Jackson v. East Bay Hosp. (Summary)

Jackson v. East Bay Hosp., No. 98-17152 (9th Cir. Apr. 19, 2001)

The wife and daughter of a psychotic man who died after being misdiagnosed in a California emergency room sued the hospital and the company that provided its financial and administrative services, alleging violations of federal and state EMTALA laws as well as state negligence claims.

The man went to the emergency room three times over the span of three days, each time being diagnosed as having psychiatric problems. Detecting no medical emergency, the ER physicians referred
him to a local psychiatric facility for follow-up care. Upon transfer to the psychiatric facility, the man went into cardiac arrest caused by Anafranil toxicity (a medication used to treat his psychosis) and died.

The Ninth Circuit upheld dismissal of the federal EMTALA claim, finding that since the ER physicians performed the medical exam that all patients presenting with the decedent’s symptoms receive, the medical screening examinations provisions of EMTALA were met.

The Court agreed with the survivors that the California statutes create a reasonable care standard for the medical examination but held that it only applies when the hospital does not provide a screening or examination to determine if the patient has an emergency medical condition or when the hospital detects an emergency medical condition but declines to treat the patient. In this case, the hospital provided an exam but did not detect an emergency condition, so that standard did not apply.

The Ninth Circuit went on to hold that the agreement between the hospital and the company that provided its financial and administrative services did not give the company control over patient care or hospital operations and, therefore, it could not be held liable for any negligence on behalf of the hospital.