Roberts v. Galen of Va., Inc.
Annotate this Case
525 U.S. 249 (1999)
OCTOBER TERM, 1998
ROBERTS, GUARDIAN FOR JOHNSON v. GALEN OF VIRGINIA, INC., FORMERLY DBA HUMANA HOSPITALUNIVERSITY OF LOUISVILLE, DBA UNIVERSITY OF LOUISVILLE HOSPITAL
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT
No. 97-53. Argued December 1, 1998-Decided January 13, 1999
The Emergency Medical Treatment and Active Labor Act (EMTALA) places screening and stabilization obligations upon hospitals and emergency rooms that receive patients suffering from an emergency medical condition. Among other things, the statute requires a hospital with an emergency department to provide "an appropriate medical screening examination" for an emergency room patient, 42 U. S. C. § 1395dd(a); requires the hospital to provide either medical examination and treatment to stabilize the patient, or for transfer to another medical facility, § 1395dd(b); and authorizes civil fines and a private cause of action for violations of the statute, § 1395dd(d). A severely injured Wanda Johnson was rushed to respondent's hospital and remained there, in a volatile state of health, for about six weeks. She was then transferred to another facility, where her condition deteriorated significantly. Petitioner Roberts, her guardian, filed a § 1395dd(d) action, alleging § 1395dd(b) violations. The District Court granted respondent summary judgment on the grounds that petitioner had failed to show that either the medical opinion that Johnson was stable or the decision to transfer her was caused by an improper motive. The Sixth Circuit affirmed, holding that § 1395dd(b) requires proof of an improper motive.
Held: Section 1395dd(b) does not require proof that a hospital acted with an improper motive in failing to stabilize a patient. The Sixth Circuit's holding extended earlier Circuit precedent deciding that § 1395dd(a)'s "appropriate medical screening" duty also required proof of an improper motive. See Cleland v. Bronson Health Care Group, Inc., 917 F.2d 266. There, the court was concerned that the term "appropriate" might be interpreted incorrectly to permit federal liability under EMTALA for any violation covered by state malpractice law. Id., at 271. However, § 1395dd(b)'s text contains no appropriateness requirement, nor can it reasonably be read to require an improper motive. The Court declines to address, at this stage of the litigation, respondent's two alternative grounds for affirming the decision below.
111 F.3d 405, reversed and remanded.
Joseph H. Mattingly III argued the cause and filed briefs for petitioner.
James A. Feldman argued the cause for the United States as amicus curiae urging reversal. With him on the brief were Solicitor General Waxman, Assistant Attorney General Hunger, Deputy Solicitor General Kneedler, and Barbara C. Biddle.
Carter G. Phillips argued the cause for respondent. With him on the brief were Jacqueline Gerson Cooper and Thomas S. Calder.*
The 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, 42 U. S. C. § 1395dd, places obligations of screening and stabilization upon hospitals and emergency rooms that receive patients suffering from an "emergency medical condition." The Court of Appeals held that in order to recover in a suit alleging a violation of § 1395dd(b), a plaintiff must prove that the hospital acted with an improper motive in failing to stabilize her. Finding no support for such a requirement in the text of the statute, we reverse.
Section 1395dd(a) imposes a "[m]edical screening requirement" upon hospitals with emergency departments: "[I]f any individual ... comes to the emergency department and a request is made on the individual's behalf for examination or treatment for a medical condition, the hospital must provide for an appropriate medical screening examination within the capability of the hospital's emergency department." 42 U. S. C. § 1395dd(a). Section 1395dd(b), entitled "Necessary
*Martha F. Davis filed a brief for the NOW Legal Defense and Education Fund et al. as amici curiae urging reversal.
Thomas W Merrill, Michael L. Ile, Leonard A. Nelson, and Robert M.
Portman filed a brief for the American Hospital Association et al. as amici curiae urging affirmance.