Eldridge

Ruth W. Eldridge appeals from a summary judgment in favor of the respondent, Sierra View Local Hospital District, a public agency, its board of directors and administrator. The appeal raises the issue of whether a local hospital district may lawfully prohibit a person from simultaneously holding the position of hospital district board member and hospital employee.

Facts

In June or July of 1986 appellant, Ruth W. Eldridge, a nurse employed by Sierra View Hospital, announced her candidacy for a vacant position as a director on the Sierra View Local Hospital District Board of Directors. When the administrator of the hospital district learned of her candidacy, he became concerned about the propriety of a hospital district employee sitting on the board and brought the matter to the attention of the board. The board ultimately concluded that it was not appropriate for an employee to sit on the board while in the employ of the district. The board was of the opinion the two positions were incompatible and fraught with conflicts of interest. In an effort to address the perceived incompatibility, the board passed the following amendment to the bylaws of the hospital…