| Decision | Description | PERC Vol. | PERC Index | Date |
|---|---|---|---|---|
| 2505M |
City of Roseville
606.01000: EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES; In General
Where parties tentatively agreed to negotiate “Other Post-Employment Benefits” separate from MOU negotiations and no other evidence was presented as to the importance of that subject or whether the parties’ failure to reach agreement on it contributed in any meaningful way to the breakdown in negotiations, Board declined to disturb ALJ’s finding that negotiations had reached a bona fide impasse as the result of good-faith bargaining. Impasse refers to an overall deadlock in negotiations. An employer may not insist on separating one negotiable subject from all others and then bargain to impasse only as to that subject and impose its proposal, while refusing to discuss other subjects that may form the basis of a possible compromise. Although impasse may result from disagreement over a single subject, that subject must be of such critical and overriding importance to the parties that disagreement on that subject alone causes an overall breakdown in negotiations such that further bargaining over any subject would be futile. (pp. 33-35.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2505M |
City of Roseville
606.15000: EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES; Other
Where parties tentatively agreed to negotiate “Other Post-Employment Benefits” separate from MOU negotiations and no other evidence was presented as to the importance of that subject or whether the parties’ failure to reach agreement on it contributed in any meaningful way to the breakdown in negotiations, Board declined to disturb ALJ’s finding that negotiations had reached a bona fide impasse as the result of good-faith bargaining. Impasse refers to an overall deadlock in negotiations. An employer may not insist on separating one negotiable subject from all others and then bargain to impasse only as to that subject and impose its proposal, while refusing to discuss other subjects that may form the basis of a possible compromise. Although impasse may result from disagreement over a single subject, that subject must be of such critical and overriding importance to the parties that disagreement on that subject alone causes an overall breakdown in negotiations such that further bargaining over any subject would be futile. (pp. 33-35.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2505M |
City of Roseville
900.02000: IMPASSE PROCEDURES; IN GENERAL; DUTY TO PARTICIPATE IN GOOD FAITH; Declaration/Determination of Impasse
Where parties tentatively agreed to negotiate “Other Post-Employment Benefits” separate from MOU negotiations and no other evidence was presented as to the importance of that subject or whether the parties’ failure to reach agreement on it contributed in any meaningful way to the breakdown in negotiations, Board declined to disturb ALJ’s finding that negotiations had reached a bona fide impasse as the result of good-faith bargaining. Impasse refers to an overall deadlock in negotiations. An employer may not insist on separating one negotiable subject from all others and then bargain to impasse only as to that subject and impose its proposal, while refusing to discuss other subjects that may form the basis of a possible compromise. Although impasse may result from disagreement over a single subject, that subject must be of such critical and overriding importance to the parties that disagreement on that subject alone causes an overall breakdown in negotiations such that further bargaining over any subject would be futile. (pp. 33-35.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2505M |
City of Roseville
601.01000: EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; REFUSAL TO BARGAIN IN GOOD FAITH (FOR SPECIFIC SUBJECTS, SEE SCOPE OF REPRESENTATION, SEC 1000); In General, Per Se and Totality of Conduct; Prima Facie Case
Although per se violations may also serve as indicia of bad faith in support of a surface bargaining allegation, there was no evidence that the City’s unilateral change to the employer paid member contribution, which was unilaterally imposed post-impasse, had contributed to the breakdown in pre-impasse negotiations or had undermined IBEW’s authority during the prior negotiations. Although the Board ordered the City to remedy the unilateral change violation, it dismissed the complaint’s separate bad-faith bargaining allegation where no other probative evidence of bad faith had been presented and the City’s unilateral change occurred after negotiations had already broken down. (p. 36.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2505M |
