Pettyjohn v. Mission St. Joseph’s Health Sys., Inc. (Summary)

Pettyjohn v. Mission St. Joseph’s Health Sys., Inc., No. 01-1140 (4th Cir. Oct. 30, 2001)

After the suicide death of her son afflicted with bipolar disorder, a mother filed an EMTALA claim against the hospital at which her son was seen six days before his death. Affirming the district court’s decision, the United States Court of Appeals for the Fourth Circuit held that the mother did not provide any evidence indicating that her son had received treatment disparate from that received by other individuals with the same condition. In fact, the court noted that there was no evidence that the hospital had ever treated similarly situated patients more aggressively than it had treated the son. Also, the court held that the mother’s expert witness testimony was not sufficient to support her claim that the hospital actually knew that the son had an emergency medical condition within the meaning of EMTALA.