App. I respectfully dissent. The applicant must check the box on the application indicating that they are seeking a waiver. Here, by contrast, Chapter 433 constitutes an interpretation of a constitutional provision, the construction and limits of which are disputed. The court concluded that Caltrans had violated the injunction by contracting with private entities for substantial amounts of project development work without providing adequate justification. 134.) As plaintiffs observe, "Were the rule otherwise, the civil service system could be entirely undone by a system of contracting; and the state's work force could be dominated by independent contractors who would be hired from job to job." (See, e.g., Producers Dairy Delivery Co. v. Sentry Ins. Although Globe Grain concerned a statute which contained some express limits on the commission's exercise of discretion, I see no reason why the same presumption should not apply here. PECG offers members life, disability, and other insurance benefits at group rates. As this court recently explained, "Although the language of California Constitution article III, section 3, may suggest a sharp demarcation between the operations of the three branches of government, California decisions long have recognized that, in reality, the separation of powers doctrine ' "does not mean that the three departments of our government are not in many respects mutually dependent" ' [citation], or that the actions of one branch may not significantly affect those of another branch. 2d 912, 916 [152 P.2d 169]; Martin v. Riley (1942) 20 Cal. The title acts are Agricultural, Chemical, Control Systems, Fire Protection, Industrial, Metallurgical, Nuclear, Petroleum, and Traffic Engineering. 134.). 490.). 21, 529 P.2d 53] [adoption of constitutional language similar to that in former constitutional provision is presumed to incorporate authoritative judicial construction of former language]; cf. If the law, when thus considered, does not appear to be unconstitutional, the court will not go behind it, and, by a resort to evidence, undertake to ascertain whether the legislature, in its enactment, observed the restrictions which the constitution imposed upon it as a duty to do, and to the performance of which the members were bound by their oaths of office." In summary, the court found that Caltrans was violating the 1990 injunction by contracting with private entities without factually demonstrating that it had met the statutory criteria for doing so. (29 Cal.3d at pp. (1981) 85 A.D.2d 733 [445 N.Y.S.2d 812, 813]; Carter v. Ohio Dept. 2d 561, 569 [154 P.2d 674].) App. This reading is supported by the Legislature's express finding in section 14130, subdivision (a)(3), which recites that contracting out "avoid[s] the costly process of short-time hiring and layoff while still responding in a timely manner to funding opportunities and uncertainties[. Rptr. As a member of the executive management team, Jason collaborates on business strategy, marketing, & operations mgmt for the company. In the case that the NCEES Record does not provide the information the Board needs to determine if an applicant meets the requirements for licensure in California, the applicant will be asked to provide additional information. Rptr. In Caltrans's view, the rules these cases announced are unsupported by the bare language of the civil service mandate and constitute further judicial legislation. Practices Com. (California State Employees' Assn. Code, 14130, subd. J Y2UETU2+]g0Zb. Rptr. To me, however, the existence of this provision further shows the Legislature was aware of Riley and its progeny and was attempting to enact legislation that would pass constitutional muster. The People enacted article VII to avoid this. 225, 703 P.2d 1119] [ordinary deference courts owe to legislative action vanishes when constitutionally protected rights are threatened].) In 1981, this court made quite plain that the foregoing presumptions and rules of deference apply when legislation is challenged as being in conflict with article VII of the California Constitution (article VII). In my judgment the majority, although purporting to follow settled rules, in fact apply a totally unprecedented standard for invalidating Chapter 433 without offering any justification or rationale for rejecting a century of decisional law in California. App. 313, 1.5) dealt with contracts for professional and technical services. ), Likewise, regarding section 14130, subdivision (a)(4), the court concluded: "In section 14130, subdivision (a)(4), the Legislature finds that '[w]ithout the ability to continue a stable contracting out program, the department will not be able to perform project delivery adequately, competently, or satisfactorily.' . Rptr. What are the Time Limits for Reinstatement? ", FN 15. 