RIALTO POLICE BENEFIT ASS'N. v. City of Rialto

I. INTRODUCTION

This case presents an issue of first impression: Is a city’s decision to enter into a contract with the county sheriff for law enforcement services, rather than continue to provide such services through the city’s own police department, subject to the meet-and-confer requirements of the Meyers-Milias-Brown Act (MMBA) (Gov. Code, § 3500 et seq.)? We answer the question in the affirmative, and we therefore affirm the trial court’s decision on the issue.

ff. FACTS AND PROCEDURAL BACKGROUND

The City of Rialto (City) is a general law city, and its city council (City Council) is its elected policymaking body, responsible for policy oversight of City operations. The Rialto Police Department (RPD), headed by a police chief, serves as the law enforcement arm of the City. The Rialto Police Benefit Association (RPBA) is the exclusive representative of a bargaining unit consisting of all of the police officers and most of the civilian personnel employed by the RPD.

From January 2004 through the end of December 2005, the City and RPBA were parties to a memorandum of understanding (MOU). In September 2005, the City administrator submitted a staff report to the City…