Sanders v. Legacy Emanuel Med. Center (Summary)

EMTALA

Sanders v. Legacy Emanuel Med. Center, No. 3:14-cv-00690-PK (D. Or. Oct. 16, 2014)

fulltextThe United States District Court for the District of Oregon dismissed a patient’s Emergency Medical Treatment and Active Labor Act (“EMTALA”) claim against a hospital, finding that the hospital had in fact provided the patient with a medical screening. The patient had presented at the emergency room of the defendant hospital suffering from hyperammonemia. An ultrasound and glucose test were performed on the patient but ultimately failed to diagnosis the patient’s chromobacterium infection. The patient sued alleging that the hospital had violated EMTALA by failing to provide him with a medical screening.

The court held that the hospital did provide him with a medical screening as evidenced by the two tests that had been performed on him, noting that a screening that may have been inadequate to diagnose his condition was very different than a disparate screening practice based upon whether a patient was insured or uninsured. The court also held that the patient failed to allege sufficient facts that his hyperammonemia symptoms were so severe that in the absence of immediate medical attention it would reasonably be expected that the patient would suffer the types of serious bodily harm as outlined in EMTALA, noting that even the patient had admitted that hyperammonemia is not an emergency medical condition. Finally, the court upheld the magistrate’s dismissal of the patient’s claims against several named physicians, finding that EMTALA claims can only be brought against hospitals, and that any claims against named physicians had to be brought under state law negligence actions.