| Decision | Description | PERC Vol. | PERC Index | Date |
|---|---|---|---|---|
| 2904E |
Clovis Unified School District
700.01000: EMPLOYER DOMINATION OR ASSISTANCE; DOMINATION OF OR ASSISTANCE TO LABOR ORGANIZATIONS; In General
In finding that District dominated the Senate, the Board found that these facts, among others, showed the lack of an arm’s length relationship, while noting that certain facts, by themselves, would be enough to prove domination: (1) District policy identified the Senate as the de facto official representative for teachers, although teachers never chose the Senate to be their exclusive representative; (2) the District’s organizational charts showed that the Senate president reports to the District superintendent; (3) the Senate president repeatedly consulted the District on questions that arose in running the Senate; (4) District administrators regularly attended Senate meetings, and the District approved Senate meeting minutes before the Senate shared them with teachers; (5) the District conducted internal Senate elections; (6) the District adjusted complaints and conducted investigations filed by and against senators and Senate officers in those capacities, including promising that the Senate would establish policies and procedures regarding attendance at Senate meetings; (7) in response to a Senate officer’s complaint, the District reached more than a dozen conclusions which show domination and interference with Senate administration, including promising that the District would work with the Senate to create a procedure for senate elections and setting an expectation for the Senate president to respond to inquiries within 24 hours; (8) the only binding agreement the District signed with the Senate was one that was financially useful to the employer; (9) the District provided extensive financial support to the Senate which it did not provide to other entities; and (10) the District sent e-mail defending its support of the Senate and castigating a rival nonexclusive representative for trying to enforce the law. (pp. 37-40.) more or view all topics or full text. |
49 | 14 | 06/20/24 |
| 2904E |
Clovis Unified School District
700.01000: EMPLOYER DOMINATION OR ASSISTANCE; DOMINATION OF OR ASSISTANCE TO LABOR ORGANIZATIONS; In General
District involvement in internal elections of the Senate, a nonexclusive representative, showed unlawful domination and interference with the Senate’s administration. (See Poway Unified School District (2015) PERB Decision No. 2441, adopting proposed decision at p. 45 [“an employer must not intervene to address the lawfulness of a union’s internal procedures affecting voting or to police the union’s actions, lest it be held liable for interfering in the administration of the union”].) (p. 39.) more or view all topics or full text. |
49 | 14 | 06/20/24 |
| 2904E |
Clovis Unified School District
700.01000: EMPLOYER DOMINATION OR ASSISTANCE; DOMINATION OF OR ASSISTANCE TO LABOR ORGANIZATIONS; In General
EERA section 3543.5, subdivision (d) equally bars formation, domination, and interference with the administration of an employee organization. In assessing such claims, PERB considers whether the employer’s conduct tends to interfere with the employee organization’s ability to maintain an arm’s length relationship with the employer. (Clovis Unified School District (2021) PERB Order No. IR-63, pp. 18-19; City of Arcadia (2019) PERB Decision No. 2648-M, pp. 24-25; Azusa Unified School District (1977) EERB Decision No. 38, adopting recommended decision at p. 6, fn. 3.) The level of the employer’s involvement in the employee organization’s internal affairs is relevant, particularly in determining whether the conduct rises to the level of domination or merely constitutes unlawful support or interference with internal affairs. (City of Arcadia (2019) PERB Decision No. 2648-M, p. 23; Redwoods Community College District (1987) PERB Decision No. 650, adopting proposed decision at p. 62.) (pp. 37-38.) more or view all topics or full text. |
49 | 14 | 06/20/24 |
| 2904E |
Clovis Unified School District
700.01000: EMPLOYER DOMINATION OR ASSISTANCE; DOMINATION OF OR ASSISTANCE TO LABOR ORGANIZATIONS; In General
