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

LA-CE-328-H

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 * * *

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Perc Vol: 19
Perc Index: 26079

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

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.