4.) California Association of Professional Scientists (CAPS) 11 . It looks like your browser does not have JavaScript enabled. The majority's decision to apply an independent-judgment-of-the-facts approach in assessing the constitutional validity of legislative action marks a radical departure from long-standing case law holding that judges may not substitute their judgment for that of the Legislature if there is any reasonable justification for the legislative action. We are not prepared to take that step and disregard three decades of jurisprudence applying and construing the constitutional provision. (Ch. But until such a study is performed, we have no basis for concluding that Chapter 433's legislative findings have undermined the injunction. Engineering and Scientific Technicians. Code, 3424, subd. There is aQualification Flowchartdepicting the requirements. Please view theFingerprinting FAQsfor detailed information. ), In my view, the findings and statements of intent included in Chapter 433 are not inconsistent on their face with appropriate constitutional interpretation of article VII. Recent legislation authorizes a court to modify or dissolve an injunction or temporary restraining order "upon a showing that there has been a material change in the facts upon which the injunction or temporary restraining order was granted, that the law upon which the injunction or temporary restraining order was granted has changed, or that the ends of justice would be served by the modification or dissolution of the injunction or temporary restraining order." (Dis. Accordingly, the court ruled the private contracts invalid. 2 (E.g., Spiritual Psychic Science Church v. City of Azusa (1985) 39 Cal. (See Department of Transportation v. Chavez (1992) 7 Cal. The judiciary, in reviewing statutes enacted by the Legislature, may not undertake to evaluate the wisdom of the policies embodied in such legislation; absent a constitutional prohibition, the choice among competing policy considerations in enacting laws is a legislative function. The judiciary's review of legislative acts must be circumspect and deferential, reflecting the constraints of the Constitution. The only function of the courts is to determine whether the exercise of legislative power has exceeded constitutional limitations." The section then contains the legislative conclusion that "Without the ability to continue a stable contracting out program, the department will not be able to perform project delivery adequately, competently, or satisfactorily, thereby necessitating the use of private consultants to supplement its in-house staff.". In 1993, the Legislature enacted Chapter 433 in recognition that California needed a "comprehensive and integrated highway construction plan" to maximize the capture and use of federal, state, local, and private funds and to maintain a competitive posture in seeking supplemental federal funds. 107, 1, subd. Rptr. Com. opn., ante, at p. Professional Engineers in California Government was formed in 1962 for the sole purpose of representing state-employed engineers and related professionals responsible for designing and inspecting California's infrastructure, improving air quality, and developing clean energy and green technology. Thus, the California Constitution Revision Commission considered and rejected an approach that would have given the Legislature open-ended authority to create exemptions from civil service in any area in which the Legislature felt that public policy would be served better by an alternative to the civil service system. 363, 364 ["The inclusion of independent contractors is of vital importance as it cuts off a wide area of possible subversion of the civil service system."].). And the Legislature may not undertake to readjudicate controversies that have been litigated in the courts and resolved by final judicial judgment. 