Matta-Rodriguez v. Ashford Presbyterian Cmty. Hosp. (Summary)

EMTALA

Matta-Rodriguez v. Ashford Presbyterian Cmty. Hosp.
No.12-1028 (PAD) (D.P.R. July 18, 2014)

The United States District Court for the District of Puerto Rico dismissed a family’s Emergency Medical Treatment and Active Labor Act (“EMTALA”) claim against a hospital, holding the hospital fulfilled its statutory duty to the patient. After a patient was admitted to the hospital, he was evaluated for an open cholecystectomy. Four days later, an additional test was ordered for the patient, but not by his treating physicians. This test would ultimately reveal the patient had high levels of bilirubin and alkaline. However, his treating physicians discharged him, and he reappeared in the hospital’s emergency room five days later. The patient was readmitted and after a consultation with the same treating physicians a CT scan was performed. The CT scan revealed two liters of bile in the patient’s abdominal cavity. The treating physicians determined the patient needed a special surgery that the hospital was not equipped and transferred the patient to a neighboring hospital for the surgery. The patient died two days later. The patient’s family brought this action against the hospital, claiming that the hospital violated EMTALA when it discharged the patient with an “unstablized emergency medical condition,” when it did not order a CT scan as part of the initial screening process during the patient’s second visit, and when it transferred the patient in an unstable condition.

The court held that despite the family potentially having a state medical malpractice claim, EMTALA was not violated. The court stated that the patient being negligently discharged is not an appropriate EMTALA claim since EMTALA no longer applies once a patient has been admitted as an inpatient. The court also found that the hospital fulfilled its EMTALA duty once it admitted the patient. Next, the court stated that the hospital did not take the patient’s financial ability into consideration when it failed to order a CT scan as part of his initial screening process. The hospital’s initial screening process had never included a CT scan, no matter how wealthy or poor the patient. Lastly, the court stated that the third claim falls outside of EMTALA’s protections as well because the patient was not transferred for financial reasons.