No. 97-53 Roberts v. Galen of Virginia, Inc.

PETITIONER: No. 97-53 Roberts
RESPONDENT: Galen of Virginia, Inc.
LOCATION: Elizabeth Township, Allegheny County

DOCKET NO.: 97-53
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 525 US 249 (1999)
ARGUED: Dec 01, 1998
DECIDED: Jan 13, 1999

ADVOCATES:
Carter G. Phillips - Argued the cause for the respondent
James A. Feldman - For the United States, as amicus curiae, supporting the petitioner
Joseph H. Mattingly, III - Argued the cause for the petitioner

Facts of the case

Wanda Johnson was run over by a truck in May 1992 and was rushed to the Humana Hospital-University of Louisville, Kentucky, now Galen of Virginia, Inc. After about six weeks at Galen, during which time Johnson's health remained in a volatile state, Galen's agents arranged for her transfer to the Crestview Health Care Facility in Indiana. Johnson was transferred to Crestview in July, and upon arrival her condition deteriorated significantly. Johnson was taken to the Midwest Medical Center where she remained for many months and incurred substantial medical expenses as a result of her deterioration. Jane Roberts, Johnson's guardian, then filed a federal action under the Emergency Medical Treatment and Active Labor Act (EMTALA), alleging violations of Section 1395dd(b) of the Act. Section 1395dd of the Act places obligations of screening and stabilization upon hospitals and emergency rooms that receive patients suffering from an "emergency medical condition." The District Court granted summary judgment for Galen on the ground that Roberts 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." In affirming, the Court of Appeals held that in order to state a claim in an EMTALA suit alleging a violation of Section 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.

Question

Must a plaintiff prove that a hospital acted with an improper motive in failing to stabilize a patient in order to prove a violation of the Emergency Medical Treatment and Active Labor Act?

Media for No. 97-53 Roberts v. Galen of Virginia, Inc.

Audio Transcription for Oral Argument - December 01, 1998 in No. 97-53 Roberts v. Galen of Virginia, Inc.

William H. Rehnquist:

We'll hear argument now in No. 97-53, Jane M. Roberts v. Galen of Virginia, Inc.--

Mr. Mattingly.

Joseph H. Mattingly, III:

Mr. Chief Justice, and may it please the Court:

This case comes to this Court on the claim of Wanda Johnson, a Kentucky resident, who claims that the respondent hospital violated the antidumping provisions of the Emergency Medical Treatment and Active Labor Act passed by Congress in 1986.

Ms. Johnson's claim was dismissed by the district court on summary judgment.

That dismissal was upheld by the court of appeals on the sole issue of whether or not the statute requires proof of an improper motive on the part of the offending hospital as a prerequisite for recovery.

This Court granted certiorari on that specific issue and that specific issue only.

The respondent in this case has conceded that it can no longer defend the rationale of the lower courts, that the statute cannot be read as requiring proof of an improper motive.

Therefore, this case is ripe for reversal and remand to the trial court.

This Court could make that decision and say very little more.

Sandra Day O'Connor:

Mr. Mattingly, do you contend that this statute, this emergency medical care statute, incorporates some kind of substantive standard of medical care?

Joseph H. Mattingly, III:

Justice O'Connor, the statute provides, number one, a duty on the part of the hospital to provide an appropriate medical screening examination, and it does, by definition of some of the key terms, refer to an obligation on the hospitals not to transfer patients if that transfer would cause a substantial deterioration in a patient's condition.

So, arguably, yes, it does create a minimum standard.

However, if we think about what that standard is... hospital, you cannot transfer a patient if that transfer is going to be the cause of material deterioration in a substantial condition of that patient... I can't imagine that any State standard would be lower than that.

You can't transfer if that transfer is going to be the cause of deterioration.

Sandra Day O'Connor:

Well, it says... it doesn't really talk about deterioration.

It says that the hospital can't transfer until there's been... until the condition has been stabilized.

Is that it?

Joseph H. Mattingly, III:

That's correct, Your Honor.

However, the... the definition of... of stabilized and to stabilize indicate that, within reasonable medical probability, no deterioration would occur to... to a condition that the patient had at the time of transfer.

Sandra Day O'Connor:

Now, in... in... in this situation, if Ms. Johnson had been stabilized at the time she was initially admitted to the emergency room, could she then have been transferred?

Joseph H. Mattingly, III:

Your Honor, again, if... if--

Sandra Day O'Connor:

I mean, is... doesn't this statute really focus on what happens in the emergency room and the stabilization there?

Could she at that point have been admitted to general admission in the hospital or sent elsewhere?

Joseph H. Mattingly, III:

--Justice O'Connor, in my opinion no.

Unfortunately, that's not an issue that--

Sandra Day O'Connor:

No.

Joseph H. Mattingly, III:

--that the parties have had an opportunity to fully brief--

Sandra Day O'Connor:

I just wondered what your view of it was because on the surface it would appear that this statute just addresses itself to emergency room care.

Joseph H. Mattingly, III:

--I would disagree with that analysis for a couple of reasons, Your Honor.