San Ramon Valley Unified School District (PERB I046E)

STATE OF CALIFORNIA
DECISION OF 	THE
PUBLIC 	EMPLOYMENT 	RELATIONS 	BOARD
SAN 	RAMON VALLEY UNIFIED SCHOOL
DISTRICT,
Charging 	Party,
SAN 	RAMON VALLEY EDUCATION
ASSOCIATION, CTA/NEA,
Respondent.
Case No. 	SF-CO-262
PERB Order 	No. 	IR-46
October 12, 	1984
Appearances; 	Gregory J. 	Dannis, Attorney 	(Breon, 	Galgani,
Godino, 	and O'Donnell) 	for 	the San Ramon Valley Unified School
District; 	Kirsten L. 	Zerger, 	Attorney for 	the San Ramon Valley
Education Association, 	CTA/NEA.
Before Hesse, Chairperson; Jaeger, Morgenstern, and Burt,
Members.
DECISION
JAEGER, 	Member: 	This case is before 	the Public Employment
Relations Board 	(PERB or Board) 	on a request for 	injunctive
relief 	filed by 	the 	San 	Ramon Valley 	Unified 	School 	District
(District) 	against 	the San Ramon Valley Education Association,
CTA/NEA 	(Association). 	The District filed an unfair 	practice
charge alleging 	that, 	by engaging 	in certain strike activity,
the Association violated section 3543.6(a), 	(c) 	and 	(d) 	of the
Educational Employment Relations Act 	(EERA or Act).*
1The 	EERA 	is 	codified 	at Government Code 	section 	3540 	et
seq. 	Unless otherwise 	indicated, 	all references are to 	the
Government Code.
Section 3543.6 	provides, 	in relevant part:

It 	shall be unlawful 	for 	an employee
organization 	to:
(a) 	Cause or attempt to cause a public
school employer 	to violate 	Section 3543.5,
(c) 	Refuse or 	fail to meet and negotiate 	in
good 	faith with a public 	school employer 	of
any of 	the employees of which 	it 	is 	the
exclusive 	representative.
(d) 	Refuse to participate 	in good faith 	in
the 	impasse procedure 	set forth 	in Article 	9
(commencing with Section 354 8 ) .
PERB's 	authority 	to seek 	injunctive 	relief 	is governed 	by
section 3541.3(j). 	That section empowers the Board:
To 	bring 	an action 	in a court 	of competent
jurisdiction to enforce any of 	its 	orders,
decisions, 	or rulings or to enforce the
refusal to obey a subpoena. 	Upon 	issuance
of 	a 	complaint charging 	that any person has
engaged 	in or 	is engaging 	in an unfair
practice, 	the board may petition the court
for 	appropriate 	temporary 	relief 	or
restraining 	order.
An 	injunction 	is proper 	in circumstances mandating
extraordinary relief. 	Thus, 	the charge must not only state a
prima 	facie 	violation of the Act, 	but 	the Board must determine
that 	(1) 	there 	is 	"reasonable cause" 	to believe that an unfair
practice has been committed, 	and 	(2) 	that the relief sought 	is
"just and 	proper." 	Public 	Employment 	Relations 	Board 	v.
Modesto City Schools 	(1982) 	136 Cal.App.3d 	881, 	895.

FACTS
The parties' 	collective bargaining 	agreement expired on
June 30, 	1983. 	Thereafter, 	the parties engaged in
negotiations, 	but were unable to reach agreement for 	the
1983-84 school year. 	On December 11, 	1983, 	the parties jointly
requested 	a declaration of 	impasse 	and 	the 	appointment of 	a
mediator. 	PERB granted 	this request, 	and the parties
participated 	in mediation sessions 	through April 	1, 	1984.
On March 23 and again on March 29, 	1984, 	during 	the
pendency of mediation, 	the Association engaged 	in one-day
strikes. 	As 	a result of this conduct, 	the District 	filed an
unfair 	practice 	charge and a 	request 	for 	injunctive 	relief
(SF-CO-230). 	The Board granted 	the District's 	request and on
April 	4, 	1984 	obtained 	a 	temporary 	restraining 	order 	that
enjoined 	the Association 	from engaging 	in 	strike 	activity prior
to completion of 	the 	statutory 	impasse 	procedure.
On May 7 and 11, 	1984, 	the parties participated in
factfinding. 	The 	factfinding 	report was 	issued on May 24,
1984. 	Both parties agreed to resume negotiations. 	Thereafter,
the parties engaged 	in nine 	negotiating 	sessions, 	but could not
reach 	agreement.
The District 	submitted 	its 	"last best offer" 	to 	the
Association on July 10, 	1984, 	and 	indicated that 	the governing
board was willing 	to adopt the 	factfinder's 	report 	in 	full. 	On
July 17, 	1984, 	the governing board adopted 	the last best offer,

