January 2026 Board Decisions Summary
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In January 2026, the Board issued five decisions. The decision descriptions and dispositions are below.
Employer: City and County of San Francisco
Case No. SF-CE-1972-M
Issued date: January 7, 2026
Non-Precedential
Description: Eileen Villaruel alleged that the City and County of San Francisco violated the Meyers-Milias-Brown Act by retaliating against her for filing the instant charge with PERB. PERB’s Office of the General Counsel dismissed the charge, as amended, explaining that Villaruel had not alleged facts that would establish causation between the alleged adverse actions and the protected activity, i.e., filing her initial charge. Villaruel appealed.
Disposition: In a non-precedential decision, the Board affirmed the dismissal.
Employer: City of Thousand Oaks
Case No. LA-RR-1368-M
Issued date: January 13, 2026
Non-Precedential
Description: Petitioner International Alliance of Theatrical Stage Employees Local 442 (IATSE) initiated a Request for Recognition with PERB based on an allegation that the City of Thousand Oaks was unduly delaying a recognition request IATSE had filed with the City pursuant to the City’s local rules. PERB’s Office of the General Counsel dismissed the matter, and IATSE appealed. While the appeal was pending before the Board, the City referred IATSE’s recognition request to the State Mediation and Conciliation Service (SMCS) for a card check pursuant to the City’s local rules. Thereafter, SMCS informed the Board’s Appeals Office that IATSE had withdrawn its recognition request without prejudice, and accordingly SMCS would not be proceeding with the card check and had closed the matter.
Disposition: The Board issued an Order to Show Cause indicating that the case appeared to be moot and affording IATSE an opportunity to either withdraw the case without prejudice or show cause why it was not moot. IATSE did not respond, and the Board therefore found the matter to be moot and dismissed it without prejudice.
Employer: Regents of the University of California
Case No. SF-PC-162-H
Issued date: January 13, 2026
Non-Precedential
Description: Interested Party University Professional and Technical Employees, Communication Workers of America Local 9119 (UPTE) sought to appeal a determination by PERB’s Office of the General Counsel (OGC) to proceed with an election to resolve a certification petition filed by Communications, Marketing, and Sales Professionals-UAW (ComMas-UAW).
Disposition: In a non-precedential decision, the Board denied UPTE’s appeal.
Employer: County of San Diego
Case No. LA-CE-1778-M
Issued date: January 20, 2026
Non-Precedential
Description: Charging Party Joseph Pickar appealed the Dismissal of his unfair practice charge by PERB’s Office of the General Counsel (OGC). Charging Party alleged that Respondent County of San Diego violated the Meyers-Milias-Brow Act (MMBA) by rejecting him during probation for unlawful reasons. Respondent asserted that the charge was time-barred, it did not contain sufficient facts to demonstrate retaliation or discrimination under the MMBA, and PERB has no jurisdiction to enforce the County’s civil service rules and policies. OGC issued a warning letter stating Charging Party did not allege a prima facie case of retaliation or discrimination and he failed to file his charge within the statue of limitations. Charging Party amended his charge, however, OGC found the amended charge did not establish a continuing violation and dismissed the charge. Charging Party appealed.
Disposition: In a non-precedential decision, the Board affirmed the dismissal of Charging Party’s charge without leave to amend.
Employer/Organization: Santa Clara Unified School District and United Teachers of Santa Clara and California Teachers Association
Case Nos. SF-CE-3665-E and SF-CO-897-E
Issued date: January 26, 2026
Non-Precedential
Description: Charging Party SCM filed an unfair practice charge against Respondent Santa Clara Unified School District initiating Case No. SF-CE-3665-E. Charging Party also filed an unfair practice charge against United Teachers of Santa Clara and California Teachers Association, CTA,NEA (CTA) initiating Case No. SF-CO-897-E. Charging Party filed a document in both cases titled, “Motion to Proceed Under Pseudonym and to Seal, or, in the Alternative, Redact Confidential Information”. PERB’s Office of the General Counsel (OGC) denied both motions and advised Charging Party the denials could be appealed to the Board within 10 days.
Disposition: In a non-precedential decision, the Board remanded the appeals to the OGC for further processing. The Board directed OGC to deem Charging Party’s appeals to be a request to join in the appeal and certify the matter to the Board pursuant to PERB Regulation 32200. The Board also issued a stay in both cases until the date the Board Agent completes processing Charging Party’s appeals pursuant to PERB Regulation 32200. The order for stay dissolves automatically without further action from the Board on the next day the Board Agent either certifies the interlocutory appeals or declines to do so.
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