Maryland Court Discusses The Duty to Provide Emergency Medical Care

Pursuant to federal law, health care providers generally must provide people suffering from critical health concerns with emergency care, regardless of their ability to pay. As such, if a medical facility refuses to treat an indigent patient, they can be liable for civil damages. As discussed in a recent Maryland case, however, this duty to provide emergent care ends when a person is admitted as an inpatient. If you were hurt by inadequate medical care, it is wise to speak to a Maryland medical malpractice attorney about your rights.

Case Background

It is reported that the plaintiff filed a lawsuit against the defendant in federal court, alleging that he received inadequate care in July 2019, at the defendant’s health care center. He further claimed that this care violated the Emergency Medical Treatment and Active Labor Act (EMTALA) and that the United States, the defendant, and the defendant’s employees were liable for medical malpractice, lack of informed consent, and patient abandonment under state tort law. The plaintiff later dismissed his claims against the United States. The defendant filed a motion to dismiss the EMTALA claim or, alternatively, for summary judgment. The plaintiff initially consented to dismissal without prejudice but later opposed it. The court treated the motion as one for summary judgment.

The Duty to Provide Emergency Care

The court began by discussing EMTALA, highlighting that its purpose is to ensure hospitals provide emergency care to all, regardless of their ability to pay. It imposes a duty on hospitals to screen and stabilize emergency conditions. If a hospital admits a patient for inpatient treatment in good faith, its obligations under EMTALA end. Liability under EMTALA is limited and does not cover misdiagnosis or general malpractice.


When analyzing the plaintiff’s EMTALA claim, the court found no genuine dispute that Adventist admitted him as an inpatient on July 16, 2019. According to EMTALA, an inpatient is defined as an individual admitted to a hospital with the expectation of remaining overnight, even if they are later discharged or transferred. The court cited medical records and evidence supporting the plaintiff’s inpatient status.

Further, the court noted the plaintiff’s claim that he was under “23 Hour Observation” was contradicted by the medical records, which showed he received inpatient care from 2:49 p.m. on July 16 until 10:58 a.m. on July 17. Finally, the court found that testimony from various witnesses did not raise a genuine dispute of material fact as to the EMTALA claim. Therefore, the defendant’s motion for summary judgment on the EMTALA claim was granted.

With the EMTALA claim resolved, only the tort claims for medical malpractice, lack of informed consent, and patient abandonment remained. As the court lacked original jurisdiction over these claims, it could decline to exercise supplemental jurisdiction over them. Considering judicial economy, convenience, fairness, and comity, the court opted to decline jurisdiction over the state law claims, dismissing them without prejudice.

Meet with a Skilled Maryland Attorney

Doctors who refuse to provide patients with necessary treatment may be liable for medical malpractice and may violate state and federal laws as well. If you were hurt by incompetent medical care, you could be owed compensation, and you should speak to an attorney. The skilled Maryland lawyers of Arfaa Law Group can inform you of your options and aid you in seeking any recoverable damages. You can reach us through our online form or by calling us at (410) 889-1850 to set up a conference.

Contact Information