San Juan Teachers Ass'n v. San Juan Unified School District

These appeals, consolidated for decision, involve separate disputes as to the scope of a public school employer's obligation to "meet and confer" with representatives of certificated employee organizations under the provisions of the Winton Act (Ed. Code, § 13080 et seq.). [1]

In each case, upon the complaint of a teachers' association and the chairman of the certificated employee council which represented that organization, [2] the superior court tried the cause without a jury and granted declaratory relief generally adverse to the contentions of the teachers' employer, the defendant school district. Additionally, in the action against the Yuba City Unified School District, the judgment permanently enjoined the district's board of trustees from conduct inconsistent with the court's declaration of rights. Each school district appeals from the judgment against it.

To facilitate comprehension of the facts relevant to each appeal, we quote those portions of the Winton Act upon which the rights of the parties depend: [3]

"It is the purpose of this article [the Winton Act] to promote the improvement of personnel management and employer-employee relations within…

These appeals, consolidated for decision, involve separate disputes as to the scope of a public school employer’s obligation to “meet and confer” with representatives of certificated employee organizations under the provisions of the Winton Act (Ed. Code, § 13080 et seq.). 1

*240 In each case, upon the complaint of a teachers’ association and the chairman of the certificated employee council which represented that organization, 2 the superior court tried the cause without a jury and granted declaratory relief generally adverse to the contentions of the teachers’ employer, the defendant school district. Additionally, in the action against the Yuba City Unified School District, the judgment permanently enjoined the district’s board of trustees from conduct inconsistent with the court’s declaration of rights. Each school district appeals from the judgment against it.

Winton Act

To facilitate comprehension of the facts relevant to each appeal, we > quote those portions of the Winton Act upon which the rights of the parties depend: 3

*243 San Juan Case (3 Civil No. 14010)

1. Facts in San Juan Case

In May 1971, the San Juan Teachers Association (“Association”),…

I concur in part, dissent in part. The Winton Act contains a number of large verbal abstractions which give the appearance but not the reality of concrete solutions. For example, after expressing a broad purpose “to afford [teacher organizations] a voice in the formulation of educational policy” (§ 13080), the act demands that school trustees meet and confer with these organizations “with regard to procedures relating to the definition of educational objectives, the determination of the content of courses and curricula, the selection of textbooks, and other aspects of the instructional program ....” (§ 13085.) Relatively narrow employee participation in procedures is hardly coextensive with broad participation in policy. Similar examples of linguistic looseness abound.

*261 Statutory generalizations of this sort have the earmarks of verbal compromises between contending special interests. They allow a legislative escape from controversy and send the contending interests out into the administrative arena and from thence into already overburdened courts. Conventional tenets of statutory interpretation fall flat in the face of such draftsmanship. Hence, conflicting interpretations…