Lopez v. Contra Costa Reg’l Med.l Ctr (Summary)

EMTALA

Lopez v. Contra Costa Reg’l Med.l Ctr., No. C 12-03726 LB (N.D. Cal.  Feb. 28, 2014)

The family of a mother who passed away following the birth of her third child, from complications related to the pregnancy, brought a claim against the hospital for malpractice and for violating the Emergency Medical Treatment and Active Labor Act (“EMTALA”).  With respect to the EMTALA claim, the family asserted that the hospital had admitted the mother to its facility to stabilize her emergency condition, but did so in bad faith.

The United States District Court for the Northern District of California granted summary judgment to the hospital because the records clearly showed that the mother had been admitted to the hospital for treatment, not to be stabilized.  The court concluded that EMTALA does not have a “good faith” requirement with respect to the provision of medical treatment after admission. 

According to the court, the family had not shown that the mother had been admitted to the hospital to be stabilized for transfer.  Rather, the hospital had sufficiently established that the mother was admitted for the delivery of her child as well as for the postpartum complications she suffered.  Therefore, EMTALA was not implicated.