Amalgamated Transit Union etc. v. Santa Clara Valley Transp. Auth. CA6

CourtCalifornia Court of Appeal
DecidedDecember 12, 2025
DocketH052725
StatusUnpublished

This text of Amalgamated Transit Union etc. v. Santa Clara Valley Transp. Auth. CA6 (Amalgamated Transit Union etc. v. Santa Clara Valley Transp. Auth. CA6) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Amalgamated Transit Union etc. v. Santa Clara Valley Transp. Auth. CA6, (Cal. Ct. App. 2025).

Opinion

Filed 12/12/25 Amalgamated Transit Union etc. v. Santa Clara Valley Transp. Auth. CA6

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SIXTH APPELLATE DISTRICT

AMALGAMATED TRANSIT H052725 UNION LOCAL 265, (Santa Clara County Super. Ct. No. 24CV430088) Plaintiff and Appellant,

v.

SANTA CLARA VALLEY TRANSPORTATION AUTHORITY,

Defendant and Respondent.

This appeal arises from the denial of a petition to compel arbitration. Amalgamated Transit Union Local 265 (Local 265 or union) petitioned to compel arbitration of nine grievances against Santa Clara Valley Transportation Authority (VTA). The trial court found the grievances were not arbitrable under the provisions of the parties’ collective bargaining agreement. Local 265 contends the trial court erred under case precedent and California’s public policy favoring arbitration, which require courts to give broad effect to labor arbitration agreements. The union asserts the arbitrator, not the court, should in the first instance interpret any relevant limitations on or exclusions from arbitrability under the agreement. Applying the plain language of the collective bargaining agreement between the parties, we conclude the grievances in dispute are not arbitrable. We therefore affirm the denial of the petition to compel arbitration. I. FACTS AND PROCEDURAL BACKGROUND A. Collective Bargaining Agreement The collective bargaining agreement (CBA, or the agreement) between the parties is titled “agreement between AFL-CIO division 265 Amalgamated Transit Union and the Santa Clara Valley Transportation Authority, September 9, 2019 – September 8, 2022.” (Some capitalization omitted.) Section 6 of the CBA, titled “[p]robation” addresses probation for employees, defined as “a trial period during which VTA is to judge the ability, competency, fitness, and other qualifications of employees to do the work for which they are employed.” It provides that “[a]ll new employees shall be on probation immediately following their date of hire for the period of formal training and for 180 calendar days following completion of said training” and allows for extension of the probation period “by mutual agreement” of the parties under specified conditions. Section 6 further provides, “[n]ew probationary employees may be disciplined or discharged at the total discretion of VTA and such actions shall not be subject to review under any provision of this [a]greement.”1

1 Though not at issue in this appeal, the use of the adjective “[n]ew” in

this sentence appears to limit the application of the exclusionary provision to apply to “[n]ew probationary employees” as opposed to employees who are on probation because they have been promoted or transferred to a new classification. As section 6 specifies, “[a]ll new employees shall be on probation immediately following their date of hire for the period of formal training and for 180 calendar days following completion of said training,” while “[a]ll employees who are promoted or transferred to a new classification shall be on probation immediately following their date of promotion or

2 Section 19, titled “[g]rievances and [d]ispute [r]esolution” governs the grievance procedures. Section 19.1 defines a grievance, in relevant part, “as any controversy or dispute between VTA and the [u]nion concerning the interpretation or application of this labor [a]greement, excluding cases of discipline and discharge, which” are addressed in section 18. Section 19.2 states that a grievance “must be filed in writing with the designated representative of VTA or the [u]nion . . . within 30 calendar days after the occurrence or discovery of the alleged grievance,” and section 19.3 sets forth the procedures for an informal hearing and written decision. Section 19.4 provides that “[a]ll time limits may be extended in writing and for good cause by mutual agreement.” Under section 19.5, a party’s failure to adhere to the time limitations governing the grievance process “shall cause forfeiture of that party’s case.” Section 20, titled “[a]rbitration” governs arbitration, including prearbitration mediation, notice and procedure, applicable rules, and costs. If a party is dissatisfied with the written decision resulting from the grievance process, section 20.3 provides that either party may request arbitration within 90 days of receipt of the written decision or response from the informal hearing. Under section 20.2, “[a]ny grievance, or any discipline or discharge action which cannot be resolved” through the processes stated in sections 18 and 19 may be submitted to arbitration upon compliance with the conditions of section 20. B. The Subject Grievances Between January and October 2022, Local 265 filed nine individual grievances alleging violations of the CBA. For each of the nine grievances,

transfer for the period of formal training and for 180 calendar days following completion of said training.” 3 VTA held an informal hearing and rendered a written decision denying the grievance. The nine grievances are as follows: (1) grievance No. 2022-ATU-0007, filed on January 21, 2022, challenging VTA’s random video monitoring of light rail operators; (2) grievance No. 2022-ATU-0039, filed on May 6, 2022, challenging VTA’s denial of an overtime request; (3) grievance No. 2022-ATU- 0053, filed on May 16, 2022, challenging VTA’s denial of an employee’s requested work classification; (4) grievance No. 2022-ATU-0049, filed on May 20, 2022, challenging VTA’s discharge of a probationary employee; (5) grievance No. 2022-ATU-0061, filed on June 13, 2022, challenging VTA’s denial of an employee’s request for compensation; (6) grievance No. 2022- ATU-0065, filed on July 11, 2022, challenging VTA’s denial of an employee’s requested work assignment; (7) grievance No. 2022-ATU-0072, filed on July 19, 2022, challenging VTA’s denial of an employee’s requested work assignment; (8) grievance No. 2022-ATU-0084, filed on August 30, 2022, challenging VTA’s denial of an employee’s requested compensation; and (9) grievance No. 2022-ATU-0101, filed on October 14, 2022, challenging VTA’s termination of an employee from a training program. One of the nine grievances (grievance No. 2022-ATU-0049, filed on May 20, 2022, hereafter the “section 6 grievance”) arose from the discharge of a new probationary employee. According to VTA’s statement of decision after the initial hearing, the employee was discharged for failure to meet acceptable attendance standards after she failed to produce the documentation required to support her requested probation extension. As to each of the other eight grievances (hereafter, the “section 19 grievances”), VTA maintained they were filed outside of the 30-day window mandated by section 19.2, requiring a grievance to “ ‘be filed in writing . . . within 30

4 calendar days after the occurrence or discovery of the alleged grievance.’ ” (Italics omitted.) The VTA declared in denying each of those grievances that they were forfeited for untimeliness. Local 265 requested in writing to proceed to arbitration on each of the nine denied grievances, but VTA refused to proceed to arbitration. C. Petition to Compel Arbitration In January 2024, the union petitioned the trial court to compel arbitration of the nine grievances (petition). The petition alleged that at all relevant times, Local 265 complied with the grievance provisions of the CBA, but VTA refused to comply with the agreement by refusing to submit each of the grievances to an arbitrator for resolution.

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