United Public Employees, Local 390/400 v. City & County of San Francisco

Several labor organizations representing city employees (appellants) 1 brought this mandamus proceeding against the City and County of San Francisco and its Board of Supervisors alleging that the city violated the Meyers-Milias-Brown Act (MMBA) (Gov. Code, § 3500 et seq.) by declaring its intent to submit any prospective agreement between the city and appellants on fringe benefits to the voters for approval, as required by the city charter. The trial court declined to issue a writ, and we affirm.

In the latter part of 1984, appellants contacted the city demanding that it meet and confer over proposals for the establishment of dental insurance and other fringe benefits for city employees. The MMBA’s “meet and confer” guidelines require public employers to “meet and confer in good faith” with representatives of recognized employee organizations concerning, inter alia, wages, hours and other terms and conditions of employment. The MMBA defines that obligation as including the duty “to exchange freely information, opinions, and proposals, and to endeavor to reach agreement____” (Gov. Code, § 3505.)

The city responded by letter that it was willing to meet and confer on all…