Salem Police Employees Union v. City of Salem

The City of Salem (City) seeks judicial review of an order of the Employment Relations Board (ERB) holding that City committed an unfair labor practice when it refused to bargain with the Salem Police Employees Union (Union) over a proposed reserve police officer program adopted by City. We affirm.

The underlying facts are not disputed. Union’s bargaining unit consists of approximately 105 officers, 78 of whom work in the patrol section. Patrol officers usually patrol alone and are responsible for policing the streets, enforcing laws and preventing crime. The number of sworn officers has…