Decision 1093H – California State University (California State Employees Association) * * * VACATED by California State Employees' Association v. Public Employment Relations Board (1996) 51 Cal.App.4th 923
Decision Date: April 5, 1995
Decision Type: PERB Decision
* * * VACATED by California State Employees’ Association v. Public Employment Relations Board (1996) 51 Cal.App.4th 923 * * *
Description: CSU unilaterally suspended payment of merit salary adjustments without negotiating.
Disposition: Dismissed. No violation found.
Perc Vol: 19
Perc Index: 26079
602.01000 – In General
Whether a unilateral change has occurred is measured by comparing the action taken to the status quo established by a contract or the past practice; p. 11. Under federal law, which is generally followed by PERB in duty to bargain cases, it is clear that the duty to bargain from a status quo after contract expiration emanates from a statute and the duty to bargain obligation imposed by HEERA is more restricted than that imposed by federal statutues; p. 14.