Byrne v. Cleveland Clinic (Summary)

EMTALA

Byrne v. Cleveland Clinic, No. 12-4033 (3d Cir. Mar. 19, 2013)

The United States Court of Appeals for the Third Circuit affirmed a trial court’s grant of summary judgment in favor of a hospital after a patient claimed that the hospital violated the Emergency Medical Treatment and Active Labor Act (“EMTALA”).  The case involved a patient who presented to the hospital’s emergency department with chest pains.  Within 20 minutes of the patient’s arrival, the hospital had drawn his blood and requested an EKG, and within the next 30 minutes, the hospital performed a chest x-ray.  The patient was later examined by an emergency department physician and a cardiologist, who gave the patient treatment options.  Based on the cardiologist’s advice, the patient decided to have an emergency stent implanted through a catheterization procedure which was completed roughly five and a half hours after he had presented to the emergency department.  The patient subsequently sued the hospital for a range of claims, but the Third Circuit in this instance considered the patient’s allegation that the hospital breached its EMTALA duties by not satisfying the Act’s screening requirement.

Noting that EMTALA does not serve as a federal malpractice statute, but rather, it is an anti-discrimination statute, the court noted that the hospital had two protocols for treating patients presenting with chest pains, and both protocols were administered to the patient indiscriminately.  Furthermore, the court noted that EMTALA’s screening requirement is not clearly defined, but the degree of care delivered to the patient clearly satisfied the screening requirement.  Accordingly, the court affirmed the trial court’s grant of summary judgment in favor of the hospital.