Washington State Nurses Ass'n v. Sacred Heart Medical Center
287 P.3d 516
Wash.2012Background
- WSNA seeks overtime pay under the Minimum Wage Act for ~1,200 Sacred Heart nurses in Spokane.
- Sacred Heart’s CBA required a paid 15-minute rest period every four hours; if a rest was missed, nurses received 30 minutes straight-time compensation.
- Nurses argue missed 10-minute rest periods should be paid as overtime under RCW 49.46.130; Wingert governs extending the workday for missed breaks.
- Court held both missed rest and the additional labor count as hours worked, entitling overtime for the first 10 minutes of each missed break.
- Trial court damages, attorney fees, and costs were awarded to WSNA; double damages were reversed; issues included whether a bona fide dispute existed and the proper interpretation of the CBA under the MWA.
- Court conducted de novo review on legal questions, with dispute centered on whether WAC 296-126-092(4) and MWA overtime apply to missed rest periods.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are missed rest periods hours worked under the MWA? | WSNA argues missed breaks extend hours and warrant overtime. | Sacred Heart maintains missed breaks only require straight pay per IWA; no overtime under the MWA. | Yes; missed rest periods constitute hours worked warranting overtime. |
| Does Wingert determine the remedy for missed breaks under the MWA? | Wingert supports overtime for missed breaks. | Wingert applies to IWA remedies, not the MWA; straight pay suffices. | Wingert supports overtime for missed breaks under the MWA. |
| Do rest periods and time worked through breaks extend the nurse’s workweek for O/T purposes? | Both the 0.25 hour rest and 0.25 hour labor through the break count as hours worked. | Rest time can be compensated straight-time; overtime not triggered unless weekly hours exceed 40. | Yes; both components extend hours worked, triggering overtime under RCW 49.46.130. |
| Was there a bona fide dispute negating willfulness for double damages? | Sacred Heart’s interpretation of the CBA was not willful deception. | There was a fair, debatable dispute about proper wage treatment. | A bona fide dispute existed; no willful deprivation proven. |
| Are attorney fees and costs properly awarded to WSNA? | WSNA sought fees under RCW 49.52.070 and 49.46.090(1). | N/A or objecting to additional fee bases. | Attorney fees and costs affirmed. |
Key Cases Cited
- Wingert v. Yellow Freight Systems, Inc., 146 Wn.2d 841 (Wash. 2002) (missed 10-minute break extends workday; overtime may be due under IWA)
- Champagne v. Thurston County, 163 Wn.2d 69 (Wash. 2008) (fairly debatable wage dispute; compliance with CBA does not prove willfulness)
- Morgan v. Kingen, 166 Wn.2d 526 (Wash. 2009) (bona fide dispute exception to willfulness on wage withholding)