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

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A party’s steadfast refusal to meet and negotiate is a per se failure to bargain in good faith. (City and County of San Francisco (2023) PERB Decision No. 2858-M, p. 12; City of Glendale (2020) PERB Decision No. 2694-M, pp. 64-65 [finding that city’s attempt to “keep stalling” negotiations was an outright refusal to bargain]; Children of Promise Preparatory Academy (2018) PERB Decision No. 2558, p. 26 [initial refusal to bargain was a per se violation of the duty to bargain].) Board found that Alliance engaged in per se bad faith bargaining when it disavowed bargaining dates to which it agreed in interim MOUs and failed to respond to UTLA’s multiple requests for bargaining dates. (pp. 27-28)