Pacific Legal Foundation v. Brown

624 P.2d 1215, 172 Cal. Rptr. 487, 29 Cal. 3d 168 (1981)

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Pacific Legal Foundation v. Brown

California Supreme Court
624 P.2d 1215, 172 Cal. Rptr. 487, 29 Cal. 3d 168 (1981)

Facts

Article VII of California’s constitution was aimed at establishing a system of meritocracy for state civil service. Article VII mandated employment in the classified service based solely on merit and efficiency and established a nonpartisan State Personnel Board (the state board). The state board was empowered to prescribe probationary periods and employment classifications, adopt other rules, and review disciplinary actions. In 1977 California enacted the State Employer-Employee Relations Act (SEERA) to guarantee collective-bargaining rights to state employees. SEERA established the principle of exclusive representation, imposed an obligation on employers to meet and confer in good faith, and directed parties to form a memorandum of understanding. SEERA also established the Public Employment Relations Board (PERB) to investigate and devise remedies for unfair labor practices. SEERA contained several limitations on the bargaining process. No provision in a memorandum of understanding could conflict with a state statute, and budgets were subject to legislative approval. In January 1979, before full implementation of the new process, two groups, the Pacific Legal Foundation and the Public Employees Service Association (collectively, the organizations), filed an original mandate proceeding in the court of appeal, naming as a defendant then-governor Edmund Brown (defendant), contending SEERA was unconstitutional on its face because it usurped the state board’s power to set salaries, overlapped with the state board’s jurisdiction, and conflicted with Article VII’s explicit mandate for meritocracy. The attorney general filed a similar suit two weeks later. The cases were consolidated. The court of appeal agreed with the organizations’ claims and struck down the statute in its entirety.

Rule of Law

Issue

Holding and Reasoning (Tobriner, J.)

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