Phillips v. Hillcrest Med. Ctr. - EMTALA Case Law Summary (IRAC)

This case study summarizes the Phillips v. Hillcrest Medical Center case, focusing on the Emergency Medical Treatment and Active Labor Act (EMTALA) claim. The plaintiff sued the defendant for violating EMTALA after the death of Martin Shane Phillips, who was treated at Hillcrest Medical Center. The court ruled that an EMTALA claim did not exist because the hospital had performed a medical screening examination in line with its policies to determine if Phillips suffered from an emergency medical problem, thereby fulfilling EMTALA requirements. The court emphasized that EMTALA aims to ensure appropriate screening, not accurate diagnosis, and does not replace medical negligence claims. While the plaintiffs could proceed with medical negligence claims, the court upheld the district court's decision that there was no evidence to substantiate an EMTALA violation.

Running Head: CASE LAW SUMMARY 1
Phillips v. Hillcrest Med. Ctr. (D.C. No. 98-CV-829-H): Case Law Summary
Facts
The facts of the case were that on 23rd September, 1998, Martin Shane Phillips visited the
Hillcrest Medical Center (HMC). He had serious chest pains and with symptoms that presents as
pneumonia. Phillips was admitted and recorded as having no insurance. After check up in the
emergency room minor care section, Phillip was given prescription drugs and discharges with a
referral for follow-up treatment to the Oklahoma Medical Clinic. Phillips then reported for duty
at work after being discharged notwithstanding the fact that the symptoms did not subside. His
situation therefore deteriorated fast through the four days that ensued. Phillip was then rushed to
Tulsa Regional Medical Clinic. The attending physician ran tests and found that Phillips was
suffering from bacterial endocarditis. Phillips then succumbed to the sickness and was
pronounced dead on 28th September 1998. The cause of sickness by agreement of all the parties
was acute bacterial endocarditis. The Plaintiffs sued the defendants for having violated the
provisions of the Emergency Medical Treatment and Active Labor Act (EMTALA). Their claims
were dismissed by the district court before trial and the plaintiffs appealed against that decision.
Issues
Did, as a matter of law, an EMTALA claim exist and if yes, was there a violation thereof
by the defendants?
The Court’s Ruling
The court ruled that an EMTALA claim did not exist as a matter of law, thereby
upholding the decision of the district court.
The Court’s Analysis
The Legal Framework
The court, in reaching its decision, considered the legal framework governing EMTALA
and medical malpractice vis-à-vis the Appellants’ claims. The purpose of the enactment of
EMTALA by Congress was considered and held to be for addressing the nuisance of patients
who needed medical attention being dumped due to lack of health insurance (Abercrombie v.
Osteopathic Hospital, 1991). Although this was the initial intention, the applicability of
EMTALA extended to both the insured and uninsured (Collins v. DePaul Hospital, 1992). In
other words, an EMTALA claim is not defeated by uninsured status or lack of indigency.
Therefore, it was of no consequence to the determination of the appeal, whether Phillips was
covered by insurance or not.
The court examined the fact that participating hospitals had two obligations under
EMTALA (Ingram v. Muskogee Reg’l Med Ctr., 2000). The hospital is required to first initially
do a medical examination and decide if the patient was ailing of an emergency medical problem
(Abercrombie v. Osteopathic Hospital, 1991). Secondly, the hospital is obliged, if it is
determined that there is such a condition, to stabilize and then transport him or her to another
facility (Urban v. King, 1994). Congress then created and enacted a private cause of action
through 42 U.S.C. § 1395dd (d) to ensure that hospitals comply with the two obligations.
Therefore, the only action that can be brought under EMTALA is where there was no provision
of appropriate screening as necessitated by that law.

CASE LAW SUMMARY 2
By dint of section 1395dd (d), it was incumbent upon HMC to conduct a medical
examination to decide whether there was in existence, an emergency medical condition. The
court held that the determination of whether an appropriate medical examination was conducted
by a hospital depended on the varying capabilities of a particular hospital (Repp v. Anadarko
Mun. Hosp., 1994). The standard set by the court was to question whether a hospital’s own
procedures were adhered to and not whether they were adequate if adhered to. Accordingly,
HMC was required by the dictate of the law to apply a uniform screening procedure to any and
all patients arriving at the emergency room regardless of the perception as being able or unable
to cater for medical expense. The court cited the case of Vickers v. Nash Gen. Hosp. Inc (1996)
where it was held that the linchpin of a claim under EMTALA was uniformly treating all patient
whether they could pay or not.
The Appellants Claims
The Appellants claims, both at the district court and at the appellate court, was that
evidence that there was bias towards an uninsured patient was suffice to found a claim under
EMTALA. The court held that for EMTALA liability to attach, it did not require any particular
motive but rather the court looks at the actions of a participating hospital and not its motives
(Roberts v. Galen of Virginia, 1999). The court, however, conceded that although it may be
relevant to furnish evidence that a hospital was aware of a patient’s uninsured status in failing to
follow established procedures, this alone cannot suffice to establish that a hospital violated
uniform treatment requirement of EMTALA.
The appellants also attempted to point to certain policies of HMC which they claimed
were not followed. To this extent, the court found that as long as a medical screening
examination was performed by HMC in line with the hospital policy in trying to establish if
Phillips suffered from an emergency medical problem, HMC had fulfilled EMTALA
requirements (Repp and Tank v. Chronister, 1996). The Appellants then argued that although
HMC was in technical compliance of its own standards, practically the effect was that Phillips
was inadequately examined. In this regard, the court appreciated the intersection between
medical negligence and EMTALA claims. The court held that EMTALA does not purport to
replace existing medical negligence claims but is rather limited to the determination of whether
emergency medical conditions exist.
Finally, the court allowed the appellants to proceed to the jury with their medical
negligence claims for the alleged misconduct of the staff at HMC. However, with respect to
EMTALA, the court held that the district court was right in holding that there was no evidence
presented to substantiate an EMTALA claim.
Conclusion
After thoroughly reviewing and analyzing all the evidence presented before it fairly, the
court found that although EMTALA existed as a guarantee that patients will be screened
appropriately, it does not provide a panacea for inaccurate or inadequate diagnosis. Therefore,
the court held that there was no violation of EMTALA by the defendants.

CASE LAW SUMMARY 3
Reference
Abercrombie v. Osteopathic Hospital Founders Association, 950 F.2d 676, 680 (10th Cir. 1991).
Collins v. DePaul Hospital, 963 F.2d 303, 308 (10th Cir. 1992).
Ingram v. Muskogee Regional Medical Center, 235 F.3d 550, 551 (10th Cir. 2000).
Repp and Tank v. Chronister, 941 F. Supp. 969 (D. Kan. 1996).
Repp v. Anadarko Municipal Hospital, 43 F.3d 519, 521-22 (10th Cir. 1994).
Roberts v. Galen of Virginia, 525 U.S. 249, 252 (1999).
Urban v. King, 43 F.3d 523, 525 (10th Cir. 1994).
Vickers v. Nash General Hospital Incorporated, 78 F.3d 139, 143 (4th Cir. 1996).