EMTALA

Carlisle v. Frisbie Mem'l Hosp., No. 2004-555 (N.H. Nov. 30, 2005)

An intoxicated and suicidal patient who entered a hospital's emergency room brought claims under the Emergency Medical Treatment and Active Labor Act (EMTALA) and the state's patient's bill of rights (PBR), after the treating emergency room physician transferred the patient to jail after she refused to see a counselor. A jury trial found for the patient and the hospital appealed. The New Hampshire Supreme Court affirmed the trial court's decision, finding that the hospital failed to stabilize the patient as required by EMTALA when it provided no treatment before transferring the patient to protective custody.