3d 258, 282 [96 Cal. The Court of Appeal ordered the 1990 injunction dissolved and the matter remanded to the trial court for further proceedings. (Tobe v. City of Santa Ana (1995) 9 Cal. ), This court explained that when dealing with the question of whether to uphold the Legislature's determination that an urgency measure is necessary, it applies "the rule that a declaration of urgency by the Legislature will not be declared invalid 'unless it "appears clearly and affirmatively from the legislature's statement of facts that a public necessity does not exist." App. As I shall explain, Chapter 433 provides a constitutionally valid basis for dissolving the 1990 injunction on the same ground. While acknowledging that "courts must give legislative findings great weight and should uphold them unless unreasonable or arbitrary" (maj. 4th 594] This court has adhered to these principles in numerous cases involving diverse situations. as amended July 14, 1993, p. 4; see ante, at p. 570) and a letter from the Legislative Analyst to a state senator indicating that figures purporting to show the respective costs of private and public service "are not directly comparable." 4th 606] have stressed in First Amendment cases that the deference afforded to legislative findings does 'not foreclose our independent judgment of the facts bearing on an issue of constitutional law.' The practice acts are Civil, Electrical, and Mechanical Engineering. The court concluded: "[T]he Legislature, with its extensive fact-finding powers, is better suited than we are to assess the financial and aesthetic consequences of its policies. Moreover, an Assembly Transportation Committee report submitted to the Legislature before it adopted Chapter 433 acknowledged that questions existed concerning the constitutionality of the legislation. 593.) (Maj. Sess.) fn. ReviewBusiness and Professions Code section 6759for additional information regarding comity. and to locally funded highway projects fn. [15 Cal. 1018.) 1209 (1993-1994 Reg. 4th 550] promote efficiency and economy' " in state government, and "to eliminate the 'spoils system' of political patronage." California Federation of Interpreters, Communication Workers of America, AFL-CIO v. Region 4 Court Interpreter Employment Relations Committee, et al. fn. (Art. 548-550), as applied to those contracts. RH'L`ISJT *2Pe8YcrPXffr!9@1Xr?j [Q%.QV v. Spokane Community Coll. In Salazar, the trial court's injunction was based on "assumptions about the law" that changed when this court filed a new decision. 4th 568] Caltrans' bare claim that the use of contracts 'results in faster and less expensive service delivery.' CalHR 138: Leave Reduction Plan; (See California State Employees' Assn. 9 However, when read with a view toward finding the statute constitutional (see Miller v. Municipal Court [15 Cal. ` 3evNID#DA@$_%Lx~X/s#&h aM A title authority indicates a proficiency in that field greater than what is required for Civil Engineering licensure. The film tells the story from the perspectives of the construction contractor, Caltrans engineers and designers, and two of the reporters who covered the story. That is not to say we are required to acknowledge the emperor's clothing if he is naked; rather, it is to say that if we cannot by resort to what reasonable people know to be indisputably true reach a contrary finding, we must accept and respect the findings of those who have that responsibility. Easy 1-Click Apply (DUNHILL PROFESSIONAL SEARCH & GOVERNMENT SOLUTIONS) System Engineer Lead - Remote job in Fairfax at Dunhill Professional Search job in Dallas, TX. ), In the Court of Appeal majority's view, these findings and declarations override or replace the trial court's earlier findings that Caltrans's inability to perform projects through the state civil service was caused by its own policy of inadequate staffing. There is nothing in the record to refute the implicit legislative finding that sufficient additional staff could not be obtained on a cost-effective basis." There are three categories of Professional Engineer licensure available in California: (1) practice act, (2) title act, and (3) title authority. PECG has sponsored and produced several Emmy Award-winning documentaries that have been seen by millions of viewers around the country. Caltrans cites various sources in support of its position that the constitutional civil service mandate was not intended to restrict private contracting. 'If there is any doubt as to whether the facts do or do not state a case of immediate necessity, that doubt should be resolved in favor of the legislative declaration .' [Citation.] Code, 14133 [contracts over $250,000 must comply with Gov. opn., ante, at pp. Similarly, section 14130.2, subdivision (a)(2), purports to relieve Caltrans of its obligation to maintain a civil engineering staff "at a level to provide services for other [local] agencies" that arrange their own financing for state highway projects. Unit 9 (Professional Engineers) MOU Analysis Format: HTML; August 25, 2022 - We reviewed the proposed memorandum of understanding for Bargaining Unit 9 (Professional Engineers). 