Decision 0991E – Long Beach Community College District

LA-CE-3065

Decision Date: April 26, 1993

Decision Type: PERB Decision

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Perc Vol: 17
Perc Index: 24083

Decision Headnotes

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

Pre-impasse unilateral change in established, negotiable practice constitutes a per se violation of the duty to negotiate in good faith; p. 8. Established practice may be reflected in (1) collective bargaining agreement, including examination of bargaining history where provisions are vague or ambiguous; or (2) past practices; p. 9.

602.00000 – EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; UNILATERAL CHANGE (FOR NEGOT OF SPECIFIC SUBJECTS, SEE SEC 1000, SCOPE OF REPRESENTATION)
602.03000 – Contract Repudiation or Breach

No violation where District's conduct violated the contract, but there was no evidence that this contract violation had a generalized effect or continuing impact on the terms and conditions of employment of bargaining unit members; p. 12. Where there is insufficient evidence to show an established past practice, Board must look to the language of the collective bargaining agreement; p. 9.

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

Where there is insufficient evidence to show an established past practice, Board must look to the language of the collective bargaining agreement; p. 9.