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Sacramento County Employees Organization v. County of Sacramento

Citations: 201 Cal. App. 3d 845; 247 Cal. Rptr. 333; 1988 Cal. App. LEXIS 491Docket: C000506

Court: California Court of Appeal; May 27, 1988; California; State Appellate Court

Narrative Opinion Summary

In the case of Sacramento County Employees Organization v. County of Sacramento, the central issue was whether court employees in California are entitled to collective bargaining rights under the Meyers-Milias-Brown Act (MMBA). The Sacramento County Employees Organization (SCEO) sought to compel the County of Sacramento to negotiate employment terms under the MMBA. The court determined that court employees, including court reporters and clerks, are not covered by the MMBA as they are classified as court employees, not county employees. This distinction was affirmed by examining factors such as who appoints and supervises the employees. The court further clarified that the MMBA applies only to local governmental entities and their employees, excluding the judiciary. Therefore, superior courts are not considered public agencies under the MMBA, and their employees do not have collective bargaining rights under this statute. The judgment upheld the trial court's decision, affirming that municipal court employees in Sacramento lack bargaining rights under the MMBA. The case highlights the legislative intent to exclude court personnel from the bargaining rights intended for local government employees under the MMBA, reinforcing the separation between the judiciary and local governmental entities.

Legal Issues Addressed

Applicability of the Meyers-Milias-Brown Act to Court Employees

Application: The court determined that employees working in California courts are not entitled to collective bargaining rights under the MMBA, as they are considered court employees rather than county employees.

Reasoning: The court concludes that the employees in question are court employees and not subject to MMBA protections, affirming the trial court's judgment.

Classification of Employees as County or Court Workers

Application: The court applied various factors to determine that employees supervised by the court executive officer are court employees, while courtroom clerks appointed by the county clerk are county employees.

Reasoning: In the case examined, employees were determined to be court employees as they were supervised by the court executive officer, appointed under statutory authority, exempt from civil service, and served at the court's pleasure, despite salary payments and benefits from the county.

Definition of Public Agencies Under the MMBA

Application: The court affirmed that superior courts do not qualify as public agencies under the MMBA, and thus their employees do not have the right to bargain collectively under this act.

Reasoning: Superior courts are part of the state judiciary, exercising state judicial power and not functioning as local government entities. Precedents confirm that superior courts do not qualify as public agencies under the MMBA.

Legislative Intent Regarding Bargaining Rights

Application: The court found that the Legislature did not intend for employees under the exclusive control of the court to have bargaining rights with the county.

Reasoning: The Legislature did not intend for employees under the exclusive control of the court to negotiate working conditions with the county, as they are appointed by the court and not allowed to join civil service.

Municipal Court Employees' Bargaining Rights

Application: The court held that Sacramento Municipal Court employees lack bargaining rights under the MMBA as they are not considered county employees.

Reasoning: Consequently, Sacramento Municipal Court employees lack bargaining rights under the MMBA.