Hospital Admitted Patient in Good Faith, Not as Ruse to Avoid EMTALA Obligations, Fourth Circuit Holds

June 10, 2020 | Strategic Insights for Health System


In an Emergency Medical Treatment and Labor Act (EMTALA) lawsuit brought against a hospital by a patient injured in a car crash, the U.S. Court of Appeals for the Fourth Circuit found that the treating hospital satisfied EMTALA's requirements because it admitted the plaintiff for medical treatment in good faith, not as a ruse to avoid its obligations under EMTALA. The court thus affirmed judgment for the hospital.

After suffering serious injuries, particularly to his legs, during a single-car rollover, the patient arrived at the hospital at 1:33 a.m. Staff began screening him. Within 20 minutes, he was intubated, and a trauma surgeon performed a cutdown to permit infusion of large volumes of blood and fluid. Computed tomography scans were completed within an hour and a half of his arrival, and radiographs were obtained about an hour later. His first surgery, which lasted more than six...

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