EMTALA/PREEMPTION

Meierer v. St. John's Reg'l Health Ctr., No. 04-3449-CV-S-GAF (W.D.Mo. May 5, 2005)

A hospital required that uninsured patients execute a contract agreeing to pay for all medical treatment before receiving any medical services. An uninsured patient filed a complaint against the hospital citing state law claims of breach of charitable trust and breach of the duty to provide emergency medical treatment. The hospital removed the case to the United States District Court, Western District of Missouri arguing that the complaint implied federal law. The district court held that the patient's claim of breach of charitable trust did not explicitly rely on the federal EMTALA statute, that EMTALA does not provide a complete preemption of state law, and that the patient's claim of breach of charitable trust relied exclusively on state regulations governing the operation of its hospitals. Therefore, the district court remanded the case to the state court.