EERA section 3543.5, subdivision (d) makes it unlawful for an employer to “[d]ominate or interfere with the formation or administration of any employee organization, or contribute financial or other support to it, or in any way encourage employees to join any organization in preference to another.” There are three ways an employer may violate this subdivision. Different standards apply depending on whether a charging party alleges that an employer has: (1) dominated or interfered with the formation or administration of an employee organization; (2) unlawfully contributed financial or other support to an employee organization; or (3) in any way encouraged employees to join any organization in preference to another. As a threshold matter, however, it is important to note that the employer’s intent is irrelevant to each of these three types of claims. (Clovis Unified School District (2021) PERB Decision No. IR-63, p. 18; City of Arcadia (2019) PERB Decision No. 2648-M, pp. 24-25; West Contra Costa County Healthcare District (2011) PERB Decision No. 2164-M, p. 6; Redwoods Community College District (1987) PERB Decision No. 650, adopting proposed decision at pp. 53 & 56-57; Santa Monica Community College District (1979) PERB Decision No. 103, p. 22.) (p. 36.) more or view all topics or full text. |
49 | 14 | 06/20/24 |
| 2904E |
Clovis Unified School District
607.02000: EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; DUTY TO CONSULT; With Nonexclusive Representatives
A nonexclusive representative, whether or not it is seeking to ultimately be certified as an exclusive representative, has the right to receive advance notice of contemplated changes in fundamental employment terms or conditions, as well as the right to meet and discuss with the employer before it reaches a decision on such matters. (Alliance College-Ready Public Schools, et al. (2020) PERB Decision No. 2716, p. 20.) In such discussions, the employer need not engage in the full breadth of bargaining as it must with an exclusive representative, but it must listen and consider proposals in good faith. (Id. at pp. 23-24.) Furthermore, a nonexclusive representative has the right to information it needs to meet and discuss in good faith, to evaluate grievances, or to pursue administrative or legal remedies on behalf of employees. (Regents of the University of California (1999) PERB Decision No. 1354-H, adopting proposed decision, pp. 45-48; Santa Monica Community College District (1979) PERB Decision No. 103, p. 15.) However, because an employer has greater legal obligations to an exclusive representative than to a nonexclusive representative, the duty of strict neutrality does not always require an employer to afford the latter type of organization all the same privileges as the former. (Clovis Unified School District (2021) PERB Order No. IR-63, pp. 22-23, fn. 14; County of San Bernardino (2018) PERB Decision No. 2556-M, p. 10, fn. 11 & pp. 18-19; West Contra Costa Healthcare District (2010) PERB Decision No. 2145-M, p. 22.) (pp. 6 & 45, fn. 11.) more or view all topics or full text. |
49 | 14 | 06/20/24 |
| 2904E |
Clovis Unified School District
300.03000: UNFAIR PRACTICE ISSUES; PROTECTED ACTIVITIES; Activities for Nonexclusive Representative - Protected Right
A nonexclusive representative, whether or not it is seeking to ultimately be certified as an exclusive representative, has the right to receive advance notice of contemplated changes in fundamental employment terms or conditions, as well as the right to meet and discuss with the employer before it reaches a decision on such matters. (Alliance College-Ready Public Schools, et al. (2020) PERB Decision No. 2716, p. 20.) In such discussions, the employer need not engage in the full breadth of bargaining as it must with an exclusive representative, but it must listen and consider proposals in good faith. (Id. at pp. 23-24.) Furthermore, a nonexclusive representative has the right to information it needs to meet and discuss in good faith, to evaluate grievances, or to pursue administrative or legal remedies on behalf of employees. (Regents of the University of California (1999) PERB Decision No. 1354-H, adopting proposed decision, pp. 45-48; Santa Monica Community College District (1979) PERB Decision No. 103, p. 15.) However, because an employer has greater legal obligations to an exclusive representative than to a nonexclusive representative, the duty of strict neutrality does not always require an employer to afford the latter type of organization all the same privileges as the former. (Clovis Unified School District (2021) PERB Order No. IR-63, pp. 22-23, fn. 14; County of San Bernardino (2018) PERB Decision No. 2556-M, p. 10, fn. 11 & pp. 18-19; West Contra Costa Healthcare District (2010) PERB Decision No. 2145-M, p. 22.) (pp. 6 & 45, fn. 11.) more or view all topics or full text. |
