Sonoma County Board of Education v. Public Employment Relations Board

*692 Opinion

The 1975 Educational Employment Relations (Rodda) Act (Gov. Code, § 3540 et seq.) authorizes public school employees to join employee organizations for purposes of exclusive representation with public school employers on matters pertaining to employment relations including “wages.” (Gov. Code, § 3543.2.) The preexisting statutory scheme mandating the implementation of a civil service or merit system for classified employees in a county school district (Ed. Code, §§ 1317, 45240 et seq.) 1 prohibits any (salary) changes which effectively “disturb the relationship which compensation schedules bear to one another” as established by the personnel commission (§ 45268). A 1977 statutory amendment requires commission rules covering matters which are the subject of negotiation under the Rodda Act to be “in accordance With the negotiated agreement” (§ 45261, subd. (b)). In this appeal, we consider whether a conflict exists between the related statutes and the implications, if any, of such conflict.

The relevant facts are undisputed. During the course of negotiations between appellant Sonoma County Board of Education (Board) and the Sonoma County Organization of Public…