Plaintiff employees association challenged the decision of the Superior Court of Los Angeles County (California), which upheld a memorandum between plaintiff and defendant city. The trial court admitted parol testimony of negotiators to aid in the interpretation of the memorandum’s provisions.

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Overview

The court reversed the decision of the trial court. The trial court held, admitting parol testimony of negotiators, that a memorandum between plaintiff employees association and defendant city was binding. City claimed that the memorandum was not binding, that the trial court erred in its interpretation of the memorandum, and that in any event the memorandum could not be enforced writ of mandamus. City also argued that the suit was not a proper class action, and that relief was barred a failure to exhaust administrative remedies. The court held that the agreement entered into under the Meyers-Milias-Brown Act (Act), Cal. Gov’t. Code § 3505.1, and approved the governing board of the local entities bound city and employees association. The court concluded that a salary ordinance did not meet the proper criteria, and that the failure of city to pay salaries in excess of the arithmetic average of surveyed jurisdictions constituted an abuse of discretion and a breach both of the memorandum of understanding and of the city’s duty under the Act.

Outcome

The court reversed the decision of the trial court that held, admitting parol evidence, that a memorandum between plaintiff employees association and defendant city was binding. The failure of city to pay salaries in excess of the arithmetic average of surveyed jurisdictions constituted an abuse of discretion and a breach both of the memorandum of understanding and of city’s duty under statute.