Roberts v. Galen of Va., Inc.

Decision Date13 January 1999
Docket NumberNo. 97-53.,97-53.
Citation525 U.S. 249
PartiesROBERTS, guardian for JOHNSON v. GALEN OF VIRGINIA, INC., formerly dba HUMANA HOSPITALUNIVERSITY OF LOUISVILLE, dba UNIVERSITY OF LOUISVILLE HOSPITAL
CourtU.S. Supreme Court

CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

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.*

Per Curiam.

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 "medical screening requirement" upon hospitals with emergency departments: "If 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 stabilizing treatment for emergency medical conditions and labor," provides in relevant part as follows:

"(1) In general "If any individual (whether or not eligible for benefits under this subchapter) 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 to another medical facility in accordance with subsection (c) of this section. . . ."

Section 1395dd(c) generally restricts transfers of unstabilized patients, and § 1395dd(d) authorizes both civil fines and a private cause of action for violations of the statute.

Wanda Johnson was run over by a truck in May 1992, and was rushed to respondent's hospital, the Humana HospitalUniversity 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 time Johnson's health remained in a volatile state, respondent's agents arranged for her transfer to the Crest view Health Care Facility, across the river in Indiana. Johnson was transferred to Crestview on July 24, 1992, but upon arrival at that facility, her condition deteriorated 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 Indiana'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 federal action under § 1395dd(d) as codified, alleging violations of § 1395dd(b).

The District Court granted summary judgment for respondent on the grounds that petitioner had failed to show that "`either the medical opinion that Johnson was stable or the decision to authorize her transfer was caused by an improper motive.' " 111 F. 3d 405, 407 (CA6 1997). The Court of Appeals affirmed, holding that in order to state a claim in an EMTALA suit alleging a violation of § 1395dd(b)'s stabilization requirement, a plaintiff must show that the hospital's inappropriate stabilization resulted from an improper motive such as one involving the indigency, race, or sex of the patient. Id., at 411. In order to decide whether subsection (b) imposes such a requirement, we granted certiorari, 524 U. S. 915 (1998), and now reverse.

The Court of Appeals' holding—that proof of improper motive was necessary for recovery under § 1395dd(b)'s stabilization requirement—extended earlier Circuit precedent deciding that the "appropriate medical screening" duty under § 1395dd(a) also required proof of an improper motive. See Cleland v. Bronson Health Care Group, Inc., 917 F. 2d 266 (CA6 1990). The Court of Appeals in Cleland was concerned that Congress' use of the word "appropriate" in § 1395dd(a) might be interpreted incorrectly to permit federal liability under EMTALA for any violation covered by state malpractice law. Id., at 271. Accordingly, rather than interpret EMTALA so as to cover "at a minimum, the full panoply of state malpractice law, and at a maximum, . . . a guarantee of a successful result" in medical treatment, ibid., the Court of Appeals read § 1395dd(a)'s "appropriate medical screening" duty as requiring a plaintiff to show an improper reason why he or she received "less than standard attention upon arrival . . . at the emergency room," id., at 272.

Unlike the provision of EMTALA at issue in Cleland, § 1395dd(a), the provision at issue in this case, § 1395dd(b), contains no requirement of appropriateness. Subsection (b)(1)(A) requires instead the provision of "such further medical examination and such treatment as may be required to stabilize the medical condition." 42 U. S. C. § 1395dd(b)(1)(A). The question of the correctness of the Cleland court's reading of § 1395dd(a)'s "appropriate medical screening" requirement is not before us, and we express no opinion on it here.1 But there is no question that the text of § 1395dd(b) does not require an "appropriate" stabilization, nor can it reasonably be read to require an improper motive....

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    • United States
    • Court of Appeal of Michigan — District of US
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    ...of "improper motive" in a hospital's transfer decision, the United States Supreme Court reversed. Roberts v. Galen of Virginia, Inc., 525 U.S. 249, 119 S.Ct. 685, 142 L.Ed.2d 648 (1999). 89. Bryan v. Rectors & Visitors of Univ. of Virginia, 95 F.3d 349, 351 (C.A.4, 1996). 90. Id. at 350. 91......
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    ...Young v. United States, 315 U.S. 257, 258-59, 62 S.Ct. 510, 86 L.Ed. 832 (1942); see also Roberts v. Galen of Virginia, Inc., 525 U.S. 249, 253, 119 S.Ct. 685, 142 L.Ed.2d 648 (1999) (per curiam) ("Although the concession of a point on appeal by respondent is by no means dispositive of a le......
  • Sterling v. Johns Hopkins Hospital
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    • Court of Special Appeals of Maryland
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    ...and emergency rooms that receive patients suffering from an `emergency medical condition.'" Roberts v. Galen of Virginia, Inc., 525 U.S. 249, 250, 119 S.Ct. 685, 142 L.Ed.2d 648 (1999) (per curiam). The EMTALA provides a federal response to "patient dumping" by hospitals that are medicare p......
  • Florida v. U.S. Dep't of Health & Human Serv.
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    • U.S. Court of Appeals — Eleventh Circuit
    • August 12, 2011
    ...any patient who comes in with an "emergency medical condition." 42 U.S.C. § 1395dd(a)-(b); see also Roberts v. Galen of Va., Inc., 525 U.S. 249, 250-51 (1999) (per curiam). EMTALA alsorestricts the ability of hospitals to transfer a patient until he is stable or a medical determination is m......
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1 books & journal articles
  • APPENDIX A LEGAL CITATION
    • United States
    • Carolina Academic Press Oregon Legal Research (CAP)
    • Invalid date
    ...the Supreme Court addressed the requirement of motive for an EMTALA claim, the court rejected that requirement. Roberts v. Galen of Va., 525 U.S. 249, 253 (1999), rev'g 111 F.3d 405 (6th Cir. 1997). D. Signals A citation must show the level of support each authority provides. You do this by......

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