Valentin-Lugo v. Hosp. Matilde Brenes Inc. (Summary)
EMTALA
Valentin-Lugo v. Hosp. Matilde Brenes Inc., Civil No. 12-1757 (PAD) (D.P.R. Dec. 18, 2014)
The Magistrate Judge’s Report and Recommendation
The U.S. District Court for the District of Puerto Rico granted a hospital’s motion for summary judgment against an EMTALA lawsuit. The EMTALA lawsuit was filed by an employee of the hospital, who became a patient there after she developed sudden abdominal pain during her lunch break.
At issue in the case was whether the hospital conducted an adequate screening of the patient before transferring her to see her personal obstetrician. When the patient developed a sudden onset of abdominal and pelvic pain, she was taken to the hospital’s “Labor Room” for an examination by its resident obstetrician. However, she refused to consent to this examination, instead requesting that the hospital transfer her to see her personal obstetrician at another location. Prior to the transfer, the hospital conducted a “Non-Stress Test” and determined that the fetal heart rate was normal and that she was not undergoing contractions. The hospital also conducted several other tests, including a pelvic examination, blood test, urinalysis, and renal sonogram. All of these indicated that it was safe for the patient to be transferred. The parties in the lawsuit differed over whether the patient displayed any indications of trouble during transit. The hospital argued that her vital signs were normal, but the patient claimed that the paramedic record showed premature contractions and the possibility of hypovolemic shock and class II hemorrhage. Tragically, when the patient arrived at the destination hospital, the receiving nurse found no fetal heart rate. A subsequent examination revealed a ruptured uterus and intrauterine death of the fetus.
In her lawsuit, the patient alleged that the hospital failed to perform a complete medical examination before transferring her. The hospital countered by arguing that it had complied with EMTALA, and that it had treated her as it would any patient with similar symptoms. In addition, the hospital argued that although the patient claimed the Non-Stress Test did not last long enough, she had failed to submit any other evidence demonstrating that her screening was inadequate or that the hospital had failed to comply with EMTALA.
A magistrate judge initially heard the case and found that the hospital had complied with EMTALA. The judge noted that the hospital had ordered tests to identify the source of her pains and had transferred her to a hospital in her hometown after it deemed her stable. Consequently, the judge recommended that the hospital’s motion for summary judgment be granted. The U.S. District Court concluded that the magistrate judge had made the proper ruling and affirmed. It dismissed the case with prejudice.