Roberts v. Galen of Virginia
Decided on Jan 13, 1999; 525 US 249


I. ISSUES II. CASE SUMMARY III. AMICI CURIAE IV. DECISION V. WIN OR LOSS?
I. ISSUES:

A. Issues Discussed:  Civil rights (federal), Emergency Medical Treatment and Active Labor Act, healthcare

B. Legal Question Presented:

In order to establish a violation of 42 U.S.C. §1395dd (The Emergency Medical Treatment and Active Labor Act), which requires that hospitals provide necessary stabilizing treatment for patients suffering from emergency medical conditions, must the plaintiff show that the medical care provider acted with improper motive?
II. CASE SUMMARY:

A. Background:

Wanda Roberts was run over by a truck in 1992. She was taken immediately to Humana Hospital in Louisville, Kentucky. After an approximately six week stay at Humana, and while still in a volatile condition, Humana Hospital transferred Ms. Roberts to a different hospital in the state of Indiana. After incurring substantial medical expenses, Ms. Roberts applied for financial assistance through Indiana’s Medicaid program. Her application was denied on the grounds that she failed to satisfy Indiana’s residency requirements.

Ms. Roberts’ guardian filed a federal action alleging violations of §1395dd(b), which restricts hospitals from transferring unstabilized patients to other hospitals. The district court granted summary judgment for the respondents on the grounds that petitioner had failed to show that the hospital’s decision to authorize her transfer was caused by an improper motive. The Court of Appeals affirmed the decision, holding that in order to state a claim alleging a violation of the Emergency Medical Treatment and Active Labor Act (EMTALA) stabilization requirement, a plaintiff must show that that the hospital had an improper motive, such as one based on indigency, race, or sex of the patient. The Supreme Court heard the case in order to decide whether the EMTALA imposes such a requirement.

B. Counsel of Record:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)
Joseph H. Mattingly III Brian Todd Thompson
C. The Arguments:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)
The EMTALA does not require a showing of improper motive. It does require a showing that the patient received "such further medical examination and treatment as may be required to stabilize the medical condition." In order to state a claim in an EMTALA suit alleging a violation of §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.
III. AMICI CURIAE:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)
M. Elaine Johnston and Martha F. Davis filed a brief of amici curiae on behalf of Now Legal Defense and Education Fund, ACLU Women’s Rights Project, National Organization for Women Foundation, National Partnership for Women & Families, National Women’s Health Network, and National Women’s Law Center in support of Petitioner.

The United States also filed a brief as amicus curiae in support of Petitioner.
Thomas W. Merrill filed a brief as amici curiae on behalf of Respondents, joined by Fredric I. Entin and James A. Henderson of the American Hospital Association, Leonard A. Nelson of the American Medical Association, Katherine O. Orrico of the American Association of Neurological Surgeons and Robert M. Portman of the American College of Surgeons and American College of Emergency Physicians.
IV. THE SUPREME COURT'S DECISION:

"...[T]here is no question that the text of § 1395dd(b) does not require an 'appropriate' stabilization, nor can it reasonably be read to require an improper motive. This fact is conceded by respondent, which notes in its brief that 'the 'motive' test adopted by the court below... lacks support in any of the traditional sources of statutory construction...' Although the concession of a point on appeal by respondent is by no means dispositive of a legal issue, we take it as further indication of the correctness of our decision today, and hold that §1395dd(b) contains no express or implied 'improper motive' requirement.

Although respondent presents two alternative grounds for... affirmance... we decline to address these claims at this stage in the litigation. The Court granted certiorari on only the EMTALA issue, and these claims do not appear to have been sufficiently developed...

Respondent argues that the record demonstrates that it did not have actual knowledge of the patient's condition, and that the hospital properly screened Johnson, which terminated its duty under EMTALA. We express no opinion as to the factual correctness or legal dispositiveness of these claims, and leave their resolution to the courts below on remand...

Accordingly, we reverse the Court of Appeals' holding that the District Court's grant of summary judgment was proper and remand the case for further proceedings consistent with this opinion."

Held: the judgments are reversed.

Justice Vote: 9 Pro vs. 0 Con
Per curiam (by the court) decision. No individual authorship of decision.

  • Rehnquist, W. Pro
  • Stevens, J. Pro
  • O'Connor, S. Pro
  • Scalia, A. Pro
  • Kennedy, A. Pro
  • Thomas, C. Pro
  • Souter, D. Pro
  • Ginsburg, R. Pro
  • Breyer, S. Pro

V. A WIN OR LOSS FOR THE ACLU?

The ACLU filed as amicus urging reversal; The Supreme Court reversed the ruling of the Court of Appeals in a per curiam decision with a 9-0 vote, giving the ACLU an apparent win.