49 | 14 | 06/20/24 |
| 2904E |
Clovis Unified School District
202.06000: PARTIES; DEFINITIONS; EMPLOYEE ORGANIZATIONS; Nonexclusive Representatives
A “nonexclusive representative” is an employee organization that represents certain employees but is not an exclusive representative within the meaning of EERA section 3540.1, subdivision (e). (Clovis Unified School District (2021) PERB Order No. IR-63, p. 3, fn. 3.) (p. 6.) more or view all topics or full text. |
49 | 14 | 06/20/24 |
| 2904E |
Clovis Unified School District
101.03000: PERB: OPERATION, JURISDICTION, AUTHORITY; APPLICABILITY OF AND CONFLICTS WITH OTHER STATUTES; NLRA/LMRDA Precedent
California public sector labor relations precedent frequently protects employee and union rights to a greater degree than does federal precedent governing private sector labor relations, and PERB accordingly considers federal precedent only for its potential persuasive value. (The Accelerated Schools (2023) PERB Decision No. 2855, pp. 20-31; Operating Engineers Local Union No. 3 (Wagner et al.) (2021) PERB Decision No. 2782-M, p. 9, fn. 10; accord County of San Joaquin v. Public Employment Relations Bd. (2022) 82 Cal.App.5th 1053, 1073; Social Workers’ Union, Local 535 v. Alameda County Welfare Dept. (1974) 11 Cal.3d 382, 391.) (p. 55, fn. 12.) more or view all topics or full text. |
49 | 14 | 06/20/24 |
| A518E |
Pasadena Area Community College District
1402.06000: GENERAL LEGAL PRINCIPLES; WAIVER; Failure to File Exceptions
If neither party files exceptions to a proposed decision of an administrative law judge, the proposed decision becomes final and binding on the parties. (See Regents of the University of California (2023) PERB Decision No. 2884-H, p. 6 [noting impact of final decisions issued after neither party excepts to a proposed decision].) By declining to file exceptions to the proposed decision, the District waived its right to challenge the ALJ’s conclusions. (City of Pasadena (2014) PERB Order No. Ad-406-M, pp. 15-17.) (pp. 1-2.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1205.04000: REMEDIES FOR UNFAIR PRACTICES; MISCELLANEOUS REMEDIAL PROVISIONS; Attorneys Fees and Costs
A party to a PERB matter seeking litigation expenses based upon its attorney fees and costs in that matter must normally prove that its opponent maintained a claim, defense, or motion, or engaged in another action or tactic, that was without arguable merit and pursued in bad faith. (Sacramento City Unified School District (2020) PERB Decision No. 2749, p. 11.) Although the District raised arguments that had already been resolved and were no longer subject to dispute, the District integrated those arguments with non-frivolous ones and convinced the Board to reverse the Board agent’s administrative determination. Accordingly, the Board did not find the District’s conduct in litigating compliance issues met the sanctions standard. (pp. 21-22.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1201.03000: REMEDIES FOR UNFAIR PRACTICES; REINSTATEMENT; BACKPAY BENEFITS; Back Pay; Interest
PERB orders payment of overtime as part of backpay when the charging party establishes that a violation more likely than not caused a loss of overtime opportunities. (Antelope Valley Community College District (2018) PERB Decision No. 2618, pp. 25-26 [ordering backpay for lost overtime]; County of Riverside (2018) PERB Decision No. 2591a-M, p. 2 [same]; San Jacinto Unified School District (1994) PERB Decision No. 1078, p. 4 [overtime awarded based on extrapolating from overtime worked over previous three years]; cf. Long Beach Community College District (2009) PERB Decision No. 2002, p. 18 [backpay did not include daily overtime because the impacted employees had voluntarily agreed to work four ten-hour shifts, and thus were not eligible for daily overtime under the parties’ contract].) (p. 21.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1201.03000: REMEDIES FOR UNFAIR PRACTICES; REINSTATEMENT; BACKPAY BENEFITS; Back Pay; Interest
