Leek v. Washington Unified School District

124 Cal. App. 3d 43, 177 Cal. Rptr. 196, 1981 Cal. App. LEXIS 2195
CourtCalifornia Court of Appeal
DecidedSeptember 30, 1981
DocketCiv. 19665
StatusPublished
Cited by22 cases

This text of 124 Cal. App. 3d 43 (Leek v. Washington Unified School District) 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
Leek v. Washington Unified School District, 124 Cal. App. 3d 43, 177 Cal. Rptr. 196, 1981 Cal. App. LEXIS 2195 (Cal. Ct. App. 1981).

Opinions

[46]*46Opinion

CARR, J.

This is an appeal from a judgment of dismissal entered

after the trial court sustained a demurrer without leave to amend on the basis of appellants’ failure to exhaust their administrative remedies before the Public Employment Relations Board (PERB). Appellants’ primary contention is that the substantive grievances alleged in their complaint do not constitute “unfair practices” as defined by the Educational Employment Relations Act (EERA)1 and therefore lie beyond the jurisdiction of the board. More particularly at issue is the right of the exclusive representative to bargain for “organizational security” which is a clause in the collective bargaining agreement requiring all members of the bargaining unit (the public school employees in question) to become members of the association that is the exclusive bargaining representative or to pay fees to that association in an amount that does not exceed the membership dues of the association. (See Gov. Code, §§ 3540.1, subd. (i)(2), 3543.2 and 3546.)2

Respondent Washington Education Association (WEA) is the exclusive bargaining representative for a bargaining unit composed of teachers and other professional personnel, including appellants, who are employed by Washington Unified School District (WUSD). WEA is the local affiliate of California Teachers’ Association (CTA) and National Education Association (NEA) and members of WEA pay dues to CTA and NEA.

On March 2, 1979, WUSD and WEA entered into a collective bargaining agreement that requires members of the bargaining unit who are not members of WEA to become either a member or to pay a representation fee equal to the combined dues of WEA, CTA and NEA.3

[47]*47Appellants are members of the bargaining unit, but not of WEA and have refused to become a member or to pay the representation fee, contending the representation fee is excessive and a violation of their rights to freedom of expression and due process of law.

In approaching the question of exhaustion of administrative remedies under the EERA, both appellants and respondents have essentially adapted the analytical framework applied by the Supreme Court in the case of San Diego Teachers Assn. v. Superior Court (1979) 24 Cal.3d 1 [154 Cal.Rptr. 893, 593 P.2d 838]. In that case, by writ of review proceeding, the San Diego Teachers Association and its president sought annulment of contempt orders that punished them for conducting a strike against the school district in violation of a restraining order and a preliminary injunction. The strikers’ demands arose from negotiations being conducted on behalf of the district’s teachers. When the injunction was issued, both the association and the district had filed unfair practices charges against each other (§ 3541.5) with PERB, but no hearing or other action had ensued. The Supreme Court stated that “[t]he main issue is whether the restraining order and injunction are invalid because the district failed to exhaust its EERA remedies.” {Id. at p. 3.) Toward resolution of that issue the court identified three main issues: . (1) Could PERB properly determine that the strike was an unfair practice under the EERA? (2) If it made that determination could it furnish relief equivalent to that which would be provided by a trial court? (3) Did the Legislature intend that PERB would have exclusive jurisdiction over remedies against strikes that it properly could find were unfair practices?” {Id. at p. 7.)

In the instant case, appellants have modified the above paradigm as follows: (1) Could PERB properly determine that the acts complained of were unfair practices under EERA? (2) If so, could it furnish relief equivalent to that which would be provided by a trial court? (3) Did the Legislature intend that PERB would have exclusive initial jurisdiction over remedies for the acts complained of which could be found to be unfair practices? Respondents apparently have assumed the analytical framework, as suggested by appellants, is appropriate.

Section 3541.5 provides, inter alia, that “[t]he initial determination as to whether the charges of unfair practices are justified, and, if so, what remedy is necessary to effectuate the purposes of this chapter, shall be a matter within the exclusive jurisdiction of the board.” Appellants’ position is that they have not alleged charges of unfair [48]*48practices and indeed, that their grievances do not plausibly constitute unfair practices, and PERB is without jurisdiction to hear and rule upon the complaints. Both sides agree that sections 3543.5 (listing activities “unlawful” for a public school employer)4 and 3543.6 (listing activities “unlawful” for an employee organization)5 provide the basic definitions for what acts constitute unfair practices.

As formulated by the parties, the preliminary and crucial question is whether appellants have alleged plausible violations of either section 3543.5 or 3543.6. Respondents are in the position of having to make a somewhat procrustean effort to fit each of appellants’ allegations within the parameters of unlawfulness as defined by sections 3543.5 and 3543.6.

We conclude the parties have based their arguments upon the erroneous premise that PERB is limited to investigating only charges which are defined as “unlawful” under sections 3543.5 and 3543.6. The Legislature has further vested PERB with authority to investigate other alleged violations of the EERA and to make determinations with respect to such alleged violations. Section 3541.3, subdivision (i), provides that the board shall have the power and duty “[t]o investigate unfair practice charges or alleged violations of this chapter, and to take such [49]*49action and make such determinations in respect of such charges or alleged violations as the board deems necessary to effectuate the policies of this chapter.” (Italics added.) Subdivision (h) of section 3541.3 empowers the board to hold hearings, and subdivision (j) permits the board to enforce its decision or ruling by bringing an action in a court of competent jurisdiction. Subdivision (n) empowers the board “[t]o take such other action as the board deems necessary to discharge its powers and duties and otherwise to effectuate the purposes of this chapter.”

While it was appropriate for the court in San Diego Teachers Assn., supra, (24 Cal. 3d 1) to focus upon whether the strike therein could be considered an unfair practice,6 we determine the appropriate preliminary question in this case is whether the matters complained of could constitute either unfair practice charges or alleged violations of the EERA. The authority of the board to deal with matters other than those which are “unlawful” under sections 3543.5 and 3543.6 was not disputed by the court in San Diego Teachers Assn. The court noted an argument made in an amicus brief that a comparison of section 3541.57

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Leek v. Washington Unified School District
124 Cal. App. 3d 43 (California Court of Appeal, 1981)

Cite This Page — Counsel Stack

Bluebook (online)
124 Cal. App. 3d 43, 177 Cal. Rptr. 196, 1981 Cal. App. LEXIS 2195, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leek-v-washington-unified-school-district-calctapp-1981.