Stanley v. C L H G - DeQuincy L L C, 2:22-cv-06170

On Dec. 15, 2020, Robert Stanley went to DeQuincy Memorial Hospital (DMH) with possible heart-attack symptoms; his wife Deanette Stanley sought care for him.
Hospital staff (employee Laiken and nurse Ellen Naquin, RN) interacted with the Stanleys at the ER entrance; Mrs. Stanley testifies they were told Mr. Stanley could not come inside and was to remain in the vehicle.
Nurse Naquin spoke to Mr. Stanley through the car window, performed no vital signs or physical assessment, and allegedly told them he was not having a heart attack and to buy a blood-sugar test.
The Stanleys left, tested blood sugar (normal), returned home; later Mr. Stanley deteriorated, suffered cardiac arrest, and died in an ambulance that night; cause of death listed as hypertensive cardiovascular disease.
Defendant disputes many facts: Naquin says she offered to evaluate him inside and that Mr. Stanley declined; facts about whether any screening occurred are contested.
Plaintiff sued under EMTALA (42 U.S.C. § 1395dd). DMH moved for summary judgment arguing no genuine issue that Mr. Stanley was refused screening and no causation without expert proof; the court denied summary judgment, finding genuine fact issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mr. Stanley presented to DMH’s ED and requested examination	Stanley says she brought husband to ED seeking evaluation for possible heart attack	DMH says Mr. Stanley declined to come inside and thus no refusal to screen	Court: Fact dispute exists; reasonable juror could find he presented and sought care
Whether DMH failed to provide an appropriate medical screening exam	Stanley: No vitals or assessment performed; nurse only spoke through window and told them he was fine	DMH: Nurse offered to evaluate inside; denies turning them away or failing to assess	Court: Evidence viewed for nonmovant creates genuine dispute whether an MSE occurred
Causation — whether lack of screening caused death	Stanley: death certificate lists hypertensive cardiovascular disease; causation for jury without expert	DMH: Plaintiff lacks expert to link the alleged screening failure to death	Court: Denied summary judgment on causation — factual disputes allow jury to decide causation
Whether summary judgment appropriate under Rule 56	Stanley: Material facts are disputed and must go to jury	DMH: No probative evidence to create genuine dispute on EMTALA elements	Court: Rule 56 favors nonmovant where reasonable juror could find for plaintiff; motion denied

Tubacex, Inc. v. M/V Risan, 45 F.3d 951 (5th Cir. 1995) (movant’s initial burden in summary-judgment practice)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (nonmovant must show genuine factual dispute with significant probative evidence)
State Farm Life Ins. Co. v. Gutterman, 896 F.2d 116 (5th Cir. 1990) (summary-judgment evidentiary burden explained)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (court cannot weigh credibility at summary judgment)
Clift v. Clift, 210 F.3d 268 (5th Cir. 2000) (evidence must be viewed in light most favorable to nonmovant)
Brumfield v. Hollins, 551 F.3d 322 (5th Cir. 2008) (reasonable juror standard for genuine issue of material fact)