Rivera v. Doctors Center Hosp., Inc.,
No. CIV. 01-2713(JP) (D. Puerto Rico Feb. 25, 2003)

The federal district court for the District of Puerto Rico dismissed a claim against a hospital asserting violations of the screening and transfer requirements of EMTALA.

The patient suffered multiple injuries, including head trauma resulting from a car accident, and was brought to the hospital's emergency room. Because the hospital did not have neurosurgical facilities, the patient was stabilized and then transferred to a nearby facility where he died.

The court found that the hospital substantially complied with its own protocol, which was sufficient to meet EMTALA screening requirements. The court also held that the medical treatment provided by the transferring hospital was reasonable in light of the circumstances that existed at the time of discharge and at the time the diagnosis was made. In addition, the transferring hospital complied with the EMTALA provisions concerning transfer of unstable patients. Accordingly, the court found that no EMTALA violations had occurred.