Morales-Ramos v. Hosp. Episcopal San Lucas Guayama, Inc. — Sept. 2016 (Summary)

EMTALA

Morales-Ramos v. Hosp. Episcopal San Lucas Guayama, Inc.
Civil No. 13-1614 (BJM) (D.P.R. Sept. 13, 2016)

The United States District Court for the District of Puerto Rico granted in part and denied in part a hospital’s motion for summary judgment against a patient alleging, among other jurisdictional claims, transfer and screening violations under the Emergency Medical Treatment and Active Labor Act (“EMTALA”).

The court found that summary judgment was not appropriate, with respect to the patient’s EMTALA screening claim, because the hospital deviated from its standard protocol of connecting a fetal monitor to every pregnant woman with over 20 weeks of gestation. The patient, who was 37 weeks pregnant, was in the hospital’s emergency room from 1:50 a.m. to 3:30 a.m., which should have resulted in a fetal monitor being connected for at least 100 minutes. However, the fetal monitor showed that it was connected for only 50 minutes. Accordingly, the court reasoned that even though a doctor from the hospital maintained that the patient was connected the entire time, the evidence at the very least created a genuine issue of material fact.

The court further reasoned that a reasonable jury could also find that the hospital’s failure to document the patient’s vital signs constituted a deviation from standard protocol. While the patient’s vital signs were properly documented upon her arrival at the hospital, the record reflected three instances in which the patient’s vital signs were not properly documented. Additionally, the court stated that a reasonable jury could also find that the hospital did not follow the proper screening procedures required before a doctor can decide to transfer a patient. A doctor from the hospital testified that before deciding to transfer or make arrangements to transfer a patient, the patient’s laboratory test should be examined. However, the hospital began making arrangements to transfer the patient approximately 20 minutes before she arrived at the hospital’s emergency room.

Turning to the patient’s EMTALA transfer claim, the patient claimed that she was suffering from abruption placentae, which presented a life-threatening medical condition for the patient and her unborn child. The court noted, however, that the patient failed to include any evidence that the hospital was aware of her condition at the time of the transfer. The court was unconvinced by the patient’s argument that the doctor at the hospital must have known, reasoning that the patient was attempting to impose liability on a theory of constructive knowledge. The court concluded that summary judgment was appropriate because the patient failed to show any evidence indicating that the hospital knew that she was suffering from the life-threatening condition. Therefore, in light of their findings, the court granted the hospital’s motion for summary judgment with respect to the patient’s EMTALA transfer claim, and denied summary judgment with regard to their EMTALA screening claim.  Since the federal court had jurisdiction over the plaintiff’s EMTALA screening claim, it retained supplemental jurisdiction over the plaintiff’s state law, medical malpractice claim.