Boling v. Public Employment Relations Bd.

**City Must Negotiate with Unions Before Pension Changes** This case involved the City of San Diego advancing a pension reform ballot initiative without first negotiating with employee unions, as required by California's public sector labor law (the Meyers-Milias-Brown Act). The California Court of Appeal ruled that the city violated the law by failing to meet and discuss the pension changes with unions before moving forward with the initiative. However, the court took a balanced approach to the remedy. While it confirmed the city broke the law, it refused to invalidate the voter-approved initiative itself, recognizing that doing so would interfere with the democratic process and constitutional principles. Instead, the court ordered the city to negotiate with unions about the effects of the pension changes and to compensate affected employees for any harm caused by the improper process. **What this means for workers:** Public sector employees have the right to union representation in negotiations over major workplace changes, including pension reforms. Even when employers want to take issues directly to voters, they must first engage in good-faith discussions with employee unions. While courts will protect these negotiation rights, they may limit remedies to avoid overturning legitimate election results.