James v. Jefferson Reg’l (Summary)

EMTALA

James v. Jefferson Reg’l, No. 4:12CV267 JAR (E.D. Mo. May 15, 2012)

The United States District Court for the Eastern District of Missouri dismissed a psychiatric patient’s Emergency Medical Treatment and Active Labor Act (“EMTALA”) suit against a hospital, holding that EMTALA was inapplicable because the patient was admitted to the hospital.

The patient suffered from schizophrenia and presented to the hospital’s emergency department with homicidal and suicidal ideation.  Shortly after his admission, he was involved in a fight with another patient.  After the fight, the patient was discharged to a shelter and was assaulted ten days later.  He sued the hospital, claiming that it failed to stabilize him before discharge and that the assault was reasonably foreseeable because of this.

The court, rejecting a Sixth Circuit precedent, held “that a hospital meets its obligations under EMTALA once it admits a patient.”  Thus, the patient’s “EMTALA claims fail[ed] because he clearly was admitted to the hospital.”