Stafford v. Burns — Jan. 2017 (Summary)

EMTALA

Stafford v. Burns
No.1 CA-CV 15-0476 (Ariz. Ct. App. Jan. 17, 2017)

The Court of Appeals of Arizona affirmed a lower court’s instruction that the parents of a deceased patient bore the burden of a heightened standard of proof.  The case arose out of a patient arriving at a hospital’s emergency room having ingested an unknown amount of methadone.  After hours of treatment and testing, the tending physician discharged the patient.  The patient was found dead the next day, and his parents subsequently filed a complaint against the tending physician, alleging that she negligently caused the patient’s death by discharging him prematurely.

The lower court returned a defense verdict in favor of the physician, to which the parents appealed arguing, in part, that because the physician did not provide medical care in compliance with the Emergency Medical Treatment and Active Labor Act (“EMTALA”), the lower court incorrectly required the parents show a heightened burden of proof.

At the outset, the court found that EMTALA applies whenever a person comes to the hospital for “what may be” an emergency medical condition.  Consequently, because the patient came to the hospital seeking treatment for what may have been an emergency medical condition, the physician was required to provide EMTALA mandated services.  Therefore, the lower court properly invoked a heightened burden of proof as required by an EMTALA claim.