U.S. Supreme Court Addresses Emergency Medical Treatment and Labor Act

In Jane M. Roberts v. Galen of Virginia, Inc. ("Roberts"), the United States Supreme Court (the "Supreme Court") handed down its first decision addressing the Emergency Medical Treatment and Labor Act (EMTALA). EMTALA requires Medicare contracting hospitals to provide an "appropriate medicl screening examination" to determine whether an emergency condition exists whenever an individual seeks emergency services at a hospital's emergency room. If the hospital determines that an emergency exists, it is required to stabilize the patient before discharging the patient, or transferring the patient to another facility. In addition to these screening and stabilization requirements, EMTALA enables a patient to bring a personal injury suit against a hospital whenever a hospital fails to fulfill this statutory duty. In Roberts, the Supreme Court brought the Court of Appeals for the Sixth Circuit (the "Sixth Circuit") into conformity with the majority rule by holding that an EMTALA plaintiff does not need to prove that a hospital had an "improper motive" in order to prevail in a personal injury suit brought under EMTALA for the hospital's failure to stabilize a patient before transfer.

In Roberts, the plaintiff sustained severe injuries after being hit by a truck. After a six week stay at Humana Hospital (which is now operated by the defendant, Galen of Virginia, Inc.), the hospital transferred the plaintiff to a skilled nursing facility. Subsequent to the transfer, the plaintiff's medical condition deteriorated. Ultimately, the plaintiff had to be transferred to Midwest Medical Center for further inpatient medical treatment. The plaintiff brought a personal injury suit under EMTALA alleging that the hospital failed to adequately screen and stabilize her before transferring her to the skilled nursing facility.

The federal trial court granted the hospital's motion for summary judgment after finding that the plaintiff failed to prove that the hospital acted with an "improper motive" when it failed to stabilize her. On appeal, the Sixth Circuit affirmed the trial court and held that an EMTALA plaintiff must show that "the hospital's inappropriate stabilization resulted from an improper motive such as one involving the indigency, race, or sex of the patient."

The Supreme Court granted certiorari, and on review, reversed the Sixth Circuit's holding. The Supreme Court held that an EMTALA plaintiff need not demonstrate an "improper motive" when bringing suit for violation of the EMTALA provision that requires stabilization before transfer. The Supreme Court was not faced with the issue, and did not address, whether an EMTALA plaintiff must demonstrate an "improper motive" when alleging that a hospital failed to adequately screen a patient. However, the Supreme Court decision does note that the Sixth Circuit's caselaw on this issue is also in conflict with other jurisdictions. This suggests that the issue of whether a plaintiff must allege an improper motive before bringing a personal injury suit for the hospital's violation of the EMTALA screening provision is ripe for challenge and review as well. In summary, although Roberts is consistent with the majority rule, it is significant for preventing a line of cases from developing wherein plaintiffs might otherwise have been required to prove an improper motive when bringing a personal injury suit under EMTALA.