SANTA CLARA VALLEY TRANSPORTATION AUTHORITY v. JOHN M. REA
Filed 6/28/06
CERTIFIED FOR PUBLICATION
IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
SIXTH APPELLATE DISTRICT
| SANTA CLARA VALLEY TRANSPORTATION AUTHORITY, Plaintiff and Respondent, v. JOHN M. REA, as Director, etc. et al., Defendants and Appellants; | H028841 (Santa Clara County Super. Ct. No. 1-03-CV006149) |
| AMERICAN FEDERATION OF STATE, COUNTY, AND MUNICIPAL EMPLOYEES, LOCAL 101, AFL-CIO, Real Party in Interest and Appellant. |
I. Introduction
The issue in this case is whether state law requires the Santa Clara Valley Transportation Authority (VTA) to bargain with a certain labor union when the bargaining unit the union represents includes supervisory and management personnel. Resolution of the issue turns upon interpretation of two arguably contradictory sections of the Public Utilities Code.[1] Section 100301 states that all questions relating to the collective bargaining rights of VTA employees are to be resolved by application of relevant provisions of the federal Labor Management Relations Act of 1947 (29 U.S.C. § 141 et seq.) (LMRA). Section 100309 applies to a subset of employees who transferred to VTA from other public entities in 1995 as a result of reorganizing legislation. This section requires VTA to recognize the employee organizations that represented the transferring employees immediately prior to their employment by VTA. The apparent contradiction between the two code sections is that under the LMRA, an employer may not be compelled to bargain with supervisors and managers, but section 100309 appears to require VTA to bargain with a group of supervisory and managerial employees that transferred to VTA in 1995.
We conclude that section 100309, the more recent and more specific of the code sections, granted collective bargaining rights to the entire subset of employees involved in the 1995 reorganization regardless of their position in the employment hierarchy.
II. The Statutory Context
Analysis of the problem before us requires reference to three separate labor relations schemes. First, there is VTA's scheme. In 1969, the Legislature passed the Santa Clara County Transit District Act (§ 100000 et seq.) (the Act), which created the transit district now known as VTA. (See § 100002.) The Act is one of a number of different acts governing transit districts around the state. (See, e.g., §§ 25051 et seq. [Alameda-Contra Costa Transit District]; 28850 et seq. [San Francisco Bay Area Rapid Transit District]; 30750 et seq. [Los Angeles County Metropolitan Transportation Authority]; 40120 et seq. [Orange County Transit District]; 98160 et seq. [Santa Cruz Metropolitan Transit District].) Each of the transit acts contains its own labor relations provisions.
Section 100300 is the Act's grant of collective bargaining rights: â€
