Concluding that arbitrator acted within the scope of his authority when concluding that a recognition clause imposed a contractual obligation to bargain over the conditions of employment
In C C Plywood the Supreme Court said that the disputed contract provision, in dealing with increases for "particular employee[s]", did not authorize a unilateral increase for a group of employees which would invalidate previously negotiated wage differentials.
Defining the standard of care as "that degree of care, skill, and learning expected of a reasonably prudent health care provider . . . acting in the same or similar circumstances"