Theoretical rights have at most limited relevance when PERB’s task is to estimate losses that employees more likely than not would have avoided had the status quo remained the same. Thus, in ascertaining damages for a unilateral change violation, the central damages inquiry is to ascertain those faculty who more likely than not lost the opportunity to teach during winter intersessions which, in each of two years, were replaced with a second summer intersession because of the District’s unlawful conduct. That inquiry does not turn on whether faculty had a statutory right to teach during an intersession, or whether management had a statutory right to refrain from rehiring part-time faculty from term to term. (pp. 18-19.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1201.03000: REMEDIES FOR UNFAIR PRACTICES; REINSTATEMENT; BACKPAY BENEFITS; Back Pay; Interest
When calculating damages over multiple years, if an employee’s potential loss was more than offset in one of the two years (i.e., the formula for that year yields a negative number), that amount does not offset losses (if any) in the other year. (Bellflower Unified School District (2022) PERB Decision No. 2544a, p. 33.) Moreover, the employer cannot seek to offset the harm certain employees have incurred by pointing to other employees who benefited from the employer’s unlawful conduct. Rather, PERB orders a wrongdoer to make whole impacted employees while holding harmless innocent actors who benefited. (State of California (Correctional Health Care Services) (2021) PERB Decision No. 2760-S, p. 42; County of Kern (2018) PERB Decision No. 2615-M, pp. 11-12.) (pp. 18-19, fns. 10 & 11.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1201.03000: REMEDIES FOR UNFAIR PRACTICES; REINSTATEMENT; BACKPAY BENEFITS; Back Pay; Interest
In calculating damages for loss of opportunity to teach during winter intersession, the District urged that PERB offset damages with both unemployment benefits and income faculty earned during summer intersessions at the District, but it did not seek to carry its burden to show that any faculty member failed to mitigate damages by seeking employment elsewhere. (See Bellflower Unified School District (2022) PERB Decision No. 2544a, p. 29 (Bellflower) [respondent that violated the law bears the burden of proving failure to mitigate damages].) The District therefore waived any such argument. Moreover, unemployment benefits are not interim earnings that offset damages. (Id. at p. 31.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1201.01000: REMEDIES FOR UNFAIR PRACTICES; REINSTATEMENT; BACKPAY BENEFITS; In General
A charging party bears the burden of proving by a preponderance of the evidence that a violation materially caused harm. (Bellflower Unified School District (2022) PERB Decision No. 2544a, p. 26 (Bellflower).) However, the charging party need not prove damages precisely. Rather, make-whole relief usually involves predictions and estimates, and thus an approximation may be sufficient to meet the charging party’s burden. (Bellflower, supra, at p. 26; City of Pasadena (2014) PERB Order No. Ad-406-M, p. 14.) PERB resolves uncertainties against the wrongdoer. (Bellflower, supra, at p. 26; Lodi Unified School District (2020) PERB Decision No. 2723, p. 21, fn. 13; City of Culver City (2020) PERB Decision No. 2731-M, p. 26; City of Pasadena, supra, at p. 27.) Moreover, provided that an estimate has a rational basis and is not so excessive as to be punitive, it appropriately serves both a compensatory and deterrent function. (Bellflower, supra, at p. 26; City of Pasadena, supra, at p. 13.) (pp. 13-14.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1108.02000: UNFAIR PRACTICE PROCEDURES; COMPLIANCE; Burden of Proof
A charging party bears the burden of proving by a preponderance of the evidence that a violation materially caused harm. ( Bellflower Unified School District (2022) PERB Decision No. 2544a, p. 26 (Bellflower).) However, the charging party need not prove damages precisely. Rather, make-whole relief usually involves predictions and estimates, and thus an approximation may be sufficient to meet the charging party’s burden. (Bellflower, supra, at p. 26; City of Pasadena (2014) PERB Order No. Ad-406-M, p. 14.) PERB resolves uncertainties against the wrongdoer. (Bellflower, supra, at p. 26; Lodi Unified School District (2020) PERB Decision No. 2723, p. 21, fn. 13; City of Culver City (2020) PERB Decision No. 2731-M, p. 26; City of Pasadena, supra, at p. 27.) Moreover, provided that an estimate has a rational basis and is not so excessive as to be punitive, it appropriately serves both a compensatory and deterrent function. (Bellflower, supra, at p. 26; City of Pasadena, supra, at p. 13.) (pp. 13-14.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1108.02000: UNFAIR PRACTICE PROCEDURES; COMPLIANCE; Burden of Proof
