Decision 2791S – State of California (Department of Fish & Wildlife)

SA-CE-2191-S

Decision Date: September 23, 2021

Decision Type: PERB Decision (Non-Precedential)

Description: The amended unfair practice charge alleged that the State of California (Department of Fish & Wildlife) violated the Ralph C. Dills Act by refusing to promote its in-house attorneys to the Attorney V classification and instead outsourcing legal work to a private law firm. The Office of the General Counsel found the charge failed to state a prima facie case of bad faith bargaining under either the “per se” or “totality of conduct” tests, and dismissed the charge.

Disposition: The Board affirmed the dismissal of the unfair practice charge.

Decision Headnotes

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