Bryant v. Adventist Health Sys./West,
No. 00-16399 (9th Cir. May 20, 2002)
The
Ninth Circuit Court of Appeals held that a hospital cannot be liable under the
Emergency Medical Treatment and Active Labor Act ("EMTALA") if it
negligently fails to detect or misdiagnoses an emergency medical condition.
As the court held, "EMTALA...was not enacted to establish a federal malpractice
cause of action nor to establish a national standard of care." Rather,
a plaintiff's remedies for alleged inadequate medical care are more properly
addressed under state malpractice and tort laws. Moreover, the Ninth Circuit
also held that the EMTALA stabilization requirement generally ends once an individual
is admitted for inpatient care. The court continued that liability may only
attach under EMTALA if a patient is able to demonstrate that the inpatient admission
was a "ruse" to avoid EMTALA's stabilization requirements, which was
not the case in this matter.