San Diego Municipal Employees Ass'n v. Superior Court

In 2011, the proponents of a voter initiative entitled the “Comprehensive Pension Reform Initiative” (CPRI) circulated petitions to qualify the CPRI for placement on the San Diego County ballot. The CPRI, if enacted, would amend the charter of the City of San Diego (City) in ways that, among other things, would impact retirement benefits for certain City employees. After the San Diego County Registrar of Voters certified that sufficient signatures had been collected to place the CPRI on the June 5, 2012, voter ballot, petitioner San Diego Municipal Employees Association (MEA), the recognized exclusive bargaining unit for the potentially affected employees, filed an unfair practices charge (UPC) against City with the Public Employment Relations Board (PERB). The UPC alleged City had engaged in an unfair labor practice by not satisfying the meet and confer *1452 requirements of the Meyers-Milias-Brown Act (the MMBA) (Gov. Code, § 3500 et seq.) before placing the CPRI on the ballot. Accompanying the MEA’s UPC was a request for injunctive relief.

PERB responded to the UPC by issuing a complaint against City, alleging City’s conduct violated the MMBA. PERB also authorized its…