Wash. State Nurses Ass'n v. Sacred Heart Med. Ctr.
Annotate this CaseWashington State Nurses Association (WSNA) sought overtime pay pursuant to the Minimum Wage Act (MWA) for work performed by the approximately 1,200 registered nurses employed by Sacred Heart Medical Center in Spokane. Sacred Heart was obligated by its collective bargaining agreement (CBA) with WSNA to provide its nurses with a paid 15 minute block rest period each four hour work period. The parties did not dispute that when a rest period was missed, Sacred Heart provided the nurses with the equivalent of 30 minutes of straight time compensation: the 15 minutes they would have received had they merely rested as well as 15 additional minutes for instead working during the period. Relying on a Washington industrial welfare regulation requiring a 10 minute rest period on the employer's time for every four hours worked, the nurses claimed they were entitled to overtime pay, not just the straight pay they already received, for 10 of the 15 minutes of each rest period they missed. The issue before the Supreme Court hinged on how "hours worked" are calculated: whether the 15 minutes nurses spent working through their breaks should be added to or substituted for the 15 minutes they would have spent at rest. The Court held that both the missed opportunity to rest and the additional labor nurses provide constitute "hours worked." Even though Sacred Heart did not require the nurses to physically remain at the hospital after the end of the workday to make up their rest periods, nurses were entitled to overtime compensation because they provided additional labor to Sacred Heart.
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