Meierer v. St. John’s Reg’l Health Ctr.

EMTALA/PREEMPTION

Meierer v. St. John’s Reg’l Health Ctr., No. 04-3449-CV-S-GAF
(W.D.Mo. May 5, 2005)

A hospital required that uninsured patients execute a contract agreeing
to pay for all medical treatment before receiving any medical services. An
uninsured patient filed a complaint against the hospital citing state law claims
of breach of charitable trust and breach of the duty to provide emergency medical
treatment. The hospital removed the case to the United States District Court,
Western District of Missouri arguing that the complaint implied federal law.
The district court held that the patient’s claim of breach of charitable trust
did not explicitly rely on the federal EMTALA statute, that EMTALA does not
provide a complete preemption of state law, and that the patient’s claim of
breach of charitable trust relied exclusively on state regulations governing
the operation of its hospitals. Therefore, the district court remanded the
case to the state court.