Michaud v. Calais Regional Hosp. — Mar. 2017 (Summary)

EMTALA

Michaud v. Calais Reg’l Hosp.
No. 1:15-cv-359-NT (D. Me. Mar. 7, 2017)

The United States District Court for the District of Maine denied a hospital’s motion for summary judgment regarding alleged violations of the Emergency Medical Treatment and Active Labor Act (“EMTALA”).

A patient was receiving dialysis when he suffered a syncopal episode.  The patient was transferred to a hospital for evaluation.  Most of the patient’s test results came back normal, but the attending physician suspected that the patient’s syncope was potentially related to a serious, underlying cardiac problem.  Because the hospital did not provide dialysis services, the attending physician informed the patient and his family that he needed to be transferred to another hospital.  However, after a four-hour stay in the hospital, the attending physician changed his mind and informed the patient that he was being discharged instead of being transferred.  Shortly after arriving at home, the patient collapsed and died.  The patient’s wife sued the hospital, alleging that the hospital had violated EMTALA.

An EMTALA violation requires a plaintiff to demonstrate either that the screening provided by a hospital was inadequate or, based on the results of screening, that the hospital improperly transferred or discharged the patient in an unstable condition.  If a hospital performs a screening and determines that the patient has an emergency medical condition, then it is required to arrange for appropriate transfer or continuity of care to treat or stabilize the condition.  The court held that there was reasonable dispute as to whether the screening was “reasonably calculated to identify critical medical conditions,” whether the hospital knew that the patient had an “emergency medical condition,” and whether the patient was appropriately stabilized before discharge.  Accordingly, the court denied the hospital’s motion for summary judgment.