County of Los Angeles v. Los Angeles County Employee Relations Commission, 56 Cal. 4th 905

SEIU is the exclusive bargaining representative for Los Angeles County employees under MMBA provisions and county MOUs include agency shop arrangements affecting nonmembers.
HUDSON notices require nonmembers to disclose name, home address, and home phone when paying fair share or dues; SEIU has historically received such notices via ERCOM without home addresses.
County historically provided nonmember data excluding home addresses/phones; SEIU sought home addresses/phones for all represented employees to facilitate notices and union activities.
SEIU proposed amendments in 2006 to require the County to furnish names and home addresses annually to SEIU for Hudson notices and outreach; County refused, arguing privacy concerns.
ERCOM ordered disclosure following an administrative proceeding; County sought writ of mandate; trial court balanced privacy against union duties and upheld disclosure; Court of Appeal remanded with an imposed notice/opt-out procedure.
California Supreme Court reverses, holding that SEIU is presumptively entitled to home addresses and phone numbers, subject to privacy balancing and potential nonmember safeguards, and that the Court of Appeal exceeded its authority by imposing procedural safeguards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether SEIU may obtain home addresses and phone numbers of all represented employees	SEIU argues information is presumptively relevant for representation.	County argues privacy interests bar disclosure.	Disclosure required; information presumptively relevant.
Whether privacy rights under Cal. Const. art. I, § 1 bar disclosure	Privacy should be weighed against union duties and disclosure is needed for representation.	Privacy interests protect nonmembers from disclosure.	Privacy balanced in favor of disclosure, with possible safeguards.
Whether the Court of Appeal could impose procedural safeguards (notice/opt-out)	Procedural safeguards are appropriate to protect privacy.	Court cannot impose new procedures in a mandate review; decisions should leave discretion to ERCOM.	Court of Appeal exceeded its authority; safeguards may be developed through bargaining or agency rules.
Whether MMBA/ PERB precedents require disclosure of contact information	Precedents compel disclosure as part of good-faith bargaining and representational duties.	Disclosures should be limited by privacy and statutory interpretation.	MMBA requires disclosure; PERB/NLRA-inspired precedents support it.

NLRB v. Acme Industrial Co., 385 U.S. 432 (1967) (employer must provide information needed by bargaining representative)
NLRB v. Wyman-Gordon Co., 394 U.S. 759 (1969) (disclosure to unions supports fair access to information)
Excelsior Underwear, Inc., 156 NLRB 1236 (1966) (presumptive relevance of names/addresses for union organizing)
Carian v. Agricultural Labor Relations Bd., 36 Cal.3d 654 (1984) ( Cal. Supreme Court extends disclosure to organizing context)
Prudential Insurance Co. v. N.L.R.B., 412 F.2d 77 (2d Cir. 1969) (union must communicate with employees to administer contract)
San Diego Newspaper Guild, Local No. 95 v. NLRB, 548 F.2d 863 (9th Cir. 1977) (presumptive relevance and need for information to bargaining)
Pioneer Electronics (USA) Inc. v. Superior Court, 40 Cal.4th 360 (2007) (privacy notice akin to class-action context with safeguards)
Hill v. National Collegiate Athletic Assn., 7 Cal.4th 1 (1994) (Hill balancing framework for privacy rights)
Belaire-West Landscape, Inc. v. Superior Court, 149 Cal.App.4th 554 (2007) (limits on disclosure balancing where privacy interests exist)
Golden Empire Transit Dist., 74 Cal.App.4th 1 (2004) (public policy favors disclosure to unions absent compelling privacy needs)