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GUPTA v. NEW BRITAIN GENERAL HOSPITAL12/31/1996
ty,
compels the conclusion that the hospital's decision to dismiss the plaintiff was an educational and not an employment decision.
The language of the residency agreement bears many indicia of a contract for educational services. In its first sentence, the agreement provides that " he general objectives of the Program are to provide to the Physician a proper educational experience in the professional field encompassed by the Program while simultaneously providing to the Hospital's patients a high quality of health care." (Emphasis added.) The agreement further provides that " he Program covered by this Agreement is part of an overall program of education provided at the ospital." (Emphasis added.) To facilitate this learning experience, the hospital promises to "maintain its staffing and facilities so as . . . to provide a proper educational setting for the Program." (Emphasis added.)
Other parts of the residency agreement contain provisions, however, that are indicative of an employer-employee relationship. Thus, the agreement provides that the plaintiff "will be paid a weekly salary at a rate of $22,800.00 per year" and that " he Hospital will provide to the Physician . . . insurance coverage and other benefits. . . ." The agreement assures the plaintiff that he will receive "such holidays, vacation time and leaves of absence as may be set forth in the Hospital's general schedule of employee benefits." The agreement promises that the plaintiff, during his term at the hospital, "will be a member of the Hospital's Medical Staff, having all of the rights and responsibilities attendant upon such membership. . . ."
The trial court concluded that, despite the employment aspects of the residency agreement, its "consistent purpose" was "to provide an educational opportunity." Implicitly drawing on cases in which
courts> have had to decide whether residents are "students" or "employees" for the purpose of collective bargaining, the trial court found that the primary purpose of this contract was educational because, in the court's view, "without the educational component of the [agreement], the plaintiff would/could not have participated" in the residency program. Having thus discerned the agreement's primary purpose, the court concluded that the hospital's decision to dismiss the plaintiff was a proper exercise of its academic responsibility for residency training.
Although we agree with the trial court's ultimate conclusion, we are not persuaded that a singular search
for the primary purpose or purposes of the parties is determinative of the rights of the parties in this case. On its face, the residency agreement created a hybrid relationship containing both employment and educational features. See Regents of the University of Michigan v. Michigan Employment Relations Commission, 389 Mich. 96, 112, 204 N.W.2d 218 (1973) ("residents . . . are both students and employees"); House Officers Assn. v. University of Nebraska Medical Center, 198 Neb. 697, 701-702, 255 N.W.2d 258 (1977) (same); Seare v. University of Utah School of Medicine, 882 P.2d 673, 677 (Utah App. 1994), cert. denied, 892 P.2d 13 (Utah 1995) (noting existence of "two types of relationships" in a residency program: employment and education). Because of the hybrid nature of the residency agreement, we conclude that the agreement is more properly interpreted, under any particular set of circumstances, by a functional analysis of its terms in relationship to the nature of the alleged breach, rather than by an overarching search for the purpose or purposes of the parties. See Ross v. University of Minnesota, 439 N.W.2d 28, 32 (Minn. App. 1989) (" hether the
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