Oak Grove Educators Ass'n, CTA/NEA v. Oak Grove School District

California’s Educational Employment Relations Act (the act) prevented a public-school employer from dominating or interfering with the formation or administration of an employee organization, contributing support to it, and encouraging employees to join any organization to the exclusion of another. The Oak Grove School District (the district) (defendant) hired a superintendent, Robert Lindstrom, who formed a roundtable-discussion group for teachers. This was done at the request of teachers and in continuance of the predecessor’s practice. Believing it would enhance communication and provide teachers with an opportunity to express concerns, Lindstrom told each school to send one representative to the monthly meetings. The teachers’ union, Oak Grove Educator’s Association (the union) (plaintiff), was not asked to send an official representative, although some members of the roundtable group were also members of the union. The meetings took place during work hours. Members of the roundtable group could call the superintendent’s office and suggest items for the agenda, which would be finalized at the superintendent’s office. Attendees would report back to colleagues after meetings. Lindstrom attempted to walk a fine line so that issues being negotiated with the union were not discussed at meetings, but on occasion these topics would come up. No official resolutions or agreements were formed at the meetings. These matters included overloaded classrooms and class size, the amount of time teachers worked without a break, and a staff incentive-award program. Lindstrom often noted during the meetings that these issues were the subject of ongoing negotiations with the union and could not be discussed further. Testimony from various teachers suggested that the roundtable forum came to be viewed as a better avenue to express concerns and address certain issues. Attendance at union meetings eventually dropped by half. The union sued, contending that the district’s roundtable forum constituted an employee organization that the district dominated in violation of the act.