Public Case No. R 1975-102
Golden Valley Registered Nurses Association v.
Golden Valley Memorial Hospital, Clinton, Missouri
Golden Valley Registered Nurses Association filed a petition for certain Registered Professional Nurses employed by Golden Valley Memorial Hospital. The original hearing was held April 23rd and May 10th, 1975. In Golden Valley Memorial Hospital v. Missouri State Board of Mediation, 559 S.W.2d 581 (Mo.App. 1977) the court remanded the case and directed the Board to resolve the issue of supervisory status of nurses. The Association asserted that all nursing positions below that of Director of Nursing are employees within the meaning of §105.510 RSMo 1978, and have a community of interest which justifies inclusion in the bargaining unit. The hospital contends that a number of the RN’s are supervisors and should be excluded.
The Board found that the Assistant Director of Nursing was a supervisor based on the fact that she assists in formulating hospital policies and plays a significant role in personnel decisions.
The Board also excluded House Supervisor based on the independent judgment they exercised in directing and assigning the workforce. The Board declined to exclude the Relief House Supervisors, since they spent most of their time as Staff Nurses.
The Board declined to exclude Head Nurses. They noted that HN’s had little authority over personnel decisions. They said that the fact that they directed and assigned the workforce did not, in itself, constitute supervisory status. The HN is never the highest ranking authority in the hospital, since House Supervisors are always present. HN are paid at an hourly rate, unlike the other supervisors.
The Board found the duties of OB Supervisors or OR Supervisors to be similar to those of the Head Nurse, and declined to exclude them for the same reasons. The Board also declined to exclude the Circulating Nurse in Surgery, since the position is subordinate to the OR Supervisor. The Board also declined to exclude the ICU Assistant Head Nurse and Staff Nurses for the same reason.
Date Issued:July 14, 1980