Martin v. Ohio County Hosp. Corp. (Summary)

EMTALA

Martin v. Ohio County Hosp. Corp., No. 2008-SC-000211-DG (Ky. Oct. 1, 2009)

The Kentucky Supreme Court ruled in favor of a hospital in a lawsuit alleging that the hospital had violated EMTALA’s screening and transfer requirements.

The hospital was alleged to have wrongfully delayed treatment that precipitated the death of a patient when it ordered a CT scan and sent the films to a neighboring hospital to be read by a radiologist. The court emphasized that damages are available under EMTALA only when harm is a direct result of the hospital’s violation of EMTALA’s statutory requirements, and not when the harm is caused by the medical negligence of the hospital or its personnel. Therefore, the court ruled that the hospital was entitled to a directed verdict because it satisfied the elements of the statute, which was designed to prevent hospitals from dumping patients who could not pay for their care.