In calculating damages for loss of opportunity to teach during winter intersession, the District urged that PERB offset damages with both unemployment benefits and income faculty earned during summer intersessions at the District, but it did not seek to carry its burden to show that any faculty member failed to mitigate damages by seeking employment elsewhere. (See Bellflower Unified School District (2022) PERB Decision No. 2544a, p. 29 (Bellflower) [respondent that violated the law bears the burden of proving failure to mitigate damages].) The District therefore waived any such argument. Moreover, unemployment benefits are not interim earnings that offset damages. (Id. at p. 31.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1108.01000: UNFAIR PRACTICE PROCEDURES; COMPLIANCE; In General
A decision of the Board itself regarding alleged unfair practices will qualify as a “final decision or order of the board in an unfair practice case” pursuant to Government Code section 3542, subdivision (b), if the decision dismisses all allegations or if the only process that remains to be finished is ensuring compliance with a remedial order. Respondents in most unfair practice cases therefore can consider whether to file an appellate writ before they must comply with a remedial order the Board issues. Occasionally, a respondent has the right to appeal two different Board decisions in the same case—an initial appeal regarding the Board’s main decision and then, after that appeal ends and PERB compliance proceedings take place, a second appeal limited to any new Board decision regarding compliance. The
Board’s order is interlocutory, as it addresses just one question and remands for further proceedings on multiple compliance issues. Therefore, it is not yet appealable under Government Code section 3542, subdivision (b), and the period in which a party may file a writ on compliance issues would begin only after any final compliance order issued by the Board itself. (See State of California (California Correctional Health Care Services) (2024) PERB Decision No. 2888-S, p. 38, fn. 17 [decision reversing and remanding for further litigation is not a final decision subject to appeal].) (p. 22, fn. 12.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1108.01000: UNFAIR PRACTICE PROCEDURES; COMPLIANCE; In General
Faculty association sought damages for District’s unilateral change replacing the winter intersession with a second summer intersession. However, the faculty association proposed a methodology to estimate damages based on a change the complaint did not challenge: the District offering fewer total intersession work hours in the damages years than it did in the status quo year. The Board agent nonetheless adopted the faculty association’s methodology, and noted its approach sought to estimate “the amount of backpay compensation owed because of the reduction of hours.” This was an error given that the final decision did not find a duty to bargain over a reduction in intersession hours. The Board remanded to the Office of General Counsel to make reasonable efforts to more narrowly tailor its damages order to the District’s violations, excluding to the extent feasible those resulting from the lower number of intersession classes offered, while recognizing that PERB resolves uncertainties against the wrongdoer. (See City of Glendale (2020) PERB Decision No. 2694-M, pp. 74-75 [where decision to eliminate mechanic classification was based upon both a lawful decision to reduce the amount of overall construction and an unlawful decision to subcontract and transfer remaining work, Board directed compliance officer to estimate harms caused by unlawful conduct].) The Board instructed that on remand, the Board agent’s task is to arrive at a rationally supported methodology that, on average, estimates harm resulting from unlawful conduct rather than from the lower number of intersession classes in the damages years. (pp. 15-17.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1108.01000: UNFAIR PRACTICE PROCEDURES; COMPLIANCE; In General
