The Supreme Court of Pennsylvania has held that interns, residents, and clinical fellows are not employees under Pennsylvania's Public Employe [sic] Relations Act and therefore are not entitled to bargain collectively with their employers.
Philadelphia Association of Interns & Residents v. Albert Einstein Medical Center, 369 A.2d 711 (Pa. 1976).
Phyllis J. Palascak,
Labor Law - Public Employment Relations - Act 195,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol15/iss2/14