Language in a memorandum of understanding between a city and labor union did not confer a vested right to fully-paid retiree medical premiums where the term of the agreement was finite. The subjective understandings of individuals, as well as understandings communicated outside the MOU approval process, are not admissible as evidence of the city's intent. A city's history of paying the full cost of retiree medical premiums does not imply a right that such payments will continue, absent a showing of legislative intent. A city's refusal to change its position as to the amount it was willing to contribute towards retiree medical premiums does not in itself constitute surface bargaining. City also did not rush to declare an impasse where it engaged in negotiations for over a year and both parties were committed to their respective positions on the primary issue of contention between them.
Vallejo Police Officers Association v. City of Vallejo - filed Aug. 22, 2017, publication ordered Sept. 21, 2017, First District, Div. Two
Cite as 2017 S.O.S. 4734
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