P. ex rel. Internat. Assn. of Firefighters v. City of Palo Alto

I. FACTS AND PROCEDURAL BACKGROUND

This case returns to us a second time. In our previous opinion, we set out its factual and procedural background. (City of Palo Alto v. Public Employment Relations Bd. (2016) 5 Cal.App.5th 1271 (City of Palo Alto).) We describe here only pertinent details and subsequent proceedings. A. Overview In 2010 and 2011, the City of Palo Alto (city) faced a budget crisis. To reduce its labor costs, the city council contemplated altering a provision in its city charter that required submission of certain labor disputes with its public safety unions to binding interest arbitration. (Charter of the City of Palo Alto, former art. V., § 4 (article V).) The city believed Government Code section 3507 1 of the Meyers-Milias-Brown Act (MMBA) did not require prior good faith consultation with its public safety unions. (City of Palo Alto, supra, 5 Cal.App.5th at pp. 1279–1280.) In July 2011, the city council adopted resolution 9189, proposing to city voters an amendment to the city charter to repeal article V and replace it with other dispute resolution procedures. (Palo Alto Res. No. 9189 (resolution 9189).) Pursuant to this resolution, the city held a special…