City of Roseville
602.01000: EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; UNILATERAL CHANGE (FOR NEGOT OF SPECIFIC SUBJECTS, SEE SEC 1000, SCOPE OF REPRESENTATION); In General
Although per se violations may also serve as indicia of bad faith in support of a surface bargaining allegation, there was no evidence that the City’s unilateral change to the employer paid member contribution, which was unilaterally imposed post-impasse, had contributed to the breakdown in pre-impasse negotiations or had undermined IBEW’s authority during the prior negotiations. Although the Board ordered the City to remedy the unilateral change violation, it dismissed the complaint’s separate bad-faith bargaining allegation where no other probative evidence of bad faith had been presented and the City’s unilateral change occurred after negotiations had already broken down. (p. 36.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2505M |
City of Roseville
606.01000: EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES; In General
Although per se violations may also serve as indicia of bad faith in support of a surface bargaining allegation, there was no evidence that the City’s unilateral change to the employer paid member contribution, which was unilaterally imposed post-impasse, had contributed to the breakdown in pre-impasse negotiations or had undermined IBEW’s authority during the prior negotiations. Although the Board ordered the City to remedy the unilateral change violation, it dismissed the complaint’s separate bad-faith bargaining allegation where no other probative evidence of bad faith had been presented and the City’s unilateral change occurred after negotiations had already broken down. (p. 36.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2505M |
City of Roseville
606.08000: EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES; Conduct Outside of Negotiations; Prior UPs
Although per se violations may also serve as indicia of bad faith in support of a surface bargaining allegation, there was no evidence that the City’s unilateral change to the employer paid member contribution, which was unilaterally imposed post-impasse, had contributed to the breakdown in pre-impasse negotiations or had undermined IBEW’s authority during the prior negotiations. Although the Board ordered the City to remedy the unilateral change violation, it dismissed the complaint’s separate bad-faith bargaining allegation where no other probative evidence of bad faith had been presented and the City’s unilateral change occurred after negotiations had already broken down. (p. 36.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2514E |
Santa Ana Unified School District
1103.01000: CASE PROCESSING PROCEDURES; COMPLAINT; In General
A Board agent may, either on a motion by the respondent or with notice and on the agency’s own motion, properly dismiss a complaint on a pre-hearing motion to dismiss where the motion establishes failure to prosecute or an affirmative defense as a matter of law based on undisputed facts. (pp. 19-20, 24-25.) However, in the absence of a hearing, a Board agent is not authorized to resolve factual disputes or make credibility determinations to dismiss an unfair practice case, whether the dismissal occurs during the pre-complaint investigation, or after a complaint has issued but before hearing. (PERB Reg. 32207.) Because in this case, the motion to dismiss asserting failure to prosecute and laches was based on disputed material facts, including the timing and significance of a medical condition suffered by a witness, the Board reversed the dismissal and remanded the matter for hearing within a reasonable time to adjudicate the complaint’s allegations. (pp. 2-3.) more or view all topics or full text. |
41 | 132 | 02/08/17 |
| 2514E |
Santa Ana Unified School District
1503.02000: MISCELLANEOUS ISSUES; REGULATIONS; Regulations Considered (By Number)
A Board agent may, either on a motion by the respondent or with notice and on the agency’s own motion, properly dismiss a complaint on a pre-hearing motion to dismiss where the motion establishes failure to prosecute or an affirmative defense as a matter of law based on undisputed facts. (pp. 19-20, 24-25.) However, in the absence of a hearing, a Board agent is not authorized to resolve factual disputes or make credibility determinations to dismiss an unfair practice case, whether the dismissal occurs during the pre-complaint investigation, or after a complaint has issued but before hearing. (PERB Reg. 32207.) Because in this case, the motion to dismiss asserting failure to prosecute and laches was based on disputed material facts, including the timing and significance of a medical condition suffered by a witness, the Board reversed the dismissal and remanded the matter for hearing within a reasonable time to adjudicate the complaint’s allegations. (pp. 2-3.) more or view all topics or full text. |