4th 577] challenge to constitutionality of legislation authorizing state to contract with private sector for personal services]. To perform the remaining project development work targeted for private consultants, Caltrans made limited term, retired annuitant, or temporary civil service appointments. 4th 563] injunction. (CSEA, supra, 199 Cal.App.3d at p. What Constitutes a Satisfactory Reference? 4th 593] Cal.Rptr.2d 837, 913 P.2d 1046].) ), Responding to the trial court's doubts regarding the supposed "short-term" nature of the seismic safety retrofit program, the Court of Appeal majority reasoned that, although this program may be comparable to any typical Caltrans project, it "has a finite life. In examining Chapter 433, it must be presumed the Legislature intended its act to be valid and to fall within the scope of its constitutional powers. PROFESSIONAL ENGINEERS IN CALIFORNIA GOVERNMENT, Charging Party, v. STATE OF CALIFORNIA (DEPARTMENTS OF PERSONNEL ADMINISTRATION AND TRANSPORTATION), Respondent.))) Such a system, operating without regard to considerations of economy or efficiency, and open to a "patronage/spoils system" method of contracting, would conflict with the electorate's probable intent in adopting article VII and its predecessor. Apart from seeking to abrogate Riley et al., Caltrans raises no challenges independent of Chapter 433 at this time. The dissent disagreed, stating that "We are bound by the trial court's factual determination that the necessity to contract out, if any, arises out of an artificial, political constraint on the hiring of new civil service staff. "However, this question is not presented by Chapter 433. Dissenting.-The majority find chapter 433 of Statutes 1993 (Chapter 433) violative of the state Constitution's civil service provision (Cal. at pp. (Gov. Because the injunction was inconsistent with the new law, the trial court did not abuse its discretion in vacating it. 283, 816 P.2d 1309] [rejecting federal constitutional challenge to term limits initiative and finding no need for initiative's defenders to empirically demonstrate that the initiative will accomplish each of its objectives]; Buhl v. Hannigan (1993) 16 Cal. The majority have not shown that the Legislature was clearly or palpably wrong in determining that Chapter 433's provisions for additional flexibility in contracting will promote efficiency and economy in state government. This position does not require Senate confirmation and the compensation is . It is this fundamental allocation of responsibility that undergirds our [15 Cal. Although not explicitly stated in the act, it is apparent that implicit in Chapter 433 is a provision that contracting out must make economic sense-it must be cheaper than using civil service-and that the discretion of the Director of Transportation (Director) to contract out must be exercised toward that end. Rptr. "At the same time, this doctrine unquestionably places limits upon the actions of each branch with respect to the other branches. 4th 566] privatization. v. State of California (1988) 199 Cal. [Citation.] I do not find such a conclusion inconsistent with a reasonable application of Riley and its progeny. ), (3) Caltrans may use private contracting on state highway projects funded by federal and state funds "to support state transportation infrastructure funded by local resources, to ensure timely retrofitting for seismic safety on state transportation infrastructure, and to ensure timely and cost-effective project delivery." 2d 165, 170 [68 P.2d 741] (Stockburger) [enjoining state from hiring private independent contractors to clean state building].) 4th 584] highly and technically skilled in his science or profession is one which may properly be made without competitive bidding.' (See maj. Rptr. Below, we describe the types of employees in the states 21 bargaining units. 