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plaintiffdefendantmotionsummary judgmentcorporationmotion for summary judgment
plaintiffdefendantmotionsummary judgmentcorporation

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Hernandez v. Starr County Hosp. Dist., 30 F.Supp.2d 970

Facts

The Plaintiff, employed by Trans Texas Gas Corporation, suffered a work-related injury and was found unconscious by the Defendant's ambulance service. His employer instructed the ambulance personnel to transport him to Mission Hospital, and at no time did anyone request that he be taken to Starr County Memorial Hospital, which is owned by the Defendant. The Plaintiff alleges that the Defendant violated EMTALA by not transporting him to its hospital.

The Plaintiff, employed by Trans Texas Gas Corporation, suffered a work-related injury. The Defendant's ambulance service responded to the call and found the Plaintiff unconscious. Plaintiff's employer instructed the ambulance personnel to transport the Plaintiff to Mission Hospital. At no time did anyone request that the Plaintiff be transported to Starr County Memorial Hospital, a hospital owned by the Defendant.

Issue

Did the Plaintiff 'come to the emergency department' of Starr County Memorial Hospital as required by EMTALA, and was there a request made for treatment on his behalf?

Did the Plaintiff 'come to the emergency department' of Starr County Memorial Hospital as required by EMTALA, and was there a request made for treatment on his behalf?

Rule

Under EMTALA, a hospital is required to conduct appropriate medical screening examinations for any individual who 'comes to the emergency department' and for whom a request for examination or treatment is made. Both conditions must be met for the hospital to be liable under EMTALA.

EMTALA requires a hospital to conduct appropriate medical screening examinations for any individual presented to its emergency department. If an emergency condition exists, the hospital must either stabilize the patient or, in limited circumstances, transfer the patient.

Analysis

The court applied the rule by determining that the Plaintiff did not meet the first requirement of EMTALA because he was not transported to the hospital as he was instructed to go to a different facility. The court also noted that there was no request made for treatment at Starr County Memorial Hospital, as the ambulance technicians were directed to take the Plaintiff to Mission Hospital instead.

The court held that Plaintiff 'came to the emergency department' when he entered the Defendant's ambulance. However, the court found that a request was not made by the Plaintiff or on his behalf.

Conclusion

The court concluded that Starr County Hospital District was not liable under EMTALA, and therefore granted the motion for summary judgment.

Motion granted.

Who won?

Starr County Hospital District prevailed in the case because the court found that the Plaintiff did not 'come to the emergency department' as required by EMTALA and that no request for treatment was made on his behalf.

Defendant responds that summary judgment is proper because (1) Plaintiff never presented himself to Starr County Memorial Hospital as required by EMTALA.

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