EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; OTHER PER SE VIOLATIONS – Outright Refusal to Bargain

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A party cannot satisfy its duty to bargain in good faith merely by meeting and discussing a topic as it explicitly denies any duty to bargain. (City of San Ramon (2018), PERB Decision No. 2571-M, p. 15 [agreeing to meet for the sake of good labor relations does not satisfy bargaining obligation where employer denies obligation to bargain]; Rio Hondo Community College District (2013) PERB Decision No. 2313, adopting proposed decision at p. 5 [same].) (p.36.)