UNFAIR PRACTICE ISSUES; STRIKES, SLOWDOWNS AND WORK STOPPAGES – In General

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Every protected strike does not necessarily have as its motive either pressuring an employer to make concessions in collective bargaining or protesting an alleged unfair practice. (See, e.g., City and County of San Francisco (2017) PERB Decision No. 2536-M, pp. 54-55 (conc. opn. of Banks, M.) [grievance strikes may be protected]; see also National Labor Relations Bd. v. Washington Aluminum Co. (1962) 370 U.S. 9, 14-15 [strike over poor conditions]; Union Electric Co. (1975) 219 NLRB 1081, 1082 [strikes protesting suspensions].) (pp. 23-24, fn. 12.)