Decision 0051E – Pajaro Valley Unified School District
SF-CE-38
Decision Date: May 22, 1978
Decision Type: PERB Decision
Perc Vol: 2
Perc Index: 2107
Decision Headnotes
608.00000 – EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; DEFENSES
608.05000 – Past Practice; Maintenance of Status Quo
608.05000 – Past Practice; Maintenance of Status Quo
Employer-initiated payroll deductions for dental and vision care insurance not unlawful where employer had past practice of passing on increases in costs of benefits pending negotiations.
602.00000 – EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; UNILATERAL CHANGE (FOR NEGOT OF SPECIFIC SUBJECTS, SEE SEC 1000, SCOPE OF REPRESENTATION)
602.06000 – Change in Past Practice
602.06000 – Change in Past Practice
Employer-initiated payroll deductions for dental and vision care insurance not unlawful where employer had past practice of passing on increases in costs of benefits pending negotiations.
602.00000 – EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; UNILATERAL CHANGE (FOR NEGOT OF SPECIFIC SUBJECTS, SEE SEC 1000, SCOPE OF REPRESENTATION)
602.01000 – In General
602.01000 – In General
Unilateral change is per se violation of duty to bargain.
101.00000 – PERB: OPERATION, JURISDICTION, AUTHORITY; APPLICABILITY OF AND CONFLICTS WITH OTHER STATUTES
101.02000 – Conflicts Between PERB-Administered Laws and Other California Statutes; Education Code/Supersession; MMBA Supersession
101.02000 – Conflicts Between PERB-Administered Laws and Other California Statutes; Education Code/Supersession; MMBA Supersession
ALJ properly declined to address legality of dues deductions under Ed. Code or case law where not determinative of whether unfair practice committed.