Adams-Erazo v. Hosp. San Gerardo – July 2015 (Summary)

EMTALA

Adams-Erazo v. Hosp. San Gerardo, Civil No. 13-1918 (FAB) (D.P.R. July 24, 2015)

The United States District Court for the District of Puerto Rico denied a hospital’s motion for summary judgment in a suit brought by a patient’s surviving family members alleging, among other things, violations of the Emergency Medical Treatment and Active Labor Act (“EMTALA”).

The patient presented to the hospital’s emergency department with gunshot wounds. His surviving family members alleged that the hospital failed to appropriately screen the patient under EMTALA. In denying the hospital’s motion for summary judgment, the court held that a genuine issue of material fact existed as to whether the hospital provided the patient with an appropriate medical screening examination because the hospital failed to follow its gunshot wound screening protocol. In light of its decision on the EMTALA claim, the court decided to exercise supplemental jurisdiction over the plaintiffs’ Puerto Rico law claims.