Johnson v. Frederick Mem’l Hosp. (Summary)

EMTALA

Johnson v. Frederick Mem’l Hosp., No. WDQ-12-2312 (D. Md. May 15, 2013)

The United States District Court for the District of Maryland granted a hospital’s motion for partial summary judgment in a lawsuit brought by a patient asserting, among other things, violations of the Emergency Medical Treatment and Labor Act (“EMTALA”).  The patient and his wife brought the suit alleging that the hospital violated EMTALA by failing to properly screen and stabilize him when he presented to the hospital’s emergency room complaining of back pain. Ultimately, the patient suffered from “permanent lower extremity paralysis.”

The court rejected the patient and his wife’s EMTALA claims, first finding that there were no allegations that the hospital’s screening of the patient in its emergency department was “atypical or discriminatory in light of [the patient’s] perceived condition.”  The court then addressed the patient’s failure to stabilize claim, holding that the patient and his wife did not allege that his admission was in bad faith to avoid EMTALA requirements.  Accordingly, the court granted the hospital’s motion for summary judgment on the EMTALA claims and declined to exercise its discretion to hear the remaining state law claims.