The Court of Appeals of Texas affirmed a grant of summary judgment in favor of a hospital in an Emergency Medical Treatment and Active Labor Act (EMTALA) claim filed on behalf of a deceased patient. The court found that a 12-minute delay in assessment by a triage nurse was a de minimis variation from the standard protocol that the hospital had developed and therefore did not amount to a violation of EMTALA. The court found in favor of the hospital as a matter of law.