Langston v. Milton S. Hershey Med. Ctr. — Apr. 2016 (Summary)

EMTALA STABILIZATION

Langston v. Milton S. Hershey Med. Ctr.
Civil No. 1:15-CV-02027 (M.D. Pa. Apr. 11, 2016)

The United States District Court for the Middle District of Pennsylvania denied in part and granted in part motions to dismiss brought by a medical center, hospital, surgeon, and treating physician with regard to a former patient’s §1983, ADA, Rehabilitation Act, and EMTALA claims.

This case arose after a surgeon performed an ileostomy on the patient to treat a perianal fistula.  After the procedure, which had ended up being a more extensive surgery than she had hoped for, the patient said she experienced persistent complications.  Though she was experiencing leg cramps, she said that her doctor discharged her from the hospital, leaving her to take a 90-minute taxi ride to an empty house.  Within a day or so, the patient presented to another hospital’s Emergency Department, where she was treated for dehydration and then allegedly began to suffer renal failure.  As a result, she was transferred back to the medical center where her surgery had been performed.  When the medical center tried to discharge her, the patient arranged to be transferred to a nursing home for two weeks.  She continued to suffer complications, including problems with the ostomy-bag seal, dehydration, and renal failure.  These complications resulted in the patient seeking care from and being transferred numerous times between the medical center that performed the surgery, another hospital, a nursing home, and a rehabilitation facility.

The patient sued claiming, among other things, that the medical center violated EMTALA when it discharged her to a rehabilitation facility despite the fact that she was suffering from leg cramps.  She further alleged that the hospital violated EMTALA when it transferred her back to the medical center twice, the first time while she was experiencing renal failure and the second time while she was experiencing severe “vice-like” pain.

With regard to the patient’s transfer from the medical center to the rehabilitation facility, with alleged leg cramps, the court dismissed the patient’s EMTALA claim against the medical center, stating:  “…we agree with [the medical center] that ‘to stabilize’ or ‘stabilized’ does not require all ailments to be cured, only that no material deterioration of a condition is likely to result from or occur during the transfer.  Moreover, we remain unconvinced that the alleged leg cramps qualify as an independent, emergency medical condition.”

The court also dismissed one of the patient’s EMTALA claims against the hospital (the claim related to the patient’s transfer while in renal failure), because although the patient alleged that she suffered from renal failure while at the hospital, she alleged no facts concerning her condition at the time of the transfer or regarding the medical treatment she received at the hospital, if any.

The court allowed one of the patient’s EMTALA claims to proceed against the hospital – the claim related to her transfer to the medical center while suffering “vice-like” pain.  The court noted that the patient alleged her ostomy-bag seal failed multiple times, resulting in severe pain, and that her physician at the hospital ignored her requests for pain management and instead transferred her back to the medical center.  Based on these facts, the district court found the patient had adequately alleged she presented at the hospital with an emergency medical condition that was not stabilized prior to her transfer to the medical center.