Decision 2885M – Public Employees Union, Local 1 (Christian)


Decision Date: December 19, 2023

Decision Type: PERB Decision (Non-Precedential)

Description:  Charging Party Evelyn Christian alleged that Respondent Public Employees Union, Local 1 (Local 1) violated the Meyers-Milias-Brown Act by breaching its duty of fair representation in deciding not to pursue a grievance. After PERB’s Office of the General Counsel (OGC) issued Christian a warning letter, Christian amended the charge. OGC subsequently dismissed the charge on the ground that, even accepting Christian’s allegations as true at the pleading stage, Local 1 considered her case and evaluated its merits before lawfully exercising discretion in deciding not to pursue it further. On appeal, Christian claimed her charge stated a prima facie case that Local 1 breached its duty of fair representation, improperly supporting her argument with multiple new factual allegations.

Disposition:  In a non-precedential decision, the Board affirmed OGC’s dismissal of the charge.

Perc Vol: 48
Perc Index: 95

Decision Headnotes

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