4th 603] and limits pertaining to the use of such funds. (Ferguson v. Skrupa (1963) 372 U.S. 726, 729 [83 S. Ct. 1028, 1030, 10 L. Ed. And as indicated previously, it is contemplated that these statutory provisions are to remain in effect only until January 1, 1998. fn. Code, 14130.1, subd. (See Kennedy v. Ross (1946) 28 Cal. The trial court found no facts to support a finding that civil service staff would be unable "adequately and competently" to perform the work at issue. endstream endobj 379 0 obj <>stream As plaintiffs observe, " there is no evidence in the record to support [15 Cal. Rptr. (1 Witkin, Cal. Judges may not substitute their judgment for that of the Legislature if there is any reasonable justification for the latter's action. Dist. ), The Court of Appeal relied on case law presuming the validity of legislation and according "great weight" to legislative findings unless "unreasonable and arbitrary" or "clearly and palpably wrong." Respondents' petition for a rehearing was denied July 16, 1997. According to the court, this finding could only be based on a study of actual workloads and available staff during particular fiscal years. [Caltrans] is not required to staff at a level to provide services for other agencies." 15 Article VII does not involve "constitutionally protected rights," nor does Chapter 433 threaten such rights. We do, however, apply the general rule that 'a strong presumption of constitutionality supports the Legislature's acts. 2d 832, 839 [313 P.2d 545] (whether sales tax levy was subject to referendum); Busch v. Turner (1945) 26 Cal. In the absence of any substantial evidence supporting this legislative intent to accommodate Caltrans in circumventing the court's injunction, we must deem this purpose, however clearly expressed, insufficient to satisfy the constitutional mandate. Rptr. VII, 1 (article VII)) and its implied mandate limiting the state's authority to contract with private entities to perform services the state has historically or customarily performed. The trial court used similar factual conclusions elsewhere in its order as well. (13 Cal.App.4th at pp. (Id. As one appellate decision has observed, "Decisional law interprets article VII as a restriction on the 'contracting out' of state activities or tasks to the private sector. Professional Scientific. Code, 14130, subd. (a)(3)). "[A]n as applied challenge assumes that the statute violated is valid and asserts that the manner of enforcement against a particular individual or individuals or the circumstances in which the statute is applied is unconstitutional." 1209 (1993-1994 Reg. (Italics added. To hold otherwise would invite chaos. 844. ), Because of the largely implicit nature of the private contracting restriction, we must discern its scope from judicial decisions applying it in [15 Cal. As the dissent explained, "The trial court had determined the rights and obligations of the parties to this litigation under contracts entered into under the law preceding Chapter 433. Rptr. 4th 556] retrofitting and locally funded project categories. of Scalia, J.) PECG represents 14,000 state-employed engineers and related professionals responsible for designing and inspecting California's infrastructure, improving air. Please view theFingerprinting FAQsfor detailed information. FN 7. The rule, moreover, remains viable today. Greg has over 10 years of Defence + 19 years of industry experience and is a professional project manager. If conflicts arise, the Professional Engineers Act will take precedence. I. Sess.) Co. v. Deukmejian, supra, 48 Cal.3d at page 822, footnote 15 (attack on facial validity of initiative measure); Metromedia, Inc. v. City of San Diego (1982) 32 Cal. 2d 798, 802 ; Miro v. Superior Court (1970) 5 Cal. 568.) PECG is a big supporter of STEM/STEAM programs, including science and engineering fairs, all over the state. Gregg v. Georgia (1976) 428 U.S. 153, 184-186 [96 S. Ct. 2909, 2930-2931, 49 L. Ed. 2015-12-21, 10:17 AM - Flash Flood in the Northern California, Sacramento and Placer Counties until 12:15 PM. 2d 126, 134-136 [69 P.2d 985, 111 A.L.R. 4.) 3d 840, 844 [245 Cal. 592-593; Williams, supra, 7 Cal.App.3d at pp. FN 10. 1209 (1993-1994 Reg. 844. All applicants are required to supply the Board with a full set of fingerprints upon submittal of an application for licensure/certification. [Citations.]" In my view, the majority err by presuming not that the Legislature intended its enactment to be consistent with the purposes of article VII, but that it intended its enactment as a way to circumvent the limitations which have been judicially imposed to implement that constitutional mandate. Remarks. To the extent Chapter 433's provisions conflict with the civil service mandate, they are invalid. Although the Court of Appeal majority concluded that Chapter 433 alone justified dissolution of the 1990 injunction, we disagree, believing the principles announced in prior case law require a contrary holding. Greg's diverse project experience includes: * Coastal and Port Structures, * Bridges and Culverts, * Buildings, * Mining Infrastructure Processing Structures and Equipment (EPC), and<br>* Subsea.