41 | 132 | 02/08/17 |
| 2514E |
Santa Ana Unified School District
1503.03000: MISCELLANEOUS ISSUES; REGULATIONS; Regulations Considered (By Number) (Continued)
A Board agent may, either on a motion by the respondent or with notice and on the agency’s own motion, properly dismiss a complaint on a pre-hearing motion to dismiss where the motion establishes failure to prosecute or an affirmative defense as a matter of law based on undisputed facts. (pp. 19-20, 24-25.) However, in the absence of a hearing, a Board agent is not authorized to resolve factual disputes or make credibility determinations to dismiss an unfair practice case, whether the dismissal occurs during the pre-complaint investigation, or after a complaint has issued but before hearing. (PERB Reg. 32207.) Because in this case, the motion to dismiss asserting failure to prosecute and laches was based on disputed material facts, including the timing and significance of a medical condition suffered by a witness, the Board reversed the dismissal and remanded the matter for hearing within a reasonable time to adjudicate the complaint’s allegations. (pp. 2-3.) more or view all topics or full text. |
41 | 132 | 02/08/17 |
| 2514E |
Santa Ana Unified School District
1100.05000: CASE PROCESSING PROCEDURES; CHARGE; Dismissal of Charge; Appeal
Unlike most PERB failure to prosecute cases, in which the charging party fails or refuses to attend or participate in a duly noticed hearing, in this case, the complaint was dismissed without hearing based on a pre-hearing motion. Because the matter was dismissed without hearing, the Board applied the standard governing the pre-complaint investigation of an unfair charge to consideration of pre-hearing motions to dismiss. Although designated as “exceptions” to a proposed decision, the charging party’s filing, which substantially complied with the requirements of PERB Regulation 32635, subdivision (a), was treated as an appeal from dismissal. (pp. 2, 28.) more or view all topics or full text. |
41 | 132 | 02/08/17 |
| 2505M |
City of Roseville
1103.01000: CASE PROCESSING PROCEDURES; COMPLAINT; In General
Where conduct allegedly constitutes both evidence of the respondent’s bad faith and a separate unfair practice, the essential facts for each theory of liability should be stated in the complaint and identified as separate unfair practices. A respondent is entitled to notice of the issues in dispute, so that it can preserve documents and secure witnesses, or expect repose as to those unfair practice allegations that are dismissed, withdrawn, abandoned or otherwise disposed of during the Office of the General Counsel’s investigation. (PERB Regs. 32620, subd. (c), 32630, 32640, subds. (a), (b).) Identifying the essential factual allegations and the theories of liability in a complaint is necessary to provide adequate notice and ensure a full and fair adjudication of the issues, including an opportunity for the respondent to raise any affirmative defenses specific to each theory of liability. (pp. 15-16.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2505M |
City of Roseville
1103.03000: CASE PROCESSING PROCEDURES; COMPLAINT; Variance of Complaint from Charge; Evidence, Findings, or Order Varying from Complaint; Events Subsequent to Charge or Complaint
Where conduct allegedly constitutes both evidence of the respondent’s bad faith and a separate unfair practice, the essential facts for each theory of liability should be stated in the complaint and identified as separate unfair practices. A respondent is entitled to notice of the issues in dispute, so that it can preserve documents and secure witnesses, or expect repose as to those unfair practice allegations that are dismissed, withdrawn, abandoned or otherwise disposed of during the Office of the General Counsel’s investigation. (PERB Regs. 32620, subd. (c), 32630, 32640, subds. (a), (b).) Identifying the essential factual allegations and the theories of liability in a complaint is necessary to provide adequate notice and ensure a full and fair adjudication of the issues, including an opportunity for the respondent to raise any affirmative defenses specific to each theory of liability. (pp. 15-16.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2505M |
