Decision 3024E – Los Angeles Unified School District and California School Employees Association
LA-CE-7015-E and LA-CO-1899-E
Decision Date: May 28, 2026
Decision Type: PERB Decision (Non-Precedential)
Description: Charging Party Alfred Charles Valrie appealed the dismissal of his two unfair practice charges by PERB’s Office of the General Counsel (OGC). In Case No. LA-CE-7015-E, Valrie alleged that Respondent Los Angeles Unified School District violated the Educational Employment Relations Act (EERA) by constructively discharging Valrie, notating his resignation as “Resigned to Avoid Discipline,” and suing Valrie in retaliation for his protected activity. In Case No. LA‑CO-1899-E, Valrie alleges that Respondent California School Employees Association breached its duty of fair representation, thereby violating EERA, when it refused to assist Valrie regarding his constructive discharge and resignation notation. OGC issued warning letters in both cases, finding that the charge against the District was untimely and both charges failed to state prima facie violates of EERA. Valrie amended his charges, and OGC dismissed them, finding that Valrie did not cure the deficiencies outlined in the warning letters.
Disposition: In a non-precedential decision, the Board affirmed the dismissal of Valrie’s charges without leave to amend.
Decision Headnotes