EMTALA

Jakubiec v. Sacred Heart Health Sys. Inc., No. 3:04CV274MCR/MD, 3:04CV276MCR/MD (N.D.Fla May 27, 2005)

A group of uninsured patients sued two not-for-profit hospitals, alleging, among other things, violations of the Emergency Medical Treatment and Active Labor Act ("EMTALA"). The patients claimed that the hospitals analyzed their ability to pay for treatment and required them to sign contracts in which they agreed to pay for services rendered in full, prior to providing a medical screening or treatment. The District Court for the Northern District of Florida dismissed the claim, finding that the patients failed to allege either that, after signing the payment guarantee, they did not receive treatment or an appropriate medical screening exam or that being required to sign the guarantee delayed the receipt of an appropriate medical screening or treatment. The court also found the patients' economic injury did not qualify as personal injury under Florida law, and, therefore, they did not meet the personal harm requirement necessary to bring an EMTALA claim.