GGNSC Springfield LLC v. Nat'l Labor Relations Bd., No. 12-1628 (6th Cir. 2013)
Annotate this CaseThe Center, a licensed nursing home in Springfield, Tennessee, has about 100 employees, providing care to about 120 residents. An executive director oversees the facility, assisted by department heads, including a director of nursing for each of the facility’s two wings. There are 12 RNs, 10 licensed practical nurses (LPNs), and 46 certified nursing assistants (CNAs). RNs and LPNs, called “charge nurses,” report to the director of nursing. Two charge nurses are generally assigned to each wing at a time. The Union petitioned the NLRB, seeking to represent the RNs in collective bargaining. The Center objected, claiming that the RNs were “supervisors” under the Act, not permitted to unionize, 29 U.S.C. 152(3), 157. The regional director concluded that the RNs were not supervisors, certified the bargaining unit, and directed an election. The next day, the RNs elected the Union as their bargaining representative. The Center refused to bargain with the Union, which filed a complaint of unfair labor practices. The Board sustained the Union’s complaint and ordered the Center to bargain. The Sixth Circuit vacated and denied a petition for enforcement, finding that the the RNs have authority to discipline CNAs using their independent judgment and are supervisors.
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