Lincoln County Education Ass'n v. Lincoln County School District

The Lincoln County Education Association (association), a school employees’ union, filed a complaint with the Employment Relations Board (ERB), accusing the Lincoln County School District (district) of committing an unfair labor practice when, during the period after one collective bargaining agreement had expired but before another had begun, the district unilaterally increased the number of student contact hours required of teachers in three middle schools. The association contended that the increase was a per se refusal to bargain because it unilaterally changed the status quo with respect…