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New York University Medical Center and Association of Staff Psychiatrists, Bellevue Psychiatric Hospital

National Labor Relations Board
324 N.L.R.B. No. 139 (1997)


Facts

The Association of Staff Psychiatrists (Association) (plaintiff) is a labor organization, though it is not considered a union. Its members include staff psychiatrists provided by the New York University Medical Center (NYUMC) (defendant) to the Bellevue Psychiatric Hospital for the purposes of providing mental health services to the community. Due to budget constraints, NYUMC’s director of psychiatry, Dr. Trujillo, stated that it was going to change its policy requiring the psychiatrists at Bellevue to work longer hours or take a decrease in salary. The psychiatrists and members of the Association protested. In response to the protests, NYUMC and Trujillo reorganized the psychiatric department and terminated ten psychiatrists, including six who were executive members of the Association. Trujillo stated further penalties would be issued on opponents of the six-hour day work schedule. NYUMC argues that Trujillo’s statements were merely warnings that a failure to resolve the six-hour day schedule would cause more budgetary problems and layoffs. The six terminated members of the association (plaintiffs) filed charges of unfair labor practice with the National Labor Relations Board against the NYUMC.

Rule of Law

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Issue

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Holding and Reasoning (not provided)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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