PERB Decision No. 0342EA•California School Employees Association (Dyer) (PERB 0342EA)
California School Employees Association (Dyer) (PERB 0342EA)
PERB Decision No. 0342EACalperb22.05.1984
Gesamter Gesetzestext
STATE OF CALIFORNIA DECISION OF THE PUBLIC EMPLOYMENT RELATIONS BOARD THERESE M. DYER, Charging Party, v. CALIFORNIA SCHOOL EMPLOYEES ASSOCIATION, Respondent. } ) ) ) ) ) ) ) ) ) ___________________ ) Case No. SF-CO-180 Request for Reconsideration PERB Decision No. 342 PERB Decision No. 342a May 22, 1984 Appearances: John F. Henning, Attorney (Henning, Walsh & Ritchie)for the Charging Party. Before Hesse, Chairperson; Jaeger and Morgenstern, Members. DECISION JAEGER, Member: The Public Employment Relations Board (PERB or Board), having duly considered Therese M. Dyer's request for reconsideration, hereby denies that request. DISCUSSION Therese M. Dyer requests reconsideration of PERB Decision No. 342, in which the Board affirmed a Regional Attorney's dismissal of her unfair practice charge alleging a breach of the duty of fair representation by the California School Employees Association (CSEA).l The gravamen of the lpERB rules are codified at California AdministrativeCode, title 8, section 31001 et seq. PERB rule 32410(a), which governs reconsideration requests, provides: Any party to a decision of the Board itself may, because of extraordinary circumstances,
file a request to reconsider the decision within 20 days following the date of service of the decision •••• The grounds for requesting reconsideration are limited to claims that the decision of the Board itself contains prejudicial errors of fact, or newly discovered evidence or law which was not previously available and could not have been discovered with the exercise of reasonable diligence. charge was CSEA's failure to appeal a Superior Court decision dismissing a civil suit filed on Dyer's behalf against the Laguna Salada Union School District (District). The Court had concluded that the District's alleged violation of the Education Code could be an unfair labor practice over which the Board has initial exclusive jurisdiction. The Board found no basis for concluding that CSEA's decision not to appeal the Court decision was arbitrary, discriminatory or made in bad faith. Dyer bases her request for reconsideration on a claimed change in the legal standard of the duty of fair representation, citing Dutrisac 'v. Caterpillar Tractor Co. (9th Cir. 1983) F. 2d [113 LRRM 3532]. Dyer contends that, under Dutrisac, supra, the "arbitrary, discriminatory, or bad faith" standard articulated in Vaca v. Sipes (1967) 386 U.S. 171 and followed by PERB in the underlying Decision, has been replaced by a standard of "negligence." CSEA did not respond to the request. 2
Dyer's interpretation of Dutrisac, supra, gives it a meaning beyond that intended by the 9th Circuit. Rather than replacing the standard for adjudicating alleged violations of the duty of fair representation enunciated by the U.S. Supreme Court in Vaca, Dutrisac merely clarified the term "arbitrary," one part of the Vaca standard.2 Thus, the Court found that the negligent, "unexplained and unexcused" failure to perform a "ministerial act," such as failing to file a timely grievance, could support a finding of a breach of the duty of fair representation. The Court distinguished such cases from those in which the union's "failure" was essentially the consequence of a judgmental decision. The Court noted as three common examples of such cases those involving the union's evaluation of merits of a grievance, its interpretation of the collective bargaining agreement, and its decision as to the presentation of a grievance. Here, CSEA's "failure" to appeal the Superior Court decision was the consequence of a conscious decision based on the exercise of judgment. That decision was clearly not based on an unexcused and unexplained failure to perform a ministerial act. 2we limit this decision to the determination that the Dutrisac decision does not justify granting Dyer's request for ·reconsideration. In so ruling, we do not imply either the adoption or rejection of the Court's analysis. 3
In addition, Dyer raises a second theory by which CSEA allegedly breached its duty of fair representation. Specifically, Dyer argues that CSEA negligently advised her that the proper forum for adjudicating her claim against the District was in superior court and not before PERB. Dyer's argument is without merit. CSEA's decision to pursue Dyer's claim through a suit in superior court while a charge was pending before PERB,3 and the Court's subsequent decision to defer to PERB's initial exclusive jurisdiction, does not, in and of itself, state a prima facie violation of the duty of fair representation. Quite the contrary. California courts, not PERB, are empowered to enforce the Education Code, and CSEA's attempt to obtain relief through the judicial system of Dyer's claim that the District violated the Education Code by unlawfully transferring her was an appropriate exercise of judgment. That the court might dismiss the case on administrative preemption grounds was a calculated 3The complicated ~rocedural history of this case is noted in the underlying Decision. Briefly, Dyer had filed a PERB charge against the District (SF-CE-319) in October 1979, prior to CSEA's filing suit in San Mateo County Superior Court in July 1980. Dyer's private attorney withdrew that charge with prejudice in November 1981, prior to the Superior Court dismissal of her suit in February 1982. In July 1982, a PERB hearing officer denied Dyer's request to reopen case SF-CE-319 because it had been withdrawn with prejudice. Dyer did notappeal this determination to the Board itself. 4
risk concerning an issue where there is emerging precedent.4 Taking that risk certainly does not evidence a negligent failure to perform a ministerial act, let alone demonstrate arbitrary, discriminatory, or bad faith conduct. Accordingly, Dyer's request for reconsideration is denied. ORDER The Board, finding no grounds for reconsideration of its Decision No. 342, DENIES petitioner's request therefor. Chairperson Hesse and Member Morgenstern joined in this Decision. 4see, e.g., El Rancho Unified School District v. PERB (1983) 33 Cal.3d 946; Link v. Antioch School District7T983) 124 Cal.App.3d 43; FresrioUnified School District v. National Education Assn. (1981) 125 Cal.App.3d 259; San Diego TeachersAssn. v. Superior Court (1979) 24 Cal.3d l. 5
Was bedeutet dieser Text für Ihre Situation?
Kostenlose und unverbindliche Beratung
Schildern Sie uns Ihre Situation. Unser Team meldet sich per E-Mail bei Ihnen für Ihre Beratung.
Setzen Sie Ihre Recherche in ChatGPT oder Claude fort
Verbinden Sie Omnilex, um den Rechtskorpus über Ihren KI-Assistenten zu durchsuchen.