and unilaterally 	implemented provisions 	of 	that 	offer. 	At 	the
same 	meeting, 	the governing 	board 	sunshined 	its 	initial
proposal for 	the 	1984-85 	school year.
On August 7, 	1984, 	the District sunshined the Association's
initial proposal 	for 	the 	1984-85 	school year, 	but 	insisted 	that
it 	reserved 	the 	right 	to negotiate 	outstanding 	1983-84 	issues
which 	had 	been 	unilaterally 	implemented 	by 	the 	District.
On August 31, 	1984, 	the parties resumed negotiations, 	in
which 	it appears 	that both 	1983-84 	and 	1984-85 	bargaining
subjects 	were discussed. 	These negotiations 	have continued
until 	the present time.
On September 	11 and 17, 	1984, 	during the pendency of
negotiations, 	the Association engaged 	in two unannounced
one-day 	strikes.
On September 	19, 	1984, 	the District filed unfair practice
charge number 	SF-CO-262 	and a 	request 	for 	injunctive 	relief,
alleging, 	inter alia, 	that the work stoppages of September 	11
and 	17, 	1984 constituted a violation of 	the Association's duty
to negotiate 	in good faith. 	Specifically, 	the District alleged
that 	the work 	stoppages were 	unlawful 	economic 	strikes 	and,
because 	they were 	unannounced 	and of 	an 	intermittent nature,
constituted unlawful pressure 	tactics. 	The District
subsequently withdrew 	its 	injunction 	request 	pending 	further
mediation between 	the parties.
After 	the September 	17, 	1984 	strike, 	the parties resumed
negotiations, 	but made no progress. 	On September 28, 	1984, 	the

parties, 	with the assistance of PERB, 	agreed to the appointment
of a 	special mediator. 	Since 	the Board had not declared 	that
an 	impasse had been reached 	in negotiations, 	these mediation
sessions 	were 	informal and outside 	the 	statutory mediation
procedure. 	The parties 	engaged 	in 	these 	informal mediation
sessions until October 	5, 	1984, 	when the Association allegedly
refused 	to participate 	in mediation any longer.
On October 	5, 	1984, 	the Association again engaged in an
unannounced 	one-day strike. 	The District 	amended charge 	number
SF-CO-262 	to allege 	that 	the October 	5 	strike was unlawful. 	It
also 	reactivated 	its 	request 	for 	injunctive 	relief.
On October 	8, 	1984, 	the General Counsel determined 	that
charge number SF-CO-262, 	as amended, 	stated a prima facie
violation, 	and a complaint was 	issued.
Throughout 	this period, 	the Association has 	filed a 	series
of unfair 	practice charges against 	the District, 	all of which
are now pending 	before 	the Board.
In charge number SF-CE-881, 	filed on March 12, 	1984 and
amended on August 20, 	1984, 	the Association alleges that the
District engaged 	in 	the 	following 	unfair 	practices:
1. 	The District created 	and 	negotiated with an 	"advisory
committee" 	consisting of representatives of various 	schools,
thereby 	unlawfully bypassing 	the 	exclusive 	representative.
2. 	On January 24, 	1984, 	the District Superintendent sent a
memorandum 	to 	District 	employees 	which 	constituted 	an 	attempt
to bypass 	the Association 	and 	negotiate 	directly with 	employees.

