March 2026 Board Decisions Summary
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In March 2026, the Board issued five decisions. The decision descriptions and dispositions are below.
Employer: Fontana Unified School District
Case No. LA-CE-6874-E
Issued date: March 2, 2026
Non-Precedential
Description: Charging Party United Steelworkers Local 8599 appealed an administrative determination issued by PERB’s Office of the General Counsel (OGC). A PERB administrative law judge held a formal hearing and found that Respondent Fontana Unified School District violated the Educational Employment Relations Act (EERA) when it issued a directive to a bargaining unit employee not to contact students or staff at one of Respondent’s schools. Following compliance proceedings, OGC found that Respondent complied with the ordered remedy, including the order that Respondent make Charging Party and bargaining unit employees whole for any losses suffered as a result of Respondent’s unlawful directive. Charging Party appealed.
Disposition: The Board denied the appeal, finding that Charging Party’s assertion that a bargaining unit employee was denied an opportunity for summer work assignments because of Respondent’s unlawful directive was unsubstantiated.
Organization: Sequoia District Teachers Association (Downing)
Case No. SF-CO-886-E
Issued date: March 4, 2026
Non-Precedential
Description: Charging Party Sharlett Downing appealed the dismissal of her unfair practice charge by PERB’s Office of the General Counsel (OGC). Charging Party alleged that Respondent Sequoia District Teachers Association violated the Educational Employment Relations Act (EERA) by breaching its duty of fair representation by misrepresenting to her employer, the Sequoia Union High School District, the status of her leave; excluding her from union communications after she was placed on the 39-month reemployment list; and declining to advocate for restoration of her work e-mail access after she was separated. OGC issued Charging Party a warning letter explaining the facts alleged would not establish that Respondent had breached its duty of fair representation or violated EERA and that PERB is prohibited from issuing a complaint with respect to any charge based upon an alleged unfair practice occurring more than six months before the charge was filed. The warning letter also informed Charging Party that all charge allegations that were known or should have been known were outside EERA’s six-month statute of limitations. Charging Party amended her charge two times, however OGC determined she had not cured the deficiencies explained in the warning letter. OGC dismissed Charging Party’s second amended charge. Charging Party appealed the dismissal.
Disposition: In a non-precedential decision, the Board affirmed the dismissal of Charging Party’s amended charge without leave to amend.
Organization: Sacramento City Teachers Association, CTA/NEA (Reilly)
Case No. SA-CO-701-E
Issued date: March 10, 2026
Non-Precedential
Description: Charging Party Patrick Reilly appealed the dismissal of his unfair practice charge by PERB’s Office of the General Counsel (OGC). Charging Party alleged that Respondent Sacramento City Teachers Association, CTA/NEA violated the Educational Employment Relations Act (EERA) by breaching its duty of fair representation when it refused to represent him in an administrative hearing. OGC 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.
Organizations: United Teachers of Santa Clara and California Teachers Association (SCM)
Case No. SF-CO-897-E
Issued date: March 26, 2026
Non-Precedential
Description: Charging Party SCM alleged that Respondents United Teachers of Santa Clara (UTSC) and California Teachers Association (CTA) breached their duty of fair representation by engaging in a pattern of conduct to deny SCM meaningful access to grievance remedies, thereby violating EERA. After PERB’s Office of General Counsel (OGC) issued SCM a warning letter, he amended the charge and subsequently included supporting exhibits. OGC dismissed the amended charge because it did not state a prima facie violation of EERA. SCM appealed the dismissal and requested review of OGC’s denial of his request to proceed under a pseudonym.
Disposition: In a non-precedential Decision, the Board affirmed OGC’s dismissal and pseudonymity determination, and dismissed Charging Party’s charge without leave to amend.
Organization: San Francisco Deputy Sheriffs’ Association (Santana)
Case No. SF-CO-569-M
Issued date: March 27, 2026
Non-Precedential
Description: Charging Party Andre Santana filed an unfair practice charge against Respondent San Francisco Deputy Sheriffs’ Association alleging that the Association retaliated and discriminated against him and breached its duty of fair representation in violation of the Meyers-Milias-Brown Act. PERB’s Office of the General Counsel (OGC) dismissed Santana’s charge. Santana appealed OGC’s dismissal to the Board.
Disposition: In a non-precedential decision, the Board denied Santana’s appeal and dismissed the charge.
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