Decision 2983E – California School Employees Association (Sawyer)
LA-CO-1890-E
Decision Date: August 29, 2025
Decision Type: PERB Decision (Non-Precedential)
Description: Shell Sawyer filed a charge in March 2025 that alleged his exclusive representative, California School Employees Association (CSEA), breached its duty of fair representation by declining to pursue and withdrawing a 2018 grievance filed on his behalf. PERB’s Office of the General Counsel (OGC) dismissed Sawyer’s charge, finding that he failed to file his charge within the statute of limitations because, had Sawyer exercised reasonable diligence, he would have known more than six months before he filed his charge that he would not likely receive further assistance from CSEA on the grievance. Sawyer filed an appeal.
Disposition: In a non-precedential decision, the Board affirmed OGC’s dismissal of the charge.
Perc Vol: 50
Perc Index: 62
Decision Headnotes