<br><br>His key . (See Burum v. State Compensation Ins. The 2022 California Building Code will be implemented on the 2024 Civil Seismic Principles Exam. Thus, the Legislature's determination of the facts warranting its action " 'must not be set aside [15 Cal. 487, 624 P.2d 1215] [holding that the State Employer-Employee Relations Act did not conflict with article VII or the merit system mandate].) Review all applicable laws and regulations to confirm that you meet the qualifying experience requirements before you submit an application to the Board. Rptr. Subdivision (b) of that section expressed the legislative intent to allow Caltrans to contract privately for professional and technical services "whenever the department is inadequately staffed to satisfactorily carry out its program [of project development] in a timely and effective manner.". The Court of Appeal majority recognized that the foregoing conclusion is "illogic[al]," in that it states the tautology that private contracting is necessary to avoid private contracting. App. 572-574.). Further, judicial notice of findings of fact does not mean that those findings of fact are true, but, rather, only means that those findings of fact were made. ", The dissent reviewed the history of the proceedings in this case and observed that, "[u]nable to make headway with the judicial branch's tiresome requirement that Caltrans produce evidence that contracting out was warranted as cheaper or more efficient, Caltrans sought a sanction from the Legislature for its practice of contracting out. ), This statement is an evolution of Stevenson v. Colgan (1891) 91 Cal. Information for Military Personnel and Their Spouses/Domestic Partners, UPDATED FEBRUARY 22, 2023 The Civil Seismic Principles Exam will continue to test on the 2019 California Building Code for the remainder of 2023. Fund v. Riley (1937) 9 Cal. Finally, the majority's determination that Chapter 433 is unconstitutional on its face unreasonably and improperly encroaches upon the prerogative of the legislative branch of government, thereby interfering with the separation of powers. ]; Gov. FN 10. ], "Secondly, all intendments favor the exercise of the Legislature's plenary authority: 'If there is any doubt as to the Legislature's power to act in any given case, the doubt should be resolved in favor of the Legislature's action. (a).) In re Harris (1989) 49 Cal. (See CSEA, supra, 199 Cal.App.3d at pp. As we recognized back then, the party challenging the legislation bears a "heavy burden" in demonstrating that its provisions "inevitably pose a present total and fatal conflict with applicable constitutional prohibitions." 2d 126 [69 P.2d 985, 111 A.L.R. Third, the court found that Caltrans's revised plan for contracting activity during 1993-1994 was contributing to the displacement of permanent, temporary, and part-time civil service staff. 2d 814, 884 P.2d 645] (referendum of county employee compensation); People v. Hansel (1992) 1 Cal. on Transportation, Rep. on Sen. Bill No. The implication of an "economic savings" requirement is inherent in a common-sense reading of Chapter 433. "[W]herever possible, [this court] will interpret a statute as consistent with applicable constitutional provisions, seeking to harmonize Constitution and statute. 141, 728 P.2d 211] (statute permitting admission of written statements in lieu of non-eyewitness testimony at preliminary hearings); People v. Superior Court (Engert) (1982) 31 Cal. [1], In 1978, PECG fought for and won the exclusive right to represent engineers and related classes (architects, landscape architects, land surveyors, environmental specialists, engineering geologists, etc. Professional Engineer: Employees providing engineering, design, research, and related analytical information regarding structures such as highways, bridges, dams, and water treatment plants. App. of Kennedy, J. According to the court, Caltrans was displacing civil service staff from project development work that staff had historically performed and was maintaining staff at an inadequate level to create an artificial need for private contracting. [Citations.]" As the Court of Appeal majority recognized, these provisions, though somewhat inartfully drafted, seem aimed at authorizing Caltrans's private contracting and circumventing the trial court's injunction and subsequent enforcement orders. (Fn. Early on the California Supreme Court recognized that the civil service provisions will not work if the merit appointment