UNION UNFAIR PRACTICES; UNION BARGAINING CONDUCT – Refusal to Bargain in Good Faith (See, also, Scope of Representation, Sec. 1000)
Single Topic for Decision 2290E
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804.02000 – Refusal to Bargain in Good Faith (See, also, Scope of Representation, Sec. 1000)
Charge failed to allege a prima facie violation of the duty to bargain over reopener proposal, where contractual zipper clause barred negotiations unless one of two exceptions applied and employer failed to reopen agreement in a timely fashion. Document entitled “Proposal for a Side Letter Agreement” submitted in context of meetings over fiscal crisis did not constitute a valid demand to bargain, did not create a bargaining obligation, and did not constitute timely reopener demand, and untimely bargaining request did not “relate back” to proposal.