Roberts v. Galen of Virginia, Inc.
525 U.S. 249, 1999 U.S. LEXIS 508, 142 L. Ed. 2d 648 (1999)
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Rule of Law:
A plaintiff is not required to prove that a hospital acted with an improper motive to recover for a violation of the stabilization requirement under the Emergency Medical Treatment and Active Labor Act (EMTALA).
Facts:
- In May 1992, Wanda Johnson was run over by a truck, sustaining severe injuries to her brain, spine, leg, and pelvis.
- Johnson was taken to Humana Hospital-University of Louisville, where she remained for approximately six weeks.
- During her stay at Humana, Johnson's health condition remained volatile.
- Humana's agents arranged for Johnson to be transferred to the Crestview Health Care Facility in Indiana.
- Immediately upon her arrival at Crestview, Johnson's condition deteriorated significantly.
- As a result of her deterioration, she was taken to a third facility, Midwest Medical Center, where she incurred substantial medical expenses.
- Johnson's application for Indiana's Medicaid was rejected because she did not meet the state's residency requirements.
Procedural Posture:
- Jane Roberts, as guardian for Wanda Johnson, filed a lawsuit in federal District Court against Humana Hospital, alleging a violation of EMTALA.
- The District Court granted summary judgment for the hospital, finding the plaintiff had failed to show the transfer was caused by an improper motive.
- Roberts, as the appellant, appealed the decision to the U.S. Court of Appeals for the Sixth Circuit.
- The Court of Appeals affirmed the District Court's ruling, holding that a plaintiff must show an improper motive to state a claim under § 1395dd(b).
- The U.S. Supreme Court granted certiorari to review the Sixth Circuit's decision.
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Issue:
Does a plaintiff need to prove that a hospital acted with an improper motive to recover for a violation of the stabilization requirement under the Emergency Medical Treatment and Active Labor Act (EMTALA), 42 U.S.C. § 1395dd(b)?
Opinions:
Majority - Per Curiam
No. A plaintiff is not required to prove an improper motive to establish a violation of EMTALA's stabilization requirement. The plain text of § 1395dd(b) requires a hospital that has determined an individual has an 'emergency medical condition' to provide treatment to 'stabilize the medical condition.' Unlike the 'appropriate medical screening' language in subsection (a), which some lower courts have interpreted as requiring an improper motive, subsection (b) contains no such language or qualification. The statute imposes a direct obligation to stabilize a patient, and its text does not contain any express or implied requirement concerning the hospital's subjective motive for failing to do so. The Court noted that even the respondent hospital conceded that the 'improper motive' test lacks support in the statutory text.
Analysis:
This decision significantly clarifies the standard for claims brought under EMTALA's stabilization provision, resolving a disagreement among the circuit courts. By eliminating the 'improper motive' requirement, the Court lowered the evidentiary burden for plaintiffs, who no longer need to prove a hospital's subjective intent, such as a desire to avoid treating an indigent patient. The ruling shifts the legal focus from the hospital's reasons to its objective actions, reinforcing EMTALA as a strict mandate for patient care rather than an anti-discrimination statute. This makes it easier for patients to hold hospitals liable for prematurely transferring them in an unstable condition.
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