Brown v. St. Mary’s Hosp. (Summary)

EMTALA

Brown v. St. Mary’s Hosp., No. 3:14CV228 (DJS) (D. Conn. Jan. 12, 2015)

fulltextThe United States District Court for the District of Connecticut denied a defendant hospital’s motion to dismiss a lawsuit which alleged that the hospital violated the Emergency Medical Treatment and Active Labor Act (“EMTALA”) by failing to stabilize a patient’s emergency medical condition prior to his discharge.

The patient was admitted to the hospital based on his belief that he was suffering from diabetic ketoacidosis. While in the hospital, the patient underwent laboratory testing, x-rays, urinalysis, and an electrocardiogram. The patient was discharged while still in a state of diabetic ketoacidosis. He died soon after as a result of diabetes mellitus and diabetic ketoacidosis.

The court stated that EMTALA placed two obligations on the hospital – to provide a medical screening examination to determine if an emergency medical condition exists and, if one does exist, to stabilize it. The hospital argued that it was not liable under EMTALA since it provided the same treatment to the patient as it did to all other patients with diabetic ketoacidosis. In support of this argument, the hospital cited cases that stated EMTALA was violated if there was disparate treatment in stabilization. However, the court stated that those cases were not binding precedent, stated that some courts held that the stabilization requirement is not met by dispensing uniform treatment, and denied the hospital’s motion to dismiss.