Published by Arfaa Law Group
When patients enter an emergency room, they expect prompt evaluation and stabilization, regardless of insurance status, background, or appearance. Federal law, through the Emergency Medical Treatment and Labor Act (EMTALA), protects that expectation by requiring hospitals to provide appropriate medical screening and stabilization. Yet as a recent Maryland case demonstrates, proving a violation of EMTALA requires more than a patient’s personal account; it requires evidence showing disparate treatment or failure to follow hospital protocols. If you were denied emergency medical care, speaking with an experienced Baltimore medical malpractice attorney can help you understand the law and your rights.
History of the Case
It is reported that the plaintiff sought emergency care at the defendant hospital after experiencing sharp chest pain. Despite an empty waiting room, she alleged that she waited for two hours without being evaluated. During that time, she fell and injured herself while attempting to get attention from hospital staff. Following the fall, the emergency triage team evaluated and treated her.
It is alleged that the plaintiff believed the delay in screening was racially motivated because she wore a mask with the phrase “Black Lives Matter.” She claimed that one of the nurses disagreed with her mask and allowed her to wait without medical attention. The plaintiff further asserted that she was prematurely discharged, forcing her to seek care elsewhere. At the same time, the defendant contended that she left against medical advice, supported by medical records documenting her decision.
It is reported that the plaintiff filed suit asserting both negligence and EMTALA violations. The court dismissed the negligence claims, leaving only EMTALA allegations to proceed. After discovery, the defendant moved for summary judgment, asserting that the hospital complied with EMTALA and that the plaintiff had no admissible evidence to support her claims.
Analysis of EMTALA Obligations
On review, the court explained that EMTALA requires hospitals with emergency departments to provide appropriate screening to determine whether an emergency condition exists, and if one is identified, to stabilize the patient or properly transfer them. The statute’s purpose is to prevent patient “dumping” based on inability to pay, and its focus is on whether patients are treated uniformly, not on the quality of care under state malpractice standards.
The court emphasized that to succeed on a claim for failure to screen, a plaintiff must show either that she was not screened at all or that she received materially different screening from others with similar conditions. Here, the plaintiff conceded that she was evaluated and treated, but claimed the evaluation was delayed and inadequate. She did not, however, provide evidence that the hospital’s actions deviated from its own policies or that patients with similar symptoms were treated differently. Without such evidence, her claims could not meet EMTALA’s standard.
The plaintiff also attempted to raise a “failure to stabilize” claim in response to the hospital’s summary judgment motion. The court noted that EMTALA’s duty to stabilize arises only after a hospital determines that an emergency condition exists. Because the plaintiff’s allegations centered on delays in screening rather than post-diagnosis stabilization, her claim did not fit within EMTALA’s requirements. Moreover, new claims cannot be raised at the summary judgment stage. For these reasons, the court found her failure-to-stabilize argument legally deficient.
The court granted summary judgment in favor of the defendant, holding that the plaintiff failed to present evidence showing a violation of EMTALA. While acknowledging the plaintiff’s sincere belief that she had been mistreated, the court explained that unsupported allegations and unsworn statements are not enough to overcome the evidentiary burden. EMTALA requires plaintiffs to show concrete proof of disparate treatment or deviations from hospital procedures, which the plaintiff did not provide.
Talk to an Experienced Baltimore Medical Malpractice Attorney
If you were denied necessary emergency medical care, it is essential to seek counsel from an attorney who understands both federal protections and state malpractice standards. At Arfaa Law Group, our Baltimore medical malpractice attorneys are committed to advocating for patients’ rights and ensuring fair treatment under the law. Call our office at (410) 889-1850 or complete our online contact form to schedule a consultation today.