San Clemente Ranch V. Agricultural Labor Relations Board

This case arises out of the same factual setting as Highland Ranch v. Agricultural Labor Relations Bd., (1981) ante, page 848 [176 Cal. Rptr. 753, 633 P.2d 949]. Unlike Highland Ranch, however, this case concerns the obligations under the Agricultural Labor Relations Act (ALRA) incurred by San Clemente Ranch, Ltd. (San Clemente or employer) upon purchasing and subsequently undertaking the farming operation previously run by Highland. After examining all of the circumstances surrounding both the change in ownership and San Clemente's commencement of its business operation, the Agricultural Labor Relations Board (ALRB or Board) concluded that San Clemente should properly be considered a "successor employer" to Highland. It held that San Clemente succeeded, inter alia, to Highland's obligation to recognize and bargain with the United Farm Workers of America, AFL-CIO (UFW or union), the union that was officially certified as the exclusive bargaining representative of Highland's agricultural employees on virtually the same date that San Clemente assumed control of the farming operation. San Clemente now objects to the ALRB's conclusion, maintaining that the Board's successorship determination in this case is inconsistent with the governing federal successorship precedents under the National Labor Relations Act (NLRA).