The U.S. District Court for the Eastern District of Pennsylvania properly ruled in favor of several hospitals and doctors who allegedly violated the Emergency Medical Treatment and Active Labor Act (EMTALA), 42 U.S.C. § 1395dd, by failing to stabilize and inappropriately transferring a patient, when the patient in question did not present herself in an emergent state and was not in an emergent state until she began to undergo monitoring at the primary hospital.
One of the plaintiffs was a woman whose pregnancy was considered high risk due to her diabetes. On the morning of her child’s birth, she went to a routine outpatient fetal monitoring appointment at a perinatal facility. When she arrived, she complained of discomfort, yet was not alarmed about her condition and did not feel she was in an emergent state. She was subsequently administered a non-stress test, during which she began to experience increased pain and contractions. Based on the preliminary test results and her diabetic condition, her doctor terminated the non-stress test and sent her to her primary hospital for extended perinatal monitoring.
At her primary hospital, she waited approximately 15 to 20 minutes for a room and was examined. Upon review of the woman’s preliminary results, the woman was rushed into surgery and gave birth to a severely brain damaged child.
The child’s parents filed suit, asserting, among other things, that the hospitals and doctors violated EMTALA by failing to stabilize the mother’s emergency condition and inappropriately transferring her from the perinatal facility to her primary hospital.
The Third Circuit Court of Appeals held that, contrary to the parents’ assertion, the mother did not come to the hospital with an emergency medical condition. The mother was not in an emergent state until after she began the monitoring at the primary hospital and her condition quickly changed. Neither her previous complaints of discomfort nor her high-risk pregnancy amounted to an emergency under EMTALA. The circumstances failed to trigger EMTALA, and therefore precluded the parents’ EMTALA claim.
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