3. 	On February 10, 	1984, 	the District issued a memorandum
to District 	employees which contained 	an offer 	that had not
been made 	to Association 	negotiators 	and was 	not made 	to 	them
until 11 days 	later.
4. 	The District required 	teachers 	to read District
propaganda concerning 	its position in negotiations, 	and 	implied
that 	they would be disciplined 	for 	failing 	to do 	so.
5. 	The District engaged 	in regressive bargaining and
condition bargaining, 	and 	it unlawfully stated 	in negotiations
that 	it was 	bound 	to pay 	noncertificated 	employees 	the 	same
wage 	increases 	granted 	to certificated 	employees.
6. 	A member 	of 	the 	San Ramon Valley 	School 	Board published
a 	statement 	in 	the 	local 	newspaper 	threatening 	that 	the
District would 	refuse 	to 	enter 	into 	an 	agreement with 	the
Association 	unless 	the Association ceased 	to exercise 	its
statutory right 	to 	file unfair 	practice 	charges 	against 	it.
7. 	The District unilaterally 	implemented 	its mentor
teacher 	program proposal 	during 	post-factfinding 	negotiations
when 	the 	parties 	were making progress 	towards 	reaching
settlement of 	that 	issue.
8. 	The District violated 	its duty to negotiate 	in good
faith by unilaterally 	implementing 	its 	last 	best offer 	on
July 17, 	1984. 	The Association alleges that, due to the past
unfair practices committed by the District, 	no legal 	impasse
had occurred. 	In 	addition, 	the Association alleges 	that 	the

District 	unilaterally adopted policies 	that, 	by statute,
required 	the mutual consent of 	the parties 	(i.e., 	binding
arbitration, 	union security, 	and discipline short of
dismissal). 	Moreover, 	the District sought to negotiate with
the Association 	through 	an 	individual who was not on 	the
Association 	bargaining 	team and was 	associated with 	a 	rival
employee 	organization.
In charge number SF-CE-950, 	filed on September 	14, 	1984,
the Association alleges 	that 	the District engaged 	in 	the
following 	unfair practices 	since June 	1984:
1. 	On June 14, 	1984, 	the Association and the District
reached 	a 	tentative 	agreement, 	which was 	then reneged upon by
the District.
2. 	Since July 17, 	1984, 	when the District unilaterally
adopted 	its last best offer, 	it has 	refused to negotiate
concerning 	1983-84 	salary, 	health and welfare benefits,
transfers, class size, and leaves of absence.
3. 	Since July 17, 	1984, 	the District has engaged in
various acts of surface bargaining, 	condition bargaining, 	and
regressive 	bargaining 	which 	demonstrate 	subjective 	bad 	faith 	on
the part of 	the District.
4. 	On three separate occasions, 	the District prepared and
distributed to 	students 	letters which were 	to be 	taken home 	to
their 	parents, 	while 	the Association 	is precluded 	from using
the 	same method of 	communicating 	with parents.

5. 	On August 1 and 7, 	1984, 	letters from Board of
Education member McCoy appeared 	in 	the 	"Valley Times" 	blaming
the Association and 	its negotiator. 	Chuck Davies, 	for 	the
stalemate 	in negotiations.
6. 	On August 6, 	1984, 	the District distributed a flyer 	and
leaflet 	to unit members denigrating 	the Association's 	choice 	of
Chuck Davies 	as 	its chief negotiator.
7. 	On August 15, 	1984, 	District negotiator Keith Breon
terminated 	an 	informal mediation 	session prematurely 	and
without notice.
8. 	On September 	7, 	1984, 	the District distributed a flyer
to 	unit 	employees 	announcing 	a new offer 	which was more
generous 	than 	that 	offered 	to 	the Association's 	bargaining 	team.
9. 	On September 	13, 	1984, 	District negotiator 	Breon left
in 	the midst of negotiations without giving notice 	to 	the
Association. 	The remaining 	District negotiators 	refused 	to
negotiate 	until 	Breon 	returned.
10. 	The District unilaterally changed 	its policy
concerning 	the 	terms 	on which 	a 	teacher 	could 	be 	advanced 	on
the 	salary schedule.
Complaints 	have 	been 	issued 	on both charge number 	SF-CE-881
and SF-CE-950.
It 	is 	undisputed 	that 	the multiple work stoppages 	thus 	far
have 	occurred with 	little 	or 	no notice 	being given 	to 	the
District. 	As 	a 	result of the 	surprise nature of 	these 	strikes,

