Decision 2374M – City and County of San Francisco (Department of Human Resources)

SF-CO-306-M

Decision Date: May 16, 2014

Decision Type: PERB Decision (Non-Precedential)

Description: Charging party alleged that the union violated the MMBA and PERB Regulations when it authorized a labor stoppage prior to reaching impasse and in violation of the parties’ memorandum of understanding.

Disposition: Dismissal affirmed.  The Board concluded that the charging party failed to allege a prima facie violation of the duty to bargain in good faith.  While the Board has found a possible violation of the bargaining duty under the totality of the circumstances test when a strike authorization vote is coupled with evidence of significant strike preparation activities, that evidence is not alleged here.

Perc Vol: 38
Perc Index: 167

Decision Headnotes