City of Roseville
1103.04000: CASE PROCESSING PROCEDURES; COMPLAINT; Amendments
Where conduct allegedly constitutes both evidence of the respondent’s bad faith and a separate unfair practice, the essential facts for each theory of liability should be stated in the complaint and identified as separate unfair practices. A respondent is entitled to notice of the issues in dispute, so that it can preserve documents and secure witnesses, or expect repose as to those unfair practice allegations that are dismissed, withdrawn, abandoned or otherwise disposed of during the Office of the General Counsel’s investigation. (PERB Regs. 32620, subd. (c), 32630, 32640, subds. (a), (b).) Identifying the essential factual allegations and the theories of liability in a complaint is necessary to provide adequate notice and ensure a full and fair adjudication of the issues, including an opportunity for the respondent to raise any affirmative defenses specific to each theory of liability. (pp. 15-16.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2505M |
City of Roseville
1105.01000: CASE PROCESSING PROCEDURES; EVIDENCE; In General
Where conduct allegedly constitutes both evidence of the respondent’s bad faith and a separate unfair practice, the essential facts for each theory of liability should be stated in the complaint and identified as separate unfair practices. A respondent is entitled to notice of the issues in dispute, so that it can preserve documents and secure witnesses, or expect repose as to those unfair practice allegations that are dismissed, withdrawn, abandoned or otherwise disposed of during the Office of the General Counsel’s investigation. (PERB Regs. 32620, subd. (c), 32630, 32640, subds. (a), (b).) Identifying the essential factual allegations and the theories of liability in a complaint is necessary to provide adequate notice and ensure a full and fair adjudication of the issues, including an opportunity for the respondent to raise any affirmative defenses specific to each theory of liability. (pp. 15-16.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2505M |
City of Roseville
1105.02000: CASE PROCESSING PROCEDURES; EVIDENCE; Background Evidence and Matters Not Alleged
Where conduct allegedly constitutes both evidence of the respondent’s bad faith and a separate unfair practice, the essential facts for each theory of liability should be stated in the complaint and identified as separate unfair practices. A respondent is entitled to notice of the issues in dispute, so that it can preserve documents and secure witnesses, or expect repose as to those unfair practice allegations that are dismissed, withdrawn, abandoned or otherwise disposed of during the Office of the General Counsel’s investigation. (PERB Regs. 32620, subd. (c), 32630, 32640, subds. (a), (b).) Identifying the essential factual allegations and the theories of liability in a complaint is necessary to provide adequate notice and ensure a full and fair adjudication of the issues, including an opportunity for the respondent to raise any affirmative defenses specific to each theory of liability. (pp. 15-16.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2505M |
City of Roseville
1503.02000: MISCELLANEOUS ISSUES; REGULATIONS; Regulations Considered (By Number)
Where conduct allegedly constitutes both evidence of the respondent’s bad faith and a separate unfair practice, the essential facts for each theory of liability should be stated in the complaint and identified as separate unfair practices. A respondent is entitled to notice of the issues in dispute, so that it can preserve documents and secure witnesses, or expect repose as to those unfair practice allegations that are dismissed, withdrawn, abandoned or otherwise disposed of during the Office of the General Counsel’s investigation. (PERB Regs. 32620, subd. (c), 32630, 32640, subds. (a), (b).) Identifying the essential factual allegations and the theories of liability in a complaint is necessary to provide adequate notice and ensure a full and fair adjudication of the issues, including an opportunity for the respondent to raise any affirmative defenses specific to each theory of liability. (pp. 15-16.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2505M |
City of Roseville
1503.03000: MISCELLANEOUS ISSUES; REGULATIONS; Regulations Considered (By Number) (Continued)
