Roberts v. Galen of Virginia, Inc.Roberts v. Galen of Virginia, Inc.
Thе Emergency Medical Treatment and Active Labor Act (EMTALA), as added by § 9121(b) of the Consolidated Omnibus Budget Reconciliation Act of 1985, 100 Stat. 164, and as amended,
“(1) In general
“If any individual (whether or not eligible for benefits under this subehapter) comes to a hospital and the hospital determines that the individual has an emergency medical condition, the hospital must provide either—
“(A) within the staff and facilities available at the hospital, for such further medical examination and such treatment as may be required to stabilize the medical condition, or
“(B) for transfer of the individual tо another medical facility in accordance with subsection (e) of this section....”
Wanda Johnson was run over by a truck in May 1992, and was rushed to respondent’s hospital, the Humana Hospital-University of Louisville, in Louisville, Kentucky (Humana). Johnson had been severely injured and had suffered serious injuries to her brain, spine, right leg, and pelvis. After about six weeks’ stay at Humana, during which timе Johnson’s health remained in a volatile state, respondent’s agents arranged for her transfer to the Crestview Health Carе Facility, across the river in Indiana. Johnson was transferred to Crestview on July 24,1992, but upon arrival at that facility, her condition deteriоrated significantly. Johnson was taken to the Midwest Medical Center, also in Indiana, where she remained for many months and incurred substantial medical expenses as a result of her deterioration. Johnson applied for financial assistance under Indiаna’s Medicaid program, but her application was rejected on the ground that she had failed to satisfy Indiana’s residency requirements. Petitioner Jane Roberts, Johnson’s guardian, then filed this
The District Court granted summary judgment for respondent on the grounds that pеtitioner had failed to show that “‘either the medical opinion that Johnson was stable or the decision to authorize her trаnsfer was caused by an improper motive.’ ”
The Court of Appeals' holding — that proof of impropеr motive was necessary for recovery under
Unlike the provision of EMTALA at issue in
Cleland,
Although respondent presents two alternative grounds for the affirmance of the decision below,
2
we decline to address these claims at this stage in the litigation. The Court granted certiorari on only the EMTALA issue, and these сlaims do not appear to have been sufficiently developed
It is so ordered.
Notes
We note, however, that
Cleland’s
interpretation of subsection (a) is in conflict with the law of other Circuits which do not read subsection (a) as imposing an improper motive requirement. See
Summers
v.
Baptist Med. Center Arkadelphia,
Respondent argues that the record demonstratеs that it did not have actual knowledge of the patient’s condition, and that the hospital properly-screened Johnson, which terminated its duty under EMTALA. We express no opinion as to the factual correctness or legal dispositiveness of these claims, and leave their resolution to the courts below on remand.