Riverside Sheriff's Assn. v. County of Riverside

In Riverside Sheriff's Assn. v. County of Riverside (2003) 106 Cal.App.4th 1285, in determining that the County's denial of step increases to employees was not the type of action subject to the MMBA, the court cited the principle embodied in Government Code section 3504.5 that a public agency's governing body must "'give reasonable written notice to each recognized employee organization affected of any ordinance, rule, resolution, or regulation directly relating to matters within the scope of representation proposed to be adopted by the governing body . . . .'" (Riverside Sheriff's Assn., supra, at pp. 1289-1290.) By its own terms, the Government Code provision requires a public entity to give notice of actions that have a significant effect on wages, hours and other terms and conditions of employment. (Riverside Sheriff's Assn., supra, at p. 1290.) It does not require the public agency to provide notice of the terms and conditions of the MMBA itself.