No, the hospital did not break the law. This law was made to stop hospitals from refusing to treat people because they couldn't pay (known as 'patient dumping'), not to punish every medical mistake. As long as a hospital gives the same kind of check-up to every person with similar symptoms, it's following the rule. There was no proof this hospital treated Brenda differently than anyone else. The rule about making a patient stable before a transfer only applies if the hospital *actually knows* there's a life-threatening emergency. Here, the doctor honestly thought her problem was psychiatric, not a brain injury, so the hospital didn't know it had to stabilize her for a head trauma before the transfer.

No, the law says you can only sue hospitals for these issues, not the doctors themselves. The court agreed with this and said the lawsuit against the doctors couldn't go forward.

No. A hospital does not violate EMTALA if it uniformly applies its standard screening procedures, even if it results in a misdiagnosis, and the statute's stabilization and transfer provisions are triggered only by the hospital's actual knowledge of an emergency medical condition. First, the plain language and legislative history of EMTALA make clear that private civil actions for damages may only be brought against hospitals, not individual physicians. Second, the requirement for an 'appropriate medical screening' does not establish a national standard of care akin to medical malpractice. Instead, it requires a hospital to develop a screening procedure and apply it uniformly to all patients with similar complaints. Mr. Baber failed to produce evidence that RGH treated his sister differently than any other patient in a similar condition. Third, EMTALA's requirements to stabilize a patient before transfer apply only when 'the hospital determines that the individual has an emergency medical condition.' This statutory language requires actual knowledge by the hospital, not a constructive 'should have known' standard. There was no evidence that RGH or its staff actually knew Ms. Baber had a life-threatening head injury at the time of transfer. Finally, BARH had no duty to screen Ms. Baber because the screening requirement is triggered only when a patient 'comes to the emergency department,' which she did not.

No, EMTALA does not permit a private cause of action against physicians for violations of its provisions, and it does not require hospitals to provide a nationally standardized level of care in screening patients. We affirm the district court's grant of summary judgment for the defendants because: 1) The plain language of EMTALA and its legislative history clearly indicate that Congress intended to limit patients' right to recover damages for EMTALA violations to suits against hospitals, not individual physicians. 2) EMTALA requires hospitals to provide a uniform standard screening procedure to all patients with similar symptoms, but this standard is specific to each hospital and does not create a national standard of care. The statute only requires hospitals to apply their standard screening examination uniformly; it does not guarantee that emergency personnel will correctly diagnose a patient's condition. 3) To establish an EMTALA violation for failure to stabilize and appropriately transfer a patient, the plaintiff must show that the hospital had actual knowledge of the patient's emergency medical condition. Mr. Baber failed to present evidence that RGH knew Brenda had an emergency medical condition at the time of her transfer to BARH. 4) BARH did not violate EMTALA's screening requirement because Brenda was admitted directly to the psychiatric unit and did not come to the emergency department. EMTALA's screening requirement only applies to patients who seek treatment from the emergency department.

Baber v. Hospital Corp. of America

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