Byrne v. Cleveland Clinic, 519 Fed. Appx. 739, 2013 U.S. App. LEXIS 5362 (3d Cir. 2013)

(The facts of this case are taken primarily from the District Court opinion, available at Byrne v. Chester County Hosp., 2012 The plaintiff presented to the emergency room with severe shortness of breath and chest pain. The hospital had a standard screening procedure for all ER patients, which included taking a history, screening for domestic violence, questioning for symptoms, and creating a record of risk factors. The hospital also had a policy tailored to chest pain, which included increased questioning, and which could lead to either an EKG, a cardiac work-up, and/or a chest x-ray. The nurse performed a check-up and many of the other tests that were required under the policies, including an oxygen saturation check, an EKG, and a chest x-ray. The court also considered the affidavit of the Senior Vice President of the hospital, stating that the patient was screened in the same manner as other patients who complained of chest pain.

In granting summary judgment, the court found that the evidence submitted by the hospital was sufficient to rebut the pro se plaintiff’s claims, particularly relying on the sworn affidavit. On appeal, the Third Circuit, in one of its few cases on EMTALA, granted deference to the district court’s finding of appropriateness, finding it “unnecessary in the instant appeal to embark on an exhaustive analysis of what constitutes an appropriate medical screening under EMTALA.” The court affirmed without significant discussion on the issues.

Notes: The opinion suggests that an “exhaustive analysis” of appropriate medical screening may be required when the evidence is not sufficiently clear to show that a hospital complied with its own policies.