City & County of S.F. v. Public Employment Relations Bd.

CourtCalifornia Court of Appeal
DecidedJune 22, 2026
DocketA173302
StatusPublished

This text of City & County of S.F. v. Public Employment Relations Bd. (City & County of S.F. v. Public Employment Relations Bd.) 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
City & County of S.F. v. Public Employment Relations Bd., (Cal. Ct. App. 2026).

Opinion

Filed 6/22/26 CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FIVE

CITY AND COUNTY OF SAN FRANCISCO, A173302 Petitioner, (Public Employment Relations v. Board Decision No. 2958-M PUBLIC EMPLOYMENT Case No. SF-CE-2157-M) RELATIONS BOARD, Respondent; MUNICIPAL ATTORNEYS ASSOCIATION OF SAN FRANCSICO, A Real Party in Interest.

The Meyers-Milias-Brown Act (MMBA) (Gov. Code, §§ 3500– 3511) governs “disputes regarding wages, hours, and other terms and conditions of employment between public employers and public” unions. (Id., § 3500.) Among other things, the MMBA establishes procedures for resolving those disputes if the public employer and union reach an impasse during negotiations. (Gov. Code, §§ 3505.4 & 3505.5.) Under those impasse resolution procedures, a factfinding panel may “recommend terms of settlement . . . .” (Id., § 3505.5, subd. (a).) But that recommendation is “advisory only.” (Ibid.) Thus, notwithstanding the panel’s recommendation, the public employer “may, after holding a

1 public hearing regarding the impasse, implement its last, best, and final offer.” (Id., § 3505.7.) The MMBA also provides an alternative for charter cities or counties. Those cities and counties may adopt their own impasse resolution procedures in lieu of the MMBA’s procedures, so long as their procedures include “a process for binding arbitration.” (Gov. Code, § 3505.5, subd. (e).) Petitioner City and County of San Francisco (City), a charter city and county, has opted for this alternative. Under the Charter of the City and County of San Francisco (Charter), certain labor disputes are eligible for interest arbitration if the City and its employee union reach an impasse. If the dispute is eligible for and submitted to arbitration, then the arbitrators must choose between the “last offer[s] of settlement on each of the remaining issues in dispute” between the City and its union. (Charter, § A8.409-4.) 1 Once the arbitrators make that choice, their decision is “final and binding,” and the City has no other recourse. (Ibid.) Real party in interest Municipal Attorneys Association of San Francisco (MAA) represents City employees who are “exempt from competitive civil service selection, appointment, and removal procedures” under the Charter. (§ 10.104.) As “exempt appointments” (S.F. Civ. Service Com. Rules, rule 114, § 114.25), 2 MAA members are at-will employees who “serve at the pleasure of the appointing authority” and may be terminated without cause (§ 10.104). During its

1 Unless otherwise indicated, all further statutory references are

to the Charter. 2 All further rule references are to the San Francisco Civil Service

Commission Rules.

2 most recent labor negotiations with the City, the MAA made two proposals that would have altered the at-will status of its members. The first would have limited the City’s ability to discharge MAA members by requiring “just cause” for any “discipline,” including “terminations (discharges).” The second would have required the City to lay off MAA members in order of their seniority. After the City refused to submit these proposals to binding interest arbitration, the MAA filed an unfair practice charge with respondent Public Employment Relations Board (PERB). PERB found that the MAA’s proposals were eligible for arbitration under the impasse resolution provisions of the Charter and held that the City engaged in bad faith bargaining by refusing to submit those proposals to arbitration. We, however, find that the MAA’s proposals are not eligible for arbitration under the Charter. We therefore vacate PERB’s decision to the contrary. BACKGROUND A. The MAA is the exclusive representative of roughly 500 attorneys employed by the City. Those attorneys are currently “at-will” employees with no “job protections.” The MAA and the City entered into a memorandum of understanding (MOU), effective July 1, 2022 through June 30, 2024. During negotiations over that MOU, the MAA proposed adding certain job protections, including binding arbitration for any discipline of its members. The City, however, rejected that proposal, claiming that it conflicted with the Charter. According to the MAA, the City refused to negotiate over any proposals that would alter the at-will status of its

3 attorneys, but the City denied this. The parties, however, agreed that the MAA’s proposal was never submitted to interest arbitration and that the MAA did not file an unfair practice charge with PERB. In December 2023, the MAA initiated negotiations over the next MOU. During these negotiations, the MAA, which had recently affiliated with “Teamsters Local 856,” prioritized the addition of job protections due to the recent history of “mass political firings” at the San Francisco District Attorney’s Office. On February 12, 2024, the MAA sent its first proposal to the City. Proposal 1, titled “Attorney Discipline,” would have altered the at-will status of the City’s attorneys by establishing that “[a]ll discipline shall be for just cause and progressive.” (Italics added.) Under the proposal, “ ‘discipline’ means and includes demotions, suspensions, or terminations (discharges).” Proposal 1 further stated that the City “shall use progressive discipline in addressing the behavior of an attorney” but may “skip one or all levels of progressive discipline, if necessary.” Finally, the proposal provided that “[a]ll attorney discipline will be reviewable, appealable and subject to binding arbitration . . . .” Over the rest of February and March 2024, the MAA submitted additional proposals to the City, including Proposal 14. Under Proposal 14, titled “Reduction in Force and Layoff,” “[w]hen a reduction in force becomes necessary, layoff and demotions in lieu of layoff shall be accomplished in inverse order of total paid . . . continuous service in the classification(s) in the current department of the effected attorney . . . .”

4 (Italics added.) Like Proposal 1, Proposal 14 would have limited the ability of the City to discharge its attorneys without cause. 3 The City never made a counteroffer to the MAA’s just cause proposals. Instead, the chief negotiator for the City wrote in an e-mail to the MAA dated March 11, 2024: “The City has not taken the position that Proposal #1 is outside the scope of bargaining under the MMBA, nor has the City refused to bargain Proposal #1. Instead, as the City has done any time [the] MAA has raised just cause rights in the past, and as is permitted under the MMBA, the City has rejected Proposal #1 and proposed instead that the parties maintain the status quo.” According to the City’s negotiator, “[s]ection 10.104 reflects the express will of the voters that attorneys employed by the City be at[-]will,” and “the City will not submit any proposal that would alter the attorneys’ exempt/at-will status to the impasse resolution procedures under . . . [s]ection A8.409-4.” In subsequent negotiation sessions, the City repeatedly rejected the MAA’s just cause proposals. The City, however, agreed to mediate and bargain over those proposals, explaining that they would be subject to factfinding under the impasse resolution procedures of the MMBA. In doing so, the City took the position that any just cause protections would conflict with the Charter and that the MAA’s just cause proposals were not eligible for binding interest arbitration under the Charter. The MAA disagreed, arguing that its proposals were eligible for arbitration.

3 We refer to Proposals 1 and 14 as the “just cause proposals.”

They are the only MAA proposals at issue here.

5 On April 25, 2024, the City and MAA reached a tentative agreement. That agreement included a provision for reopening negotiations over the MAA’s just cause proposals if PERB ruled in favor of the MAA on its unfair practice charge.

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