Roberts v. Galen of Virginia, Inc.
Headline: Federal emergency-care law’s stabilization duty does not require proof of an improper motive, Court reverses lower court and allows injured patients to sue hospitals for failing to stabilize before transfer.
Holding: The Court held that the federal emergency-care law’s stabilization rule does not require proof that a hospital acted with an improper motive, reversed the Court of Appeals, and sent the case back for further proceedings.
- Easier for injured patients to sue hospitals over failure to stabilize before transfer.
- Cases will return to lower courts to resolve factual disputes about care and knowledge.
- Hospitals can still raise defenses such as lack of knowledge; final outcomes depend on further proceedings.
Summary
Background
Wanda Johnson was run over by a truck in May 1992 and was taken to a Louisville hospital where she stayed about six weeks with severe brain, spine, leg, and pelvis injuries. Hospital agents arranged her transfer on July 24, 1992 to a nearby long-term facility in Indiana. Her condition worsened after transfer and she required further care at another Indiana hospital, accumulating substantial medical bills. Indiana Medicaid denied help because she lacked state residency. Her guardian, Jane Roberts, sued under the federal emergency-care law (EMTALA), arguing the hospital failed to provide required stabilizing treatment before transfer. The District Court granted summary judgment for the hospital and the Court of Appeals affirmed only after requiring proof of an improper motive for the transfer.
Reasoning
The central question was whether the stabilization duty in the law requires proof that a hospital acted for an improper motive. The Court explained that subsection (b) requires hospitals to provide 'such further medical examination and such treatment as may be required to stabilize the medical condition' and does not use the word 'appropriate.' Because subsection (b) contains no 'appropriate' language, the Court held there is no express or implied improper-motive requirement for claims under that provision. The Court noted the hospital itself conceded that the motive test lacked textual support. The Court reversed the Court of Appeals’ decision and remanded the case for further proceedings.
Real world impact
This ruling makes it easier for injured patients or their guardians to bring claims under the stabilization part of the federal emergency-care law without proving the hospital acted from an improper motive. The case will return to lower courts to decide factual questions such as what treatment was required and whether the hospital knew the patient’s condition. The Court did not decide other defenses raised by the hospital, so final outcomes will depend on further proceedings.
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