Where conduct allegedly constitutes both evidence of the respondent’s bad faith and a separate unfair practice, the essential facts for each theory of liability should be stated in the complaint and identified as separate unfair practices. A respondent is entitled to notice of the issues in dispute, so that it can preserve documents and secure witnesses, or expect repose as to those unfair practice allegations that are dismissed, withdrawn, abandoned or otherwise disposed of during the Office of the General Counsel’s investigation. (PERB Regs. 32620, subd. (c), 32630, 32640, subds. (a), (b).) Identifying the essential factual allegations and the theories of liability in a complaint is necessary to provide adequate notice and ensure a full and fair adjudication of the issues, including an opportunity for the respondent to raise any affirmative defenses specific to each theory of liability. (pp. 15-16.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2571M |
City of San Ramon
606.01000: EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES; In General
To determine whether a party has negotiated with the requisite subjective intention of reaching an agreement, the Board considers all evidence relevant to intent, including the parties’ conduct away from the bargaining table. (City of San Jose (2013) PERB Decision No. 2341-M, pp. 22-23.) The “ultimate question” is whether the respondent’s conduct, when viewed in its totality, was sufficiently egregious to frustrate negotiations. (Id. at p. 19.) A single indicator of bad faith, if egregious, can be a sufficient basis for finding that a negotiating party has failed to bargain in good faith. (Ibid.) The “ultimate determination of good or bad faith turns, not on a formula for the number of meetings that must occur or the number of proposals that must be exchanged before a bona fide impasse exists, but on the effect of a party’s conduct on the course of negotiations.” (Id. at p. 42.) more or view all topics or full text. |
43 | 6 | 06/20/18 |
| 2571M |
City of San Ramon
606.02000: EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES; Inflexible Position
A party exhibits bad faith if it fails to adequately explain its inflexible position. (County of San Luis Obispo (2015) PERB Decision No. 2427-M, p. 29; San Bernardino City Unified School District (1998) PERB Decision No. 1270, at pp. 85-86.) However, an inflexible position that is fairly maintained and rationally supported does not, alone, prove bad faith. (Oakland Unified School District (1982) PERB Decision No. 275, p. 16.) Hard bargaining cannot shield party from liability if it adopted a take-it-or-leave-it attitude or rushed to impasse. Employer adopted a “take-it-or-leave it” attitude when it (1) presented its position as an ultimatum, telling union it had a choice of either accepting new terms or arriving at impasse; (2) showed a predetermination to negotiate or impose its own proposals without carefully and mutually reviewing the union’s proposals, issues, and concessions; and (3) declared impasse based not on an assessment of the parties’ actual differences, but on the fact that it had not achieved capitulation to all of its demands. Furthermore, County of Solano (2014) PERB Decision No. 2402-M, is in tension with Regents of the University of California (1983) PERB Decision No. 356-H, p. 21, as it may be bad faith for employer to insist that it will not agree to different terms for different employee groups. more or view all topics or full text. |
43 | 6 | 06/20/18 |
| 2505M |
City of Roseville
1105.02000: CASE PROCESSING PROCEDURES; EVIDENCE; Background Evidence and Matters Not Alleged
Unless alleged as separate unfair practices, which would expand the respondent’s liability beyond what is already alleged in the complaint, indicators of bad faith alleged in the charge but not included in the complaint were proper for consideration as part of the totality of evidence considered in a surface bargaining case without resort to PERB’s unalleged violations doctrine. As its name suggests, the unalleged violation doctrine applies when, if proven, factual allegations presented at hearing but not included in the complaint would constitute a separate unfair practice in addition to the theories of liability set forth in the complaint. [citations omitted.] Because surface bargaining was alleged in the complaint, there was no additional or unalleged surface bargaining “violation” to consider. Although recognized as evidence of bad faith, making predictably unacceptable proposals and prematurely declaring impasse are not independent unfair practices. (p. 17.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2571M |
City of San Ramon
606.05000: EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES; Dilatory or Evasive Tactics
