Maldonado-Rodriguez v. St. Luke’s Mem’l Hosp. (Summary)

EMTALA

Maldonado-Rodriguez v. St. Luke’s Mem’l Hosp., Civ. No. 10-1362 (PG) (D. P.R. Apr. 22, 2013)

The United States District Court for the District of Puerto Rico granted a hospital’s motion for summary judgment in an EMTALA lawsuit concerning a patient who died while being treated in an emergency room for injuries suffered in an accident. The family of the patient claimed that the physicians at the hospital lacked the proper staff and equipment necessary to treat the patient and failed to properly transfer him.

In granting summary judgment to the hospital, the district court found that the hospital complied with its duty to screen the patient for an emergency medical condition.  Further, the court held that EMTALA’s stabilization requirements were not violated because the patient was never transferred. EMTALA defines stabilization as providing medical treatment to assure that a patient does not deteriorate during a transfer from one facility to another. The patient never left the hospital; he died before the transfer could be performed.

The district court also dismissed the duty to transfer claim. The court stated that the decision to transfer did not give rise to an EMTALA claim. A hospital is only liable for the conditions under which a stable or unstable patient was transferred. The transfer decision itself may trigger medical malpractice liability, but it does not trigger EMTALA liability.