Carian V. Agricultural Labor Relations Board

Harry Carian (Carian) and Richard Peters Farms (Peters), both agricultural employers covered by the Agricultural Labor Relations Act (ALRA) (Lab. Code, § 1140 et seq.),*fn1 seek review of decisions by the Agricultural Labor Relations Board (ALRB or board) finding that each of them committed certain unfair labor practices, and ordering remedies therefor. The Court of Appeal for the Fourth District granted their respective petitions for review, and in both cases reversed in part the board's determinations. We granted hearing in order to consider significant issues common to both proceedings. The two proceedings have been consolidated for purposes of argument and decision.