A party demonstrates bad faith when it rushes to impasse, or if its impasse declaration is “premature, unfounded, or insincere.” A budget deadline is not an exigent circumstance allowing employer to accelerate negotiations unilaterally. Employer holding a budget vote before completing negotiations and post-impasse procedures must refrain from voting on concessions that have not yet been ratified. While section 3505 of the MMBA provides that parties shall endeavor to reach agreement prior to a public agency’s adoption of its final budget, the statute’s use of non-mandatory language renders it “only hortatory” and contrasts with the law’s other, obligatory mandates, such as the duty to bargain for a reasonable and adequate amount of time to allow for good faith negotiations. (Dublin Professional Firefighters Local 1885 v. Valley Community Services District (1975) 45 Cal.App.3d 116, 118.) more or view all topics or full text. |
43 | 6 | 06/20/18 |
| 2505M |
City of Roseville
1105.02000: CASE PROCESSING PROCEDURES; EVIDENCE; Background Evidence and Matters Not Alleged
Although charging party’s allegations of making predictably unacceptable proposals and prematurely declaring impasse were not alleged in the complaint, these two allegations were nonetheless appropriate for consideration by analogy to the unalleged violations doctrine. Although the complaint is the operative document for framing the issues for hearing, the Board has reasoned, by analogy to the unalleged violations doctrine, that conduct which constitutes an essential element of an unfair practice, but which was not alleged in the complaint, may still be considered, if it is related to the claims in the complaint, and if the parties have had full opportunity to litigate the issues. (pp. 19-20.) more or view all topics or full text. |
41 | 97 | 11/30/16 |
| 2571M |
City of San Ramon
606.06000: EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES; Time Limit on Negotiations
A party demonstrates bad faith when it rushes to impasse, or if its impasse declaration is “premature, unfounded, or insincere.” A budget deadline is not an exigent circumstance allowing employer to accelerate negotiations unilaterally. Employer holding a budget vote before completing negotiations and post-impasse procedures must refrain from voting on concessions that have not yet been ratified. While section 3505 of the MMBA provides that parties shall endeavor to reach agreement prior to a public agency’s adoption of its final budget, the statute’s use of non-mandatory language renders it “only hortatory” and contrasts with the law’s other, obligatory mandates, such as the duty to bargain for a reasonable and adequate amount of time to allow for good faith negotiations. (Dublin Professional Firefighters Local 1885 v. Valley Community Services District (1975) 45 Cal.App.3d 116, 118.) more or view all topics or full text. |
43 | 6 | 06/20/18 |
| 2571M |
City of San Ramon
606.11000: EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; NEGOTIATIONS; INDICIA OF SURFACE OR BAD FAITH BARGAINING; TOTALITY OF CIRCUMSTANCES; Failure to Provide Counter-Proposals
A party exhibits bad faith if it fails to adequately explain its inflexible position. (County of San Luis Obispo (2015) PERB Decision No. 2427-M, p. 29; San Bernardino City Unified School District (1998) PERB Decision No. 1270, at pp. 85-86.) However, an inflexible position that is fairly maintained and rationally supported does not, alone, prove bad faith. (Oakland Unified School District (1982) PERB Decision No. 275, p. 16.) Hard bargaining cannot shield party from liability if it adopted a take-it-or-leave-it attitude or rushed to impasse. Employer adopted a “take-it-or-leave it” attitude when it (1) presented its position as an ultimatum, telling union it had a choice of either accepting new terms or arriving at impasse; (2) showed a predetermination to negotiate or impose its own proposals without carefully and mutually reviewing the union’s proposals, issues, and concessions; and (3) declared impasse based not on an assessment of the parties’ actual differences, but on the fact that it had not achieved capitulation to all of its demands. Furthermore, County of Solano (2014) PERB Decision No. 2402-M, is in tension with Regents of the University of California (1983) PERB Decision No. 356-H, p. 21, as it may be bad faith for employer to insist that it will not agree to different terms for different employee groups. more or view all topics or full text. |
43 | 6 | 06/20/18 |
Notice Regarding Use of Generative Artificial Intelligence (“AI”) at PERB
For information about use of AI in PERB filings, see Atwater Elementary Teachers Association, CTA/NEA (Garcia) (2025) PERB Decision No. 2995-E and our FAQ.