system can be circumvented by simply contracting out civil service jobs. 1209 (1993-1994 Reg. fn. As previously explained, the Legislature's factual determinations may be set aside or disregarded by the courts only if the fact of error " 'appears beyond reasonable doubt from facts or evidence which cannot be controverted, and of which the courts may properly take notice.' As the court observed, "Pursuant to the [new] provisions, [Caltrans] may calculate [its] civil service staffing needs without considering the full workload to be performed, may limit [its] procurement of civil service staff regardless of actual staffing needs or ability to productively use new staff, and [is] required to reinstate contracts for the purpose of fostering employment and business opportunities without regard to the constitutional civil service mandate. In addition to authorizing increased contracting flexibility until January 1, 1998, Chapter 433 contains an uncodified section which requires Caltrans and the Legislative Analyst to coordinate in the preparation of a [15 Cal. Co. v. Wilson (1995) 11 Cal. Rptr. 3d 390, 397 [86 Cal. We conclude that Riley and its progeny are consistent with article VII's civil service mandate. (Amwest Surety Ins. I note, as did the Court of Appeal, the arguable illogic of a portion of the finding contained in section 14130, subdivision (a)(4), that "Without the ability to continue a stable contracting out program, the department will not be able to perform project delivery adequately, competently, or satisfactorily, thereby necessitating the use of private consultants to supplement its in-house staff." (CSEA, supra, 199 Cal.App.3d at p. (a)(3), 14130.1, subd. Code, former 14132.1 [contracts of $250,000 or less]; Gov. 1.) 4th 1243, 1252 [48 Cal. Caring for the world, one person at a time has inspired and united the people . 116, 758 P.2d 58].) Eric M. Moberg v. Contra Costa Community College District, Folsom-Cordova Education Association v. Folsom-Cordova Unified School District, Victor Valley Teachers Association v. Victor Valley Union High School District, Jennifer Koontz v. Pasadena Area Community College District, Service Employees International Union Local 1021 v. County of Alameda, University Professional and Technical Employees CWA Local 9119 v. Regents of the University of California, California Federation of Interpreters, Local 39000 TNG-CWA v. Orange County Superior Court, David Southcott v. Julian-Cuyamaca Fire Protection District, California Federation of Interpreters, Local 39000 TNG-CWA v. Region 3 Court Interpreter Employment Relations Committee, C. L. Felicijan & W. Hetman v. Santa Ana Educators Association, American Federation of State, County & Municipal Employees Local 3947 v. City of Compton, Philip Stephen Fay v. Tahoe-Truckee Sanitation Agency, Service Employees International Union Local 1021 v. Alameda Health System, California School Employees Association-Chapter 348 v. South Whittier School District, Union of American Physicians & Dentists v. State of California (California Correctional Health Care Services), Christine L. Felicijan v. Santa Ana Unified School District, Woodville Teachers Association, CTA/NEA v. Woodville Union School District, Terrell Emanuel Turner v. Long Beach Unified School District, Joseph E. Knighten, Sr. v. Painters & Allied Trades, District Council 16, International Brotherhood of Electrical Workers Local 465 v. Imperial Irrigation District, University Professional & Technical Employees Communication Workers of America Local 9119 v. Butte-Glenn Community College District, Grossmont Cuyamaca Community College District Administrators Association v. Grossmont-Cuyamaca Community College District, Newport-Mesa American Federation of Teachers, Local 1794 v. Newport-Mesa Unified School District, Santa Paula Police Officers Association v. City of Santa Paula, Service Employees International Union Local 1000 v. State of California (Department of Corrections and Rehabilitation and California Correctional Health Care Services), Coachella Valley Water District Employee Association v. Coachella Valley Water District, Service Employees International Union, Local 521 v. Kern County Hospital Authority, International Union of Operating Engineers Local 501 v. State of California (Department of Transportation), International Federation of Professional & Technical Engineers, Local 21, AFL-CIO v. City & County of San Francisco, Service Employees International Union Local 1021 v. City & County of San Francisco.
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