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County Sanitation District v. Local 660, Service Employees International Union, AFL-CIO

California Supreme Court

38 Cal. 3d 564, 214 Cal. Rptr. 424, 699 P.2d 835 (1985)

Facts

Los Angeles County Sanitation District 2 (the district) (plaintiff) employed workers who were represented by Local 660 of the Service Employees International Union (the union) (defendant). Since 1973, the district and the union had bargained annually over wages, hours, and working conditions under California’s Meyers-Milias-Brown Act (MMBA). Each year, the parties’ negotiations had resulted in a binding labor contract or memorandum of understanding (MOU). However, in 1976, the district and the union reached an impasse regarding a new wage-and-benefit agreement. On July 5, 1976, following the impasse, 75 percent of the district’s employees went out on strike. The strike lasted for 11 days and ended when the employees voted to accept a new MOU with terms that were identical to the district’s offer before the strike. The district sued the union in California state court, seeking tort damages. The trial court found that the strike was unlawful and awarded the district nearly $250,000 in compensatory damages, plus prejudgment interest and costs. The union appealed.

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Holding and Reasoning (Broussard, J.)

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Concurrence (Bird, C.J.)

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Dissent (Lucas, J.)

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