May 2026 Board Decisions Summary
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In May 2026, the Board issued six decisions. The decision descriptions and dispositions are below.
Organization: Service Employees International Union Local 1021 (Haile)
Case No. SF-CO-9-P
Issued date: May 8, 2026
Non-Precedential
Description: Charging Party Tewodros Haile alleged that Respondent Service Employees International Union Local 1021 violated Chapter 4 of the San Francisco Bay Area Rapid Transit District (BART) Act (Pub. Util. Code, §§ 28848 et seq.) by failing to restore his “union seniority” after he was reinstated to employment with BART. PERB’s Office of the General Counsel (OGC) sent Haile a warning letter advising that PERB lacks jurisdiction over internal union matters having no substantial impact on employees’ relationship to their employer. Haile amended the charge, but OGC found that he failed to correct the deficiencies identified in the warning letter and dismissed the charge. Haile appealed.
Disposition: In a non-precedential decision, the Board affirmed OGC’s dismissal of the charge.
Organization: Service Employees International Union Local 2015 (Duong)
Case No. LA-CO-318-M
Issued date: May 11 2026
Non-Precedential
Description: Hoang Duong attempted to file an unfair practice charge against SEIU Local 2015. PERB’s Office of the General Counsel (OGC) found that the submission was deficient. The substance of the charge stated only “See attached Statement of Facts and Remedy,” and Duong neglected to file any such attachment. OGC afforded Duong an opportunity to cure the faulty submission, but Duong never filed an attachment or otherwise asserted any factual allegations. OGC therefore closed the case without allowing Duong’s charge to be filed. Duong appealed.
Disposition: The Board dismissed the case without prejudice because Duong failed to submit any factual allegations for review and OGC accordingly never allowed Duong’s deficient charge to be filed.
Employer: Los Angeles Unified School District
Case No. LA-CE-7046-E
Issued date: May 20, 2026
Non-Precedential
Description: Charging Party Verita Lynee Downing alleged that Respondent Los Angeles Unified School District violated the Educational Employment Relations Act by not re-electing her to a position as a Career Technical Education (CTE) teacher in retaliation for protected activity. Downing also alleged that the District had a pattern of failing to re-elect other CTE educators. PERB’s Office of the General Counsel (OGC) issued Downing a warning letter stating her charge did not allege a prima facie case and she could not bring a charge on behalf of other CTE teachers unless they were added as named charging parties. The warning letter offered Downing an opportunity to amend her charge. Downing amended her charge, however OGC determined that she had not cured the defects outlined in the warning letter and therefore dismissed the charge. Downing appealed.
Disposition: In a non-precedential decision, the Board affirmed OGC’s dismissal without leave to amend.
Employer/Organization: Los Angeles Unified School District and California School Employees Association
Case Nos. LA-CE-7015-E and LA-CO-1899-E
Issued date: May 28, 2026
Non-Precedential
Description: Charging Party Alfred Charles Valrie appealed the dismissal of his two unfair practice charges by PERB’s Office of the General Counsel (OGC). In Case No. LA-CE-7015-E, Valrie alleged that Respondent Los Angeles Unified School District violated the Educational Employment Relations Act (EERA) by constructively discharging Valrie, notating his resignation as “Resigned to Avoid Discipline,” and suing Valrie in retaliation for his protected activity. In Case No. LA CO-1899-E, Valrie alleges that Respondent California School Employees Association breached its duty of fair representation, thereby violating EERA, when it refused to assist Valrie regarding his constructive discharge and resignation notation. OGC issued warning letters in both cases, finding that the charge against the District was untimely and both charges failed to state prima facie violates of EERA. Valrie amended his charges, and OGC dismissed them, finding that Valrie did not cure the deficiencies outlined in the warning letters.
Disposition: In a non-precedential decision, the Board affirmed the dismissal of Valrie’s charges without leave to amend.
Employer: Casitas Municipal Water District
Case No. LA-CE-1861-M
Issued date: May 29, 2026
Non-Precedential
Description: Charging Party Brian H. Taylor alleged Respondent Casitas Municipal Water District violated the Meyers-Milias-Brown Act when it unilaterally changed its payroll methodology without providing notice and an opportunity to bargain. After reviewing Taylor’s charge and the District’s response, PERB’s Office of the General Counsel (OGC) issued a warning letter stating Taylor did not allege a prima facie case that the District had committed a unilateral change or engaged in bad faith bargaining. OGC dismissed the charge on the basis that individual employees lack standing to allege that an employer violated statutory sections that protect collective bargaining rights of employee organizations, including unilateral change violations and allegations of bad faith bargaining. Taylor appealed.
Disposition: In a non-precedential decision, the Board affirmed OGC’s dismissal without leave to amend.
Employer: Orange County Fire Authority
Case Nos. LA-CE-1848-M and LA-CE-1849-M
Issued date: May 29, 2026
Non-Precedential
Description: Charging Parties Juan Chumacero and John Robert Bodo each appealed the dismissal of their respective unfair practice charges by PERB’s Office of the General Counsel (OGC). Charging Parties alleged that Respondent Orange County Fire Authority retaliated and discriminated against them and interfered with their protected rights. OGC issued a warning letter in each case, stating that Charging Parties’ allegations did not state a prima facie case. Charging Parties thereafter filed amended charges. OGC dismissed the amended charges because they did not correct the deficiencies identified in the warning letters and did not otherwise state a prima facie case. Charging Parties appealed. The Board consolidated these cases for the purpose of this decision.
Disposition: In a non-precedential decision, the Board affirmed the dismissal of the unfair practice charge without leave to amend in each of the consolidated cases.
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