Moore v. Grand View Hosp. (Summary)

EMTALA

Moore v. Grand View Hosp., Civil Action No. 13-2384 (E.D. Pa. Nov. 24, 2014)

The U.S. District Court for the Eastern District of Pennsylvania granted a hospital’s request for summary judgment on the Emergency Medical Treatment and Active Labor Act (“EMTALA”) claims brought by a patient whose fetus died two days after she was discharged from the hospital’s L&D unit.

The pregnant patient had been sent to the hospital after her private obstetrician noted, during her final prenatal visit, that the patient was suffering some of the symptoms of preeclampsia. After arriving at the hospital’s L&D unit, the patient was given several tests, including blood glucose, urinalysis, and electronic fetal monitoring. After several hours of monitoring, the attending physician reviewed the patient’s blood pressure and the fetal monitor tracing (but did not screen her for preeclampsia) and determined to discharge the patient. Two days later, the patient delivered a stillborn baby. Testing indicated that the baby died due to preeclampsia.

The patient and her husband sued the hospital and others, alleging malpractice and wrongful death. In addition, with respect to the hospital, they alleged that the hospital failed to screen and stabilize the patient, in violation of EMTALA. In granting summary judgment to the hospital on the EMTALA claim, the federal district court held that the hospital’s failure to screen and stabilize the patient for preeclampsia was not an EMTALA violation because the hospital provided the same screening to this patient that it routinely provided to other patients presenting with similar symptoms. Further, the patient could not sustain a claim for discharge prior to stabilization, since the hospital did not believe the patient had an emergency medical condition and, accordingly, did not believe it was discharging the patient in a non-stabilized condition.