Freedman v. Fisher
2015 U.S. Dist. LEXIS 12323, 2015 WL 437431, 89 F. Supp. 3d 716 (2015)
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Rule of Law:
Under the Emergency Treatment and Labor Act (EMTALA), a hospital's screening duty requires it to provide uniform screening to all patients with substantially similar complaints, and its duty to stabilize a patient is only triggered by a 'transfer,' which is defined as movement to a facility outside the hospital, not an intra-hospital move.
Facts:
- Abraham Strimber presented to the emergency department at Abington Memorial Hospital (AMH) with multiple complaints, including chest and abdominal pain.
- An emergency department physician, Dr. Steven Fisher, examined Strimber, made a differential diagnosis, and ordered laboratory tests.
- Dr. Fisher then discharged Strimber from the emergency department and transferred him to an observation unit within the same hospital.
- Later in the day, Strimber was seen by an internal medicine specialist, Dr. Margo Turner, and a cardiologist, Dr. Muttreja.
- There were numerous conflicts in the medical records and deposition testimony regarding whether Strimber actually complained of chest pain to the medical staff.
- At 8:30 p.m., a nurse alerted Dr. Turner to a dangerous change in Strimber's cardiac condition.
- Strimber was taken to the catheterization lab where testing revealed a pericardial hemorrhage, and his condition rapidly deteriorated.
- Despite emergency measures, Strimber died at 10:49 p.m. from a dissecting aorta.
Procedural Posture:
- Plaintiffs, representing Abraham Strimber's estate, filed a complaint against Abington Memorial Hospital (AMH) in the U.S. District Court for the Eastern District of Pennsylvania.
- Plaintiffs filed a Motion for Leave to Amend the Complaint to add a claim under the Emergency Treatment and Labor Act (EMTALA), which the court granted.
- Plaintiffs filed a motion for partial summary judgment on their EMTALA claim.
- Defendant AMH filed a cross-motion for partial summary judgment on the plaintiffs' EMTALA claim, arguing it was time-barred and legally insufficient.
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Issue:
Under the Emergency Treatment and Labor Act (EMTALA), does a hospital violate the (1) screening requirement if a factual dispute exists as to whether it provided a patient with a different screening than other patients with similar symptoms, and (2) the stabilization requirement when it moves a patient from the emergency room to an observation unit within the same hospital?
Opinions:
Majority - J. William Ditter, Jr.
(1) Yes, a potential violation exists, but a genuine issue of material fact prevents summary judgment. (2) No, moving a patient within the same hospital does not violate the stabilization requirement. EMTALA's screening provision requires hospitals to provide uniform screening to all patients presenting with substantially similar complaints. Because the record contains conflicting evidence regarding Strimber's complaints of chest pain, a material issue of fact exists as to what screening was appropriate and whether AMH followed its standard procedure, which must be resolved by a jury. However, EMTALA's stabilization requirement applies only when a patient is 'transferred,' a term statutorily defined as the movement of an individual to a facility outside the hospital. Since Strimber was only moved from the emergency room to an observation unit within AMH, no 'transfer' occurred, and the stabilization claim fails as a matter of law.
Analysis:
This decision clarifies two distinct components of EMTALA liability, reinforcing its focus on disparate treatment rather than medical malpractice. It establishes that a screening claim can survive summary judgment if there is a factual dispute about the patient's presenting symptoms, which dictates the hospital's duty to provide uniform care. More significantly, the ruling creates a bright-line rule for stabilization claims by narrowly interpreting the statutory definition of 'transfer' to exclude intra-hospital movements, thereby limiting the scope of such claims to situations involving discharge or movement to an entirely separate facility.
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