Friedrich v. S. Cty. Hosp. Healthcare Sys. — Nov. 2016 (Summary)

EMTALA/URGENT CARE CENTER

Friedrich v. S. Cty. Hosp. Healthcare Sys.
No. 14-353 S (D.R.I. Nov. 1, 2016)

The United States District Court for the District of Rhode Island denied a healthcare system’s motion for partial summary judgment in a suit brought by the estate of a deceased patient asserting that the healthcare system’s urgent care center violated the Emergency Medical Treatment and Active Labor Act (“EMTALA”).

The patient visited the urgent care center after experiencing chest pains.  The urgent care center diagnosed the patient with acid reflux and sent her home.  The patient died the next day from a heart attack.  The patient’s estate sued the healthcare system, claiming that its urgent care center violated EMTALA because it failed to screen and stabilize the patient.  The healthcare system filed a motion for partial summary judgment arguing that the urgent care center did not constitute a “dedicated emergency department” under EMTALA and, therefore, was not required to comply with EMTALA’s mandates.  The court disagreed.  Relying on the EMTALA regulations, the court concluded that the urgent care center was a “dedicated emergency department” subject to EMTALA because it held itself out “as a place that provides care for emergency medical conditions on an urgent basis without requiring a previously scheduled appointment.”