The Health and Hospital Systems of the County of Cook v. Illinois Labor Relations Board

2015 IL App (1st) 150794, 49 N.E.3d 518
CourtAppellate Court of Illinois
DecidedDecember 31, 2015
Docket1-15-0794
StatusUnpublished
Cited by1 cases

This text of 2015 IL App (1st) 150794 (The Health and Hospital Systems of the County of Cook v. Illinois Labor Relations Board) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Health and Hospital Systems of the County of Cook v. Illinois Labor Relations Board, 2015 IL App (1st) 150794, 49 N.E.3d 518 (Ill. Ct. App. 2015).

Opinion

2015 IL App (1st) 150794 No. 1-15-0794 Fifth Division December 31, 2015 ______________________________________________________________________________

IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________

) THE HEALTH AND HOSPITAL SYSTEM OF THE ) COUNTY OF COOK, ) ) Petitioner, ) ) v. ) Petition for Administrative ) Review of a Decision and Order ILLINOIS LABOR RELATIONS BOARD, LOCAL ) of the Illinois Labor Relations PANEL; ROBERT M. GIERUT, Chairman; CHARLES ) Board, Local Panel. E. ANDERSON, Member; RICHARD A. LEWIS, ) Member; MELISSA MLYINSKI, Executive Director; ) No. L RC 14 009 and LOCAL 200, CHICAGO JOINT BOARD, RETAIL, ) WHOLESALE and DEPARTMENT STORE UNION, ) AFL-CIO, ) ) Respondents. ) ) ______________________________________________________________________________

JUSTICE GORDON delivered the judgment of the court. Presiding Justice Reyes and Justice Lampkin concurred in the judgment.

OPINION

¶1 The Health and Hospital System (HHS) of the County of Cook (the County), petitioner,

appeals from a final order of the Illinois Labor Relations Board (the Board), granting Local

200, Chicago Joint Board, Retail, Wholesale and Department Store Union, AFL-CIO’s (the

Union’s) petition to add ten recruiting positions to the existing bargaining unit. We affirm. No. 1-15-0794

¶2 The sole issue in this appeal is whether ten recruitment and selection analysts (RSA)

employed by a county hospital system are “confidential employees” as that term is defined in

section 3(c) of the Illinois Public Labor Relations Act (Act) (5 ILCS 315/3(c) (West 2012)).

The Act permits public employees to organize, but it excludes confidential employees from

the collective bargaining unit. 5 ILCS 315/3(n) (West 2012).

¶3 The petitioner on appeal is the County. In its petition, the County challenged the Board’s

finding that RSAs, who are county employees, are not confidential employees. It is this

decision that the County asks us to review. Respondents are: (1) the Board; and (2) the

Union.

¶4 BACKGROUND

¶5 This case is a direct administrative review action from an order of the Board. The order

granted the Union’s majority interest representation petition, which sought to add the ten

RSA positions at Stroger Hospital, an affiliate HHS, to the existing bargaining unit.

¶6 The Union filed its initial petition with the Board on April 2, 2014. The County filed a

response opposing the petition, arguing that RSAs were prohibited by statute from joining the

Union both as “confidential employees” as defined under section 3(c) of the Act, as well as

“supervisors” under section 3(r) (5 ILCS 315/3(c), (r) (West 2012)). After an evidentiary

hearing, an administrative law judge (ALJ) issued a recommended decision, finding that

RSAs are neither confidential employees nor supervisors under the Act. Subsequently, the

Board adopted the ALJ’s findings in a written “Decision and Order,” and granted the Union’s

petition to add RSAs to the bargaining unit.

¶7 The County does not contest the Board’s finding that RSAs are not supervisors and, thus,

at issue in this appeal is only whether RSAs are confidential employees. Accordingly, the

2 No. 1-15-0794

facts below are limited to those relevant to determining whether RSAs are confidential

employees. As we discuss later in the analysis, confidential employees are those employees

(1) who assist management with respect to labor-relations policy; or (2) who have access to

collective bargaining information. 5 ILCS 315/3(c) (West 2012).

¶8 I. The Administrative Hearing

¶9 On July 18, 2014, an administrative law judge (ALJ) held a hearing to determine whether

the ten RSAs were confidential or supervisory employees within the meaning of the Act, and

were therefore prohibited from collective bargaining. During the hearing, the parties

presented the following evidence relevant to determining whether RSAs are confidential

employees.

¶ 10 A. RSA Job Description

¶ 11 The basic job responsibilities for the RSA position were detailed in an official job

description from the Human Resources Department of HHS. The description contains a job

summary which provides, in relevant part:

“Under minimal supervision of [(1)] the Bureau Chief of Human Resources, [(2)] Deputy

Chief of Human Resources, and [(3)] Manager of Recruitment and Selections [the RSAs

are] engaged in highly confidential screening, tracking and evaluation of job applicants’

records relative to the recruitment and selection process for offices under the jurisdiction

of County Board President. Utilizes the Automated Tracking Application System

(ATAS) for applicant selection accuracy. Coordinates efforts with all areas of the Human

Resources Bureau to ensure strict adherence to policies and procedures, Employment

Plan guidelines and other protocols. Consults with Bureau Chief and Deputy as well as

other management to review policies and identify where changes are needed to ensure

3 No. 1-15-0794

that established criteria relative to fair and objective hiring are met. May participate in the

evaluation and testing of applicants, determine work priorities and train other staff in all

operations relative to the recruitment and selections process.”

¶ 12 The job description also includes a list of typical duties for the RSA position. RSAs

implement “the policies and procedures established by the Human Resources Bureau and

explain them to the general public, County’s departmental personnel and other governmental

agencies via telephone or in-person.” RSAs additionally act “as a liaison to department heads

in the preparation of current job descriptions and minimum qualifications necessary to

qualify for select positions and to acclimate them to the policies and procedures associated

with task analysis to produce job descriptions and job postings forms,” and “[m]ay serve as a

liaison on special advisory committees which analyze the various components of exams:

establishing weighted values, determining test sites, scheduling exams, preparing exam

materials, coordinating oral interviews, producing examination announcements, proctoring

exams, rating test applicants and utilizing the ATAS 1 for applicant selection accuracy.”

RSAs also assist “hiring managers as it pertains to recruitment, staffing issues, policies and

procedures,” and conduct “reference checks and employment verification for review and

approval.” Lastly, an RSA will prepare an “offer letter for selected candidate in a timely

fashion,” and provide “basic benefit information to hiring managers and candidates.”

¶ 13 B. HHS Human Resources Department Organization Chart

¶ 14 The County provided the ALJ with an organization chart depicting the structure of the

HHS Human Resources Department. It indicates that the Chief of the Department of Human

Resources reports directly to the HHS Chief Executive Officer. The chief supervises a deputy

1 As we observed in the prior paragraph, “ATAS” is an abbreviation for the “Automated Tracking Application System.” 4 No. 1-15-0794

chief, who in turn oversees the five divisions of the Human Resources Department:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
2015 IL App (1st) 150794, 49 N.E.3d 518, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-health-and-hospital-systems-of-the-county-of-cook-v-illinois-labor-illappct-2015.