Mazurkiewicz v. Doylestown Hosp.

EMTALA

Mazurkiewicz v. Doylestown Hosp.,
No. 01-CV-5418 (E.D. Pa. Feb. 17, 2004)

The
United States District Court for the Eastern District of Pennsylvania dismissed
an EMTALA claim filed by a patient against a hospital.

The patient presented to the hospital’s emergency room and
was admitted for airway observation after a CT scan and fine needle aspiration
were performed in an effort to rule out a pharyngeal abscess. After being discharged
from the hospital five days later, the patient went to a different hospital
where an abscess was diagnosed and surgically drained.

After considering EMTALA’s statutory language, legislative
history, and interpretation by the First and Sixth Circuits, the court held
that admission of a patient to the hospital is a valid defense to an EMTALA
claim so long as the admission is not used as a subterfuge to avoid responsibility
under EMTALA.