Mitchell v. Tennova Healthcare (Summary)

EMTALA

Mitchell v. Tennova Healthcare, No. 3:13-CV-364-TAV-HBG (E.D. Tenn. Mar. 21, 2014)

The United States District Court for the Eastern District of Tennessee dismissed a patient’s suit against an entity, finding that the patient failed to state a claim under the Emergency Medical Treatment and Active Labor Act (“EMTALA”).

The patient alleged that he went to the entity’s emergency room after sustaining a workplace injury, and that a physician told him the injury would have to be reported to the employer’s human resources department before treatment could be provided.  The patient returned to the employer, found the department closed, and went home for the night.  The next day, the patient spoke to human resources, returned to the entity, and was sent to a different hospital to be treated.  The patient then filed a pro se EMTALA claim against the entity, among other things.

The court found that the patient failed to state a claim as the entity that he sued was not a legal entity.  Also, the court reasoned that even if the patient had brought suit against the correct legal entity, EMTALA is intended to limit the cause of action to those individuals who did not receive an appropriate screening, among other things, and that his complaint “fails to make any mention of the screening that is required” by EMTALA.  Finally, the court observed that the patient’s complaint appears to be that he did not receive the type of medical treatment he believes he should have received, but that does not fall under the protection of EMTALA since EMTALA does not guarantee a particular type of medical treatment, but solely requires a hospital to take appropriate screening measures.