Compliance proceedings should typically not lead to protracted litigation. (Bellflower Unified School District (2022) PERB Decision No. 2544a, p. 15.) For instance, during compliance proceedings in cases where an unlawful unilateral change affected a sizable number of employees, obtaining individualized testimony or declarations from each impacted employee will rarely be a realistic or preferred means of estimating damages. But individualized testimony is more likely to be warranted if a small number of employees are individually owed an unusually large sum. (Id. at pp. 15, 64-130 & 136-137 [impacted employees testified during compliance proceedings in case where employer owed over $1,000,000 to 10 employees].) (p. 14.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1108.01000: UNFAIR PRACTICE PROCEDURES; COMPLIANCE; In General
Pursuant to PERB Regulation 32980, subdivision (a), PERB’s Office of the General Counsel assigns a Board agent to ensure that the parties comply with final Board orders. more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1108.01000: UNFAIR PRACTICE PROCEDURES; COMPLIANCE; In General
In compliance proceedings, the parties agreed that the Board agent should first resolve make-whole relief for faculty, before turning to litigation sanctions. Because the Board agent had not yet addressed the litigation sanctions the District owes, the administrative determination (AD) was an interlocutory order rather than a final one. (See Morgan Hill Unified School District (2016) PERB Order No. Ad-443, pp. 4-5.) Although the District did not seek permission to file an interlocutory appeal as required in PERB Regulation 32200, the Board resolved the appeal nonetheless because the AD wrongly stated that the parties could file an appeal under PERB Regulation 32360. (p. 3, fn. 3.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1107.21000: CASE PROCESSING PROCEDURES;PROCEDURES BEFORE THE BOARD; Administrative Appeals
In considering the District’s appeal regarding damages calculations made by a Board agent in compliance proceedings, the Board accepted as settled the ALJ’s conclusions—to which neither party had excepted—but reviewed the Board agent’s determinations de novo to the extent they went beyond the ALJ’s conclusions. (p. 3.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1107.12000: CASE PROCESSING PROCEDURES;PROCEDURES BEFORE THE BOARD; Interlocutory Appeal
A decision of the Board itself regarding alleged unfair practices will qualify as a “final decision or order of the board in an unfair practice case” pursuant to Government Code section 3542, subdivision (b), if the decision dismisses all allegations or if the only process that remains to be finished is ensuring compliance with a remedial order. Respondents in most unfair practice cases therefore can consider whether to file an appellate writ before they must comply with a remedial order the Board issues. Occasionally, a respondent has the right to appeal two different Board decisions in the same case—an initial appeal regarding the Board’s main decision and then, after that appeal ends and PERB compliance proceedings take place, a second appeal limited to any new Board decision regarding compliance. The
Board’s order is interlocutory, as it addresses just one question and remands for further proceedings on multiple compliance issues. Therefore, it is not yet appealable under Government Code section 3542, subdivision (b), and the period in which a party may file a writ on compliance issues would begin only after any final compliance order issued by the Board itself. (See State of California (California Correctional Health Care Services) (2024) PERB Decision No. 2888-S, p. 38, fn. 17 [decision reversing and remanding for further litigation is not a final decision subject to appeal].) (p. 22, fn. 12.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
| A518E |
Pasadena Area Community College District
1107.12000: CASE PROCESSING PROCEDURES;PROCEDURES BEFORE THE BOARD; Interlocutory Appeal
In compliance proceedings, the parties agreed that the Board agent should first resolve make-whole relief for faculty, before turning to litigation sanctions. Because the Board agent had not yet addressed the litigation sanctions the District owes, the administrative determination (AD) was an interlocutory order rather than a final one. (See Morgan Hill Unified School District (2016) PERB Order No. Ad-443, pp. 4-5.) Although the District did not seek permission to file an interlocutory appeal as required in PERB Regulation 32200, the Board resolved the appeal nonetheless because the AD wrongly stated that the parties could file an appeal under PERB Regulation 32360. (p. 3, fn. 3.) more or view all topics or full text. |
49 | 48 | 08/19/24 |
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