Thomas v. St. Joseph Healthcare, Inc – Summary

EMTALA

Thomas v. St. Joseph Healthcare, Inc. , Nos. 2007-CA-001192-MR, 2007-CA-001244-MR (Ky. Ct. App. July 16, 2010)

The Court of Appeals of Kentucky had previously denied the hospital’s motion for judgment notwithstanding the verdict with respect to the jury’s findings of liability for a deceased patient estate’s claims of medical negligence and EMTALA violations and the award of compensatory and punitive damages. The court, however, concluded that the instructions concerning punitive damages were deficient because the instructions did not set out the standard of proof and require proof that the hospital ratified the employee’s conduct. On appeal, the Kentucky Supreme Court remanded the case back to the State Court of Appeals to review its determinations under a new EMTALA analysis recently established by the State Supreme Court. The State Appeals Court found that its rulings were appropriate under this EMTALA analysis, and ordered a new trial on the punitive award granted.