REMEDIES FOR UNFAIR PRACTICES; REINSTATEMENT; BACKPAY BENEFITS – Back Pay; Interest
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1201.03000 – Back Pay; Interest
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.) The Board considered the issue in Tahoe-Truckee Sanitation Agency (2022) PERB Decision Number 2826-M, noting the possibility of considering whether PERB should adopt that method of calculating interest in a future case. (Tahoe-Truckee, pp. 3-4 [declining to award daily compounding interest because of the parties’ request to withdraw.].)