Moses v. Providence Hospital & Medical Centers, Inc.
2009 WL 902076, 2009 U.S. App. LEXIS 7049, 561 F.3d 573 (2009)
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Rule of Law:
The Emergency Medical Treatment and Active Labor Act (EMTALA) permits any individual who suffers direct personal harm from a hospital's violation to sue the hospital, not just the patient. A hospital's duty to stabilize an emergency medical condition, including a psychiatric crisis, is not satisfied by mere inpatient admission and requires treatment until the condition is stable upon discharge.
Facts:
- Marie Moses-Irons brought her husband, Howard, to the Providence Hospital emergency room for physical symptoms and psychiatric symptoms, including hallucinations, delusions, and disorientation.
- Moses-Irons informed hospital staff that Howard had exhibited threatening behavior, mentioned buying caskets, recently tried to board a plane with a hunting knife, and that she was fearful for her safety.
- Howard was admitted to the hospital for observation and testing.
- During the hospital stay, Dr. Paul Lessem, a psychiatrist, diagnosed Howard with 'atypical psychosis' and determined he was not 'medically stable from a psychiatric standpoint.'
- Dr. Lessem ordered Howard transferred to the hospital's psychiatric unit ('4 East') and placed on 'suicide precautions.'
- Howard was never transferred to the psychiatric unit.
- One day after the transfer order, the hospital decided to discharge Howard, with a final diagnosis of 'atypical psychosis [with] delusional disorder' and a note that his wife still 'fears him.'
- Ten days after his discharge on December 19, 2002, Howard murdered Marie Moses-Irons.
Procedural Posture:
- Johnella Richmond Moses, as representative of Marie Moses-Irons's estate, filed suit against Providence Hospital and Dr. Paul Lessem in the United States District Court.
- Defendants filed a motion to dismiss, arguing only patients have a right to sue under EMTALA, which the district court denied.
- Defendants later filed a motion for summary judgment on several grounds, including lack of standing and fulfillment of EMTALA duties.
- The district court granted Defendants' motion for summary judgment, dismissing the EMTALA claim.
- Plaintiff, as the appellant, appealed the grant of summary judgment to the U.S. Court of Appeals for the Sixth Circuit.
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Issue:
Does the Emergency Medical Treatment and Active Labor Act (EMTALA) permit a non-patient, who was harmed by a patient, to sue a hospital for failing to stabilize that patient's emergency psychiatric condition before discharging him?
Opinions:
Majority - Clay, Circuit Judge
Yes. EMTALA permits a non-patient harmed by a prematurely discharged patient to sue the hospital because the statute's plain language provides a cause of action to 'any individual who suffers personal harm as a direct result' of a violation. The court found this broad language was intentional, as other sections of the same statute are specifically limited to patients who 'come to a hospital.' Furthermore, the court held that a hospital's duty under EMTALA is not satisfied by merely admitting a patient; the hospital must provide treatment until the emergency medical condition is stabilized. Citing its precedent in Thornton v. Sw. Detroit Hosp., the court reasoned that 'Emergency care must be given until the patient’s emergency medical condition is stabilized.' Because the plaintiff presented sufficient evidence to create a genuine issue of material fact as to whether the hospital recognized Howard had an emergency psychiatric condition and failed to stabilize it before discharge, summary judgment for the hospital was improper. However, the court affirmed summary judgment for Dr. Lessem, holding that EMTALA’s civil enforcement provision authorizes suits only against participating hospitals, not individual physicians.
Analysis:
This decision significantly broadens the scope of potential liability for hospitals under EMTALA. By interpreting 'any individual' to include non-patients, the court extends a hospital's duty of care beyond the patient to third parties who are foreseeably harmed by a failure to stabilize. The ruling solidifies that acute psychiatric conditions qualify as 'emergency medical conditions' under the statute, reinforcing that mental health crises must be fully stabilized before discharge. This precedent will likely influence hospital discharge protocols for psychiatric patients and increases the legal risks for facilities that release patients whose mental state may pose a danger to others.
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