the 	District has 	had difficulty obtaining 	a 	sufficient number
of 	substitute 	instructors 	to carry on 	its 	educational mission.
The District has also suffered a decline 	in attendance on
strike days 	attributable 	to 	the 	confusing 	atmosphere caused 	by
the 	unannounced work 	stoppages.
DISCUSSION
The District's 	primary 	argument 	is 	that an 	economic 	strike
occurring prior 	to 	the completion of 	the 	impasse 	procedure
constitutes 	a refusal 	to negotiate 	in good 	faith. 	It contends
that, 	since 	the parties are presently negotiating over 	"new"
bargaining 	issues 	for 	the 1984-85 	school year, 	an entirely new
round of negotiations has begun and 	it 	is, 	therefore, 	unlawful
for 	the Association 	to engage 	in economic 	strikes.
The Association claims 	that 	its 	one-day 	strikes 	are 	unfair
practice strikes. 	In addition, 	it argues that, 	even if its
strikes are considered to be economic 	strikes, 	they occurred
after 	completion of 	the 	statutory 	impasse procedure. 	Such
post-impasse strikes, 	it contends, 	are protected under 	the Act.
In Modesto City Schools 	(3/8/83) 	PERB Decision No. 	291, 	the
Board dealt 	extensively with 	the 	legality of 	strikes 	prior 	to
the completion of the statutory 	impasse procedure. 	The Board
held 	that work 	stoppages which occur 	prior 	to 	the 	exhaustion of
the 	statutory 	impasse procedure create a 	rebuttable presumption
that such action 	is an unlawful 	tactic 	in violation of 	the
employee 	organization's 	duty 	to 	negotiate 	in good 	faith.

However, 	the presumption of unlawfulness may be rebutted by
evidence 	that 	the 	strike was 	provoked by 	the 	employer's 	unfair
practices. 	In such circumstances, 	the strike would be
protected activity under 	the Act. 	See 	also Fresno Unified
School District 	(4/30/82) 	PERB Decision No. 	208; 	Westminster
School District 	(12/31/82) 	PERB Decision No. 	277; 	Rio Hondo
Community College District 	(3/8/83) 	PERB Decision No. 	292.
The 	Board has 	not yet addressed 	the 	legality of 	strikes
which 	occur 	after 	exhaustion 	of 	the 	statutory 	impasse
procedure. 	Nor has 	the Board addressed 	the question, 	posed 	in
this case, 	of whether 	and under what circumstances 	the parties
can be considered 	to have 	returned 	to 	the Modesto 	"pre-impasse"
stage 	once 	they have 	completed 	the 	statutory 	impasse procedure,
failed to reach agreement, 	and management has 	unilaterally
implemented 	its 	last best offer.
There 	is no question, 	however, 	that a strike provoked by an
employer's 	unfair 	labor 	practices would be 	protected 	at 	any
time at which 	it occurs 	in the bargaining process as 	long as
the 	striking 	employee 	organization has 	not 	failed 	to
participate 	in good 	faith 	in the 	statutory 	impasse procedure.
Modesto City Schools, 	supra, at p. 	64. 	In this case, 	the
Association 	has 	filed numerous 	unfair 	practice 	charges 	against
the District, 	and claims that 	its strike activity was, 	at least
in part, 	motivated by the District's 	unfair 	labor practices.
The 	District disputes 	this claim, 	asserting 	that 	the
10

Association's 	strike 	activity was motivated purely by 	its
desire 	to gain concessions 	at 	the 	bargaining 	table.
Given 	the complicated factual record before us, 	the
contradictory claims of 	the parties, 	the 	unsettled 	state of 	the
law, 	and 	the absence of a 	full evidentiary hearing, 	we
determine 	that 	the District has not demonstrated 	reasonable
cause 	to believe 	that the Association has committed an unfair
practice by engaging 	in these strikes. 	Since 	the requisite
present degree of certainty 	that 	the 	strikes violate 	the Act 	is
lacking, 	it would not be just and proper 	to enjoin them. 	Thus,
while 	the 	District's 	unfair 	practice charge 	states 	a prima
facie violation, 	its 	injunctive relief request does not satisfy
the higher 	"reasonable cause" 	standard upon which 	the decision
to seek 	extraordinary 	relief must be 	based. 	PERB v. 	Modesto
City Schools, supra.
However, 	even where the objective of the strike 	is lawful,
the means used to carry out 	the strike may be unlawful. 	Thus,
it has 	long been held under 	the National Labor 	Relations Act
(NLRA) 	that sit-down strikes, 	certain wildcat strikes,
3 The NLRA 	is codified at 29 	U.S.C. 	151 	et seq. 	It 	is
appropriate 	for 	the 	Board 	to 	take guidance 	from federal 	labor
law precedent 	when 	applicable 	to public 	sector 	labor 	relations
11
, 	the question of whether 	the Modesto 	"rebuttable
presumption" 	standard would apply to 	the 	facts 	in 	this case
and, 	if so, 	whether 	the Association could meet that standard 	in
a hearing on 	the merits 	is not 	to be determined by 	the Board 	in
this 	injunctive 	relief request.

