Thornton v. Southwest Detroit Hosp., 895 F.2d 1131, 1990 U.S. App. LEXIS 1643 (6th Cir. 1990)

After suffering a stroke, the patient sought care at the hospital’s emergency room and was subsequently admitted. The patient spent ten days in the ICU and eleven days in inpatient care. The patient’s doctor sought out a rehabilitation facility that would admit the patient for post-stroke rehabilitation, but the facility refused because the patient’s health insurance would not cover the cost. The patient was discharged from the hospital and her condition deteriorated before gaining admission to a rehabilitation institute.

The plaintiff brought a stabilization claim against the hospital, and the defendant moved for summary judgment. In one of the earliest cases to determine whether the admission of a patient cuts off EMTALA liability for a hospital, the court focused on the reading of the definition sections of the statute. The court noted that the screening requirement applies to a patient who comes to a “hospital emergency room,” but that the stabilization requires a “hospital” to give necessary stabilizing treatment. The court found the difference in language to be controlling and to require a “hospital,” and not just its emergency department, to stabilize a patient until discharge regardless of whether that individual was admitted as an inpatient for a period of time. Id. at 1134. The court, in one of the broadest readings of the stabilization requirement, explained that “once a patient is found to suffer from an emergency medical condition in the emergency room, she cannot be discharged until the condition is stabilized, regardless of whether the patient stays in the emergency room.” Id. The court also looked to the legislative history and noted that Congress was primarily concerned with ensuring that patients received “emergency care,” which “does not always stop when a patient is wheeled from the emergency room into the main hospital.” Id. at 1135.  The court ultimately held that, in the case before it, the hospital had stabilized the patient’s condition and, thus, the defendant was not liable under EMTALA, although stressing that it was not basing its holding solely on the fact that the patient was admitted.

Notes: This is an early case, and several Circuit Courts and CMS have weighed in on the issue of whether EMTALA requirements end once a patient is admitted to the hospital. Read more here.