Oakwood Healthcare, Inc. v. International Union, United Automobile, Aerospace and Agricultural Implement Workers of America

The National Labor Relations Board (NLRB) ruled in this case that Oakwood Healthcare, Inc. improperly designated rotating charge nurses as supervisors. The ruling defines the types of supervisory activity in a nursing setting that will be considered as managerial. A nurse who regularly performs activities that exercise independent judgment to direct other workers will be considered a manager, and thus lose eligibility to form or participate in union activities or negotiations.

The NLRB states that a rotating charge nurse who does not consistently perform supervisory duties should not be counted as managerial personnel. This decision covers cases in which registered nurses in an organization at times take turns as charge nurses and use independent judgment to assign other nurses to specific duties. In this situation, a nurse who does not normally perform supervisory duties should considered as non-supervisory personnel.