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Baker v. Health Care Authority of City of Huntsville

United States District Court, N.D. Alabama, Northeastern Division

July 9, 2019

YVETTE BAKER, Plaintiff,



         This is a lawsuit filed under the Emergency Medical Treatment and Labor Act, 42 U.S.C. § 1395dd, et seq. (“EMTALA”) and Alabama state law against the Health Care Authority of the City of Huntsville d/b/a Huntsville Hospital, and two of its employees. Doc. 12. Congress enacted EMTALA to prevent hospitals from “turning away or transferring indigent patients without evaluation or treatment.” Harry v. Marchant, 291 F.3d 767, 768 (11th Cir. 2002) (en banc). In particular, EMTALA requires hospitals (1) to provide the appropriate medical screening and (2) to stabilize the individuals who present for treatment. Id. at 770 (citing 42 U.S.C. § 1395dd). According to Yvette Baker, Huntsville Hospital violated EMTALA by failing to conduct an appropriate screening examination when she presented for treatment at the Hospital's emergency department with symptoms of a stroke and failed to stabilize her after her admission. Doc. 12 at 6-7, 31-37.

         The defendants have moved to dismiss the lawsuit, contending that they provided a timely appropriate medical screening and treated Ms. Baker for the conditions she presented with, and ultimately stabilizing her. Docs. 15 and 16. The defendants' contentions are consistent with the allegations in Ms. Baker's complaint and proposed third amended complaint. Indeed, Ms. Baker does not dispute the defendants' contentions. She claims instead that the Hospital should have done more than it did in treating her. While that may be the case, EMTALA is not a medical malpractice statute. Therefore, Ms. Baker has failed to state a plausible EMTALA claim, and her EMTALA claims are due to be dismissed. In light of the dismissal of the federal claims, the court declines to exercise jurisdiction over the remaining state law claims.


         Under Federal Rule of Civil Procedure 8(a)(2), a pleading must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” “[T]he pleading standard Rule 8 announces does not require ‘detailed factual allegations,' but it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). Mere “‘labels and conclusions'” or “‘a formulaic recitation of the elements of a cause of action'” are insufficient. Id. at 678 (quoting Twombly, 550 U.S. at 555). “Nor does a complaint suffice if it tenders ‘naked assertion[s]' devoid of ‘further factual enhancement.'” Id. (quoting Twombly, 550 U.S. at 557).

         Federal Rule of Civil Procedure 12(b)(6) permits dismissal when a complaint fails to state a claim upon which relief can be granted. When evaluating a motion brought under Rule 12(b)(6), the court accepts “the allegations in the complaint as true and construe[s] them in the light most favorable to the plaintiff.” Hunt v. Aimco Props., L.P., 814 F.3d 1213, 1221 (11th Cir. 2016). However, “[t]o survive a motion to dismiss, a complaint must . . . ‘state a claim to relief that is plausible on its face.'” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 570). A complaint states a facially plausible claim for relief “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. In other words, the complaint must establish “more than a sheer possibility that a defendant has acted unlawfully.” Id.; see also Twombly, 550 U.S. at 555. Ultimately, this inquiry is a “context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Iqbal, 556 U.S. at 679.

         II. ANALYSIS

         To prevail on her EMTALA claim, Ms. Baker must plead facts showing that the Hospital violated the appropriate medical screening or stabilization requirements. Ms. Baker has failed to make either showing.

         A. Whether Ms. Baker asserts a plausible claim for alleged violations of EMTALA's screening requirement

         Under EMTALA, when an individual presents to an emergency department for examination or treatment, “the hospital must provide for an appropriate medical screening examination within the capability of the hospital's emergency department . . . to determine whether or not an emergency medical condition . . . exists.” 42 U.S.C. § 1395dd(a). An appropriate screening must be “calculated to identify critical medical conditions, ” and the screening an indigent individual receives “must be similar to that which would be provided for any other patient with similar complaints.” Harry v. Marchant, 237 F.3d 1315, 1319 (11th Cir. 2001) (citing Holcomb v Monahan, 30 F.3d 116, 117 (11th Cir. 1994)).[1] But, EMTALA is not a “substitute for a state malpractice claim, ” and its screening requirement “is not intended to ensure each emergency room patient a correct diagnosis.” Id. (citation omitted).

         According to the pleadings, the Hospital provided Ms. Baker with four screening examinations within an hour of her arrival, and initially diagnosed Ms. Baker with hypertensive emergency, head injury, and hypocalcemia. Docs. 12 at 13, 17, 21; 12-1 at 6-8. In addition, Ms. Baker alleges that a physician examined her and diagnosed her with a stroke several hours later. Docs. 12 at 19; 12-1 at 7. By Ms. Baker's own contentions, “[t]he facts alleged demonstrate that [the Hospital] conducted an initial screening examination and determined that [Ms. Baker] had an emergency condition.” Harry, 237 F.3d at 1319. Ms. Baker seeks to avoid this plain conclusion by claiming that the Hospital did not conduct an appropriate medical screening because the Hospital purportedly failed to diagnose or treat her stroke earlier than it did, and purportedly failed to properly treat her hypertensive emergency and possible head injury. See Id. at 18, 20-25. As pleaded, however, Ms. Baker's medical screening claim is based on the Hospital's alleged negligence, and is an attempt to assert a malpractice claim. While Ms. Baker's allegations may support a stand-alone malpractice claim, EMTALA is not intended to be a federal malpractice statute, or “to redress a negligent diagnosis by the hospital . . . .” Holcomb v. Monahan, 30 F.3d 116, 117 (11th Cir. 1994). To the contrary, “[a]s long as the Hospital screened [the plaintiff] in a manner consistent with the screening that any other patient . . . would have received, there can be no liability under the EMTALA.” Nolen v. Boca Raton Community Hosp., Inc., 373 F.3d 1151, 1154-55 (11th Cir. 2004). Consequently, because Ms. Baker's allegations establish that the Hospital conducted an initial screening exam and diagnosed her with an emergency condition, Ms. Baker does not state a valid claim of an alleged violation of EMTALA's medical screening examination requirement.

         Ms. Baker attempts to save her claim by alleging that the screening examination she received did not meet the Hospital's own policies and screening parameters, and that she “believes that she was treated differently than other patients presenting with the same symptoms.” Docs. 12 at 7, 9-10, 32, 34-36; 12-1 at 9-12, 15. As Ms. Baker puts it, she did not receive treatment required by the Hospital's financial assistance policy, which provides in relevant part that “Huntsville Hospital's policy is to provide Emergency Care and Medically Necessary Care to patients without regard to race, creed, or ability to pay.” Docs. 12 at 7, 9-10; 12-1 at 12, 17-18; 12-2 at 12-13. But, Ms. Baker does not allege the precise medical screening or screening parameters the Hospital's policy require that the Hospital purportedly failed to provide to her. See doc. 12.[2] While Ms. Baker suggests that the Hospital did not have neurologists on call as advertised to provide her with access to telemedicine, she admits that “a neurologist was secured on the telephone, ” doc. 12 at 21-22, 32, and her allegations are not sufficient to show that the Hospital had a policy of providing telemedicine as part of its medical screening procedure for other patients presenting with her symptoms. Indeed, Ms. Baker does not allege facts to support her conclusory allegations that the Hospital treated her differently than other patients with similar symptoms. See id.[3]

         Put simply, Baker has not plausibly alleged that Huntsville Hospital violated its own policies or provided her with a different screening examination than other patients. As such, she has not stated a viable claim for violations of EMTALA's medical screening requirement.

         B. Whether Ms. Baker asserts a plausible claim for alleged violations of ...

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