EMTALA

Bryant v. John D. Archbold Mem’l Hosp., No. 06-13168 (11th Cir. Oct. 27, 2006)

A patient appealed a United States district court decision that dismissed her EMTALA claims against a hospital and a physician. The patient sued the hospital and physician after she was treated for injuries sustained in an automobile accident and subsequently released, only to return to the hospital a few days later for an extensive surgical procedure. The District Court for the Middle District of Georgia held that the patient was afforded the hospital’s typical medical screening for injuries of her type, which satisfied the hospital’s EMTALA obligation. The court further held that the claim against the physician was without merit since EMTALA is not a federal medical malpractice statute. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the record and, finding no error, summarily affirmed the lower court’s decision.