PERB should adopt that method of calculating interest in a future case.