Thornhill v. Jackson Parish Hosp. — May 2016 (Summary)

EMTALA

Thornhill v. Jackson Parish Hosp.
No. 15-01867 (W.D. La. May 4, 2016)

The United States District Court for the Western District of Louisiana granted summary judgment to a hospital in an Emergency Medical Treatment and Active Labor Act (“EMTALA”) suit brought by the administrator of the estate of a deceased patient.  The patient was admitted to the hospital after presenting to the emergency department with shortness of breath and decreased level of consciousness.  His family requested that the hospital transfer the patient to another hospital.  During the transfer, the patient died.  The administrator of his estate sued, arguing that the hospital violated EMTALA by not providing an appropriate transfer.  The court rejected this argument and granted summary judgment to the hospital.  In doing so, the court accepted the Centers for Medicare & Medicaid Services’ interpretation of EMTALA found in the EMTALA regulations.  Those regulations state that a hospital’s obligation to stabilize a patient ends when the hospital, in good faith, admits a patient in order to stabilize a patient’s emergency medical condition.  According to the court, because the patient was admitted for inpatient treatment, “and because there is no indication [the hospital] took this action in bad faith, the hospital satisfied its duty to Plaintiffs under EMTALA.”