Decision 3072E – Elk Grove Unified School District
SA-CE-3268-E
Decision Date: October 27, 2026
Decision Type: PERB Decision (Non-Precedential)
Description: Charging Party Kevin Pratt alleged that Respondent Elk Grove Unified School District violated the Educational Employment Relations Act (EERA; Gov. Code, § 3540 et seq.) by interfering with protected employee rights, failing to bargain in good faith, and retaliating against him for protected conduct. Charging Party alleged that the District did not respond to information requests submitted by himself and his exclusive representative, American Federation of State, County and Municipal Employees Local 258 (AFSCME) and that it improperly rejected a wage-adjustment proposal he and AFSCME submitted to the District. He further alleged that the District interfered with his protected rights when it rejected the proposal. PERB’s Office of the General Counsel (OGC) issued Charging Party a warning letter, which explained that the facts Charging Party alleged, if proven, would not establish that the District had violated EERA. The warning letter provided Charging Party an opportunity to amend his charge to cure its deficiencies. Charging Party filed a second amended charge asserting that the District’s response to his salary request was insufficient and had therefore interfered with his rights. He further alleged that the District’s failure to respond to the information requests had interfered with his rights because it had discouraged him from seeking AFSCME’s further assistance. Additionally, he alleged that the District’s rejection of his salary adjustment was in retaliation for his seeking assistance from AFSCME. OGC dismissed the amended charge, concluding it did not state a prima facie case. Charging Party appealed, and the District filed an opposition.
Disposition: In a non-precedential decision, the Board affirmed OGC’s dismissal without leave to amend.
Decision Headnotes