Boston Medical Center Corp.

330 N.L.R.B. 152 (1999)

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Boston Medical Center Corp.

National Labor Relations Board
330 N.L.R.B. 152 (1999)

Facts

Boston Medical Center Corp. (BMC) was a teaching university associated with the Boston University School of Medicine. After finishing medical school, students would intern as either residents or fellows (collectively called house officers) at a hospital to become certified specialists in their chosen fields. After one year as interns, house officers took a licensing exam, and passing the exam allowed them to be considered full doctors. They often continued as house officers for three to four more years after that point. House officers often moonlighted at other medical facilities after passing the exam. They treated patients with increasing levels of independence as they progressed through the program. They were compensated with stipends, though not with all the benefits provided to staff doctors. House officers typically worked very long hours at their chosen hospitals. They attended lectures on topics related to their chosen medical specialties but did not take any other tests besides the licensing exam, were not given grades, and did not pay tuition or other student fees. House officers of BMC sought a determination that the National Labor Relations Board (NLRB) had jurisdiction over them and that their collective bargaining was therefore protected.

Rule of Law

Issue

Holding and Reasoning ()

Dissent (Brame, J.)

Dissent (Hurtgen, J.)

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