County of Los Angeles v. Los Angeles County Employee Relations Comm'n, 56 Cal. 4th 905 (2013)

During the course of collective bargaining, the Service Employees International Union ("SEIU") asked the county for the personal contact information (names, home addresses and home telephone numbers) of county employees who are in the bargaining unit but who are not members of the union. When the county refused to disclose that information based on the employees' right to privacy, the union filed an unfair employee-relations practice charge with the Los Angeles County Employee Relations Commission. The Commission agreed with the union and ordered the county to release the information. The trial court upheld the Commission's decision but on different grounds, and the court of appeal considered the non-members' state constitutional right to privacy, reversed the trial court's order and remanded with directions to the trial court to enter a new order directing the county and union to meet and confer on a proposed notice to non-member county employees that included an opportunity for them to object to disclosure. In this opinion, the California Supreme Court reversed the court of appeal's decision, holding that SEIU's interest in communicating with all county employees (including those who are not represented by the union) significantly outweighs non-members' interest in preserving the privacy of their contact information – however, the Supreme Court reversed the court of appeal's order attempting to impose specific notice and opt-out procedures as part of the disclosure process.