Gutierrez v. Santa Rosa Memorial Hosp. — Oct. 2016 (Summary)

EMTALA

Gutierrez v. Santa Rosa Memorial Hosp.
No. 16-cv-02645-SI (N.D. Cal. Oct. 12, 2016)

The United States District Court for the Northern District of California granted, in part, a defendant hospital’s motion to dismiss, but allowed the plaintiff patient leave to amend her complaint, alleging that the hospital, among other things, violated the Emergency Medical Treatment and Active Labor Act (“EMTALA”) by failing to adequately screen and stabilize the patient’s condition before discharge.

The patient, a diabetic with end-stage renal disease, was treated in the hospital’s emergency department.  The patient alleged that despite indications from lab results that she might have a life-threatening disease, the hospital discharged her four hours later.  The patient collapsed shortly after discharge and was transferred to the ICU in a coma.  The patient (and other members of her family) sued the hospital and others, asserting claims for a violation of EMTALA and a violation of California’s Elder Abuse and Dependent Adult Civil Protection Act.  The hospital filed a motion to dismiss the patient’s complaint.  The court granted the motion, in part, and granted the patient leave to amend the complaint.  Specifically, the court dismissed the patient’s “failure to screen” claim under EMTALA because the complaint contained “no allegations that plaintiff was provided with a screening that was not comparable to that provided to other patients who exhibited similar symptoms.”  Nor did the complaint allege “that the screening provided…was ‘at such a minimal level that it properly cannot be said that the screening [was] appropriate.’”  The court also granted the hospital’s motion to dismiss the patient’s claim under California’s Elder Abuse and Dependent Adult Civil Protection Act because the complaint did not allege that the patient was a “dependent adult” as that term is defined by the statute.  On the other hand, the court denied the hospital’s motion to dismiss with respect to the patient’s “failure to stabilize” claim under EMTALA.  According to the court, the patient’s complaint supported this claim by alleging that the hospital ignored results of lab tests showing “the presence of life-threatening disease” and, subsequently, discharged her without stabilizing her.