partial strikes, 	intermittent strikes, 	and slowdowns are
unprotected. 	NLRB v. 	Fansteel Metallurgical Corp. 	(1939) 	306
U.S. 	240 	[4 LRRM 515]; 	Confectionery and Tobacco Drivers v.
NLRB 	(2d Cir. 	1963) 	312 F.2d 108 	[52 LRRM 2163]; 	Valley City
Furniture Co. 	(1954) 	110 NLRB 1589 	[35 LRRM 1589] 	e n f d 	(5th
Cir. 	1956) 	230 F.2d 947 	[37 LRRM 2740]; 	NLRB v. 	Blades Mfg.
Corp. 	(8th Cir. 	1965) 	344 F.2d 	998 	[59 LRRM 2210].
issues. 	Fire Fighters Union v. 	City of Vallejo 	(1974) 	12
Cal.3d 608; 	San Diego Teachers Association v. 	Superior 	Court
(1979) 	24 Cal.3d 1.
Based on this general line of precedent, 	the District
argues 	that 	the 	intermittent nature 	of 	the 	strikes 	constitutes
an unlawful pressure 	tactic. 	While 	the 	Board has 	previously
held 	that 	slowdowns are unprotected 	(Palos Verdes Peninsula
Unified School District 	(2/26/82) 	PERB Decision No. 	195;
Modesto City Schools, 	supra), 	it has not directly considered
the question of whether partial or 	intermittent 	strikes 	are
unlawful. 	However, 	the NLRB and federal courts have condemned
such work 	stoppages as unlawful pressure 	tactics 	in
circumstances 	where 	it 	is 	found 	that 	they represent an attempt
by employees to work and strike at 	the same time. 	Thus,
intermittent 	or 	partial 	strikes 	are 	to be distinguished 	from
strikes of short duration, 	where employees are not attempting
to work and strike at the same 	time. 	Under 	the NLRA, 	strikes
of short duration are presumptively protected. 	See Morris, 	The
12

Developing Labor Law, 	2d Ed., at pp. 	1016-1018; 	NLRB v. 	Blades
Mfg. Corp., 	supra; 	NLRB v. 	Robinson Industries 	(9th Cir. 	1976)
560 	F.2d 	396 	[93 LRRM 2529]; 	Downslope Industries 	(1979) 	246
NLRB 948 	[103 LRRM 1041]; 	NLRB v. 	Lasaponara & Sons, Inc. 	(2d
Cir. 	1976) 	541 	F.2d 	992 	[93 LRRM 2314].
Because of 	the unsettled state of 	the 	law in 	this area as
well as 	the 	lack 	of 	record 	evidence 	only available 	through 	an
evidentiary hearing, 	we do not find 	that 	there 	is 	reasonable
cause warranting extraordinary 	relief. 	Nevertheless, 	we find
that such conduct states 	a prima 	facie violation of 	the Act,
and 	should proceed 	to a 	hearing.
Next, 	the District argues that 	the surprise nature of 	the
strikes 	constitutes 	an unlawful pressure 	tactic 	warranting
injunctive relief. 	We agree.
In 	the private sector, 	with the exception of health care
institutions, 	there 	is generally no requirement 	that employee
organizations provide notice 	to an employer 	of 	their 	intention
to engage 	in a work stoppage. 	However, 	section 8(g) 	of 	the
NLRA 	requires 	employee 	organizations 	which 	represent 	employees
in 	the health care 	industry to provide 	10 days' notice prior 	to
engaging 	in any "strike, 	picketing, 	or other concerted refusal
to work." 	Congress 	amended 	the NLRA to require prior 	notice 	of
impending 	strike 	activity 	in 	the health care 	industry 	because
it 	recognized 	that health care 	institutions deliver 	a vital
public 	service 	and 	that 	interruptions 	of 	the delivery 	of 	health
13

