Bryson v. Milford Reg’l Med. Ctr. (Summary)

EMTALA

Bryson v. Milford Reg’l Med. Ctr., Civil Action No. 11-40052-TSH (D. Mass. Mar. 27, 2014)

The U.S. District Court for the District of Massachusetts granted a defendant’s motion for partial summary judgment, determining that the Emergency Medical Treatment and Active Labor Act (“EMTALA”) transfer requirements were met by the defendant hospital. The process was deemed to be in compliance with EMTALA requirements, and any challenges to the standard of care would need to be addressed through claims of negligence or malpractice.

The plaintiff, a pregnant woman who had previously undergone gastric bypass surgery, was admitted into the defendant hospital after experiencing severe shooting pains in her abdomen. Despite pain and anti-nausea medication, the plaintiff’s condition had not improved, and she was admitted to the labor and delivery unit.  Another obstetrician examined the plaintiff and noted that, though her pain was worsening, the vital signs for her and the fetus were stable.  Ultimately, the defendant decided to transfer the plaintiff to a tertiary care center because the hospital did not have a newborn intensive care unit and did not have adequate resources to address any complications that might arise due to the plaintiff’s previous gastric bypass surgery.  Both the physician and the plaintiff signed her authorization for transfer form.  Before she left the defendant hospital, the plaintiff began vomiting blood. She arrived at the transfer hospital in critical condition and received an emergency caesarean section.  The baby was born with no heart rate and died 11 days later.  The plaintiff alleged that the defendant hospital violated EMTALA by failing to stabilize her before transferring her to another hospital. 

The defendant sought summary judgment to dismiss this claim, arguing that EMTALA does not apply in this case because the plaintiff went directly to the labor and delivery unit and bypassed the emergency room.  The court determined that there was no violation of EMTALA, as the plaintiff was appropriately transferred under the Act’s requirements.  The doctors of the defendant hospital observed and treated the plaintiff and ultimately determined after careful consideration that the benefits of better resources outweighed the risk of a transfer.  Both the physician and the plaintiff signed the authorization for transfer.  The process was, therefore, deemed to be in compliance with EMTALA requirements, and any challenges to the standard of care would need to be addressed through claims of negligence or malpractice.