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The Emergency Medical Treatment and Active Labor Act (EMTALA) requires hospitals to provide appropriate medical screening and stabilizing treatment to individuals seeking emergency care in a nondiscriminatory manner. Patients are entitled under EMTALA, not to correct or non-negligent treatment in all circumstances, but to be treated as other similarly situated patients are treated within the hospital's capabilities. It is up to the hospital itself to determine what its screening procedures will be. Having done so, it must apply them alike to all patients.
Plaintiff William Byrne entered the emergency department of Chester County Hospital in West Chester, Pennsylvania, around 5:00 p.m. on February 15, 2007, experiencing chest pains and shortness of breath. Within 20 minutes of his arrival, emergency department personnel drew blood and requested an EKG. A chest x-ray was performed approximately 30 minutes later. It took several hours before the plaintiff was actually examined by the emergency department physician. The examination was followed by a visit from a cardiologist and a catherization procedure which was concluded around 11:30 p.m. of the same day. Plaintiff subsequently filed a complaint against The Cleveland Clinic ("Clinic") and Chester County Hospital ("Hospital"), setting forth claims under the Emergency Medical Treatment and Active Labor Act ("EMTALA"), 42 U.S.C. § 1395dd, as well as a claim for breach of implied contract under Pennsylvania law. Plaintiff asserted that the Clinic and the Hospital entered into an implied contract with him and the public providing that a stent procedure would be conducted within 90 minutes or less from the time that a person enters into an emergency room. Plaintiff alleged that, due to his delayed treatment, the Hospital breached that contractual agreement. Defendants moved separately to dismiss plaintiff’s complaint. The district court granted the defendant hospital’s motion. Plaintiff appealed.
Under the circumstances, could the defendants be held liable under the EMTALA?
The court held that the district court properly granted summary judgment on the patient's cause of action under EMTALA's screening provision. The record evidence demonstrated that the hospital's screening examination was not so cursory that it would have failed to identify acute and severe symptoms alerting the physician of the need for immediate medical attention to prevent serious bodily injury, and the evidence demonstrated that the hospital applied its screening policies uniformly at the time the patient sought care.