care 	services 	because 	of labor 	disputes 	should be minimized.
See NLRB v. 	Rock Hill Convalescent Center 	(4th Cir. 	1978) 	585
F.2d 	700 	[99 LRRM 3157]; 	Kapiolani Hospital v. 	NLRB 	(9th Cir.
1978) 	581 F.2d 230 	[99 LRRM 2809]; 	NLRB v. 	Long Beach Youth
Center 	(9th Cir. 	1979) 	591 F.2d 1276 	[101 LRRM 2501];
Montefiori Hospital and Medical Center 	(2d Cir. 	1980) 	621 F.2d
510 	[104 LRRM 2160]; 	East Chicago Rehabilitation Center v. 	NLRB
(7th Cir. 	1983) 	710 	F.2d 	397 	[113 	LRRM 3241].
We 	believe 	that 	there 	is a 	significant public 	interest 	at
stake 	in 	ensuring minimal disruption 	to 	the delivery 	of
educational services as a result of labor 	disputes. 	As 	the
Supreme 	Court noted 	in 	San Diego 	Teachers Association 	v.
Superior Court, supra, at p. 11:
PERB's 	responsibility 	for 	administering 	the
EERA requires 	that 	it use 	its power 	to 	seek
judicial 	relief 	in ways 	that will 	further
the public 	interest 	in maintaining 	the
continuity 	and 	quality 	of 	educational
services.
Public 	school employers have a 	right 	to try 	to 	keep
educational 	institutions 	functioning during work 	stoppages. 	The
lack 	of 	adequate 	time 	to 	inform parents 	of 	impending 	work
stoppages 	and 	to obtain substitute personnel will 	greatly hinder
such efforts. 	Moreover, 	when parents have no advance
notification of a strike, 	they cannot 	reasonably determine
whether 	their 	minor 	children can 	safely be 	sent 	to 	school 	and
cannot make 	alternative arrangements 	for 	their 	care 	during 	school
hours 	should 	they so desire.
14

Thus, 	we 	find there 	is reasonable cause 	to believe 	that a
"surprise" strike, 	that is, 	one which occurs without adequate
notice 	to the employer, 	would constitute an unlawful pressure
tactic 	in breach of 	the 	employee 	organization's 	duty 	to 	negotiate
in good faith and, 	therefore, 	in violation of section
3543.6(c).4
Accordingly, 	we shall grant the District's 	request for
injunctive 	relief for 	the 	limited purpose 	of 	requiring 	the
Association 	to give adequate notice prior 	to engaging 	in a work
stoppage.
At this juncture, 	we are unable to determine what, 	as a
matter of law, 	would constitute 	"sufficient" 	notice. 	However,
after 	weighing 	declarations 	submitted 	by 	the 	District 	and 	the
Association's response, 	we feel that 60 hours would, 	on 	the facts
of this case alone, 	provide sufficient notice to the District.
For 	the 	foregoing reasons, 	and based on 	the Board's broad
statutory 	authority 	to 	fashion appropriate 	remedies,5 we 	find
5Section 	3541.5(c) 	provides:
The board shall have 	the power 	to 	issue 	a
decision and order 	directing 	an offending
party to cease and desist 	from 	the 	unfair
practice and 	to 	take 	such 	affirmative
action, 	including but not limited to 	the
reinstatement of employees 	with 	or 	without
back pay, 	as will effectuate 	the policies of
this chapter.
15
need not, 	at this juncture, 	reach the question of
whether 	there 	are circumstances 	in which 	a 	strike 	without
notice would 	be 	justified.

that 	in 	this 	case 	it would best serve 	the purposes of 	the Act 	to
seek 	injunctive 	relief requiring 	the Association 	to provide
adequate 	notice 	to 	the employer 	of 	its 	intention to engage 	in
work 	stoppages. 	As 	the California 	Supreme Court 	stressed 	in 	San
Diego Teachers Association v. 	Superior Court, 	supra, 	at p. 	13,
"the EERA gives PERB discretion to withhold, 	as well as pursue,
the various remedies at its disposal." 	In this case, 	it is
clear 	that it would 	best promote 	the purposes of 	the Act 	to
exercise 	our 	injunctive 	relief power 	in 	this 	limited 	fashion
until we are able, 	at a later date, 	to untangle 	the conflicting
claims of the parties.
ORDER 6
Based 	on 	the 	foregoing 	facts 	and 	the 	entire 	record 	in 	this
matter, 	the Public Employment 	Relations Board hereby ORDERS 	that
the General Counsel 	seek 	injunctive 	relief against 	the 	San Ramon
Valley Education Association, 	CTA/NEA requiring 	it to give
adequate 	notice 	to 	the San Ramon Valley Unified School District
before engaging 	in a work 	stoppage.
Chairperson Hesse 	and Members Morgenstern 	and Burt 	joined 	in
this Decision.
This 	Decision 	and Order is 	a memorialization of 	the
determination 	reached by 	the Board 	in 	its 	deliberations 	on
October 7, 1984.
16