ROBERTS v. GALEN OF VIRGINIA, INC.

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Case Basics
Docket No. 
97-53
Petitioner 
Roberts
Respondent 
Galen of Virginia, Inc.
Advocates
(Argued the cause for the petitioner)
(Argued the cause for the respondent)
(For the United States, as amicus curiae, supporting the petitioner)
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Facts of the Case 

Wanda Johnson was run over by a truck in May 1992 and was rushed to the Humana Hospital-University of Louisville, Kentucky, now Galen of Virginia, Inc. After about six weeks at Galen, during which time Johnson's health remained in a volatile state, Galen's agents arranged for her transfer to the Crestview Health Care Facility in Indiana. Johnson was transferred to Crestview in July, and upon arrival her condition deteriorated significantly. Johnson was taken to the Midwest Medical Center where she remained for many months and incurred substantial medical expenses as a result of her deterioration. Jane Roberts, Johnson's guardian, then filed a federal action under the Emergency Medical Treatment and Active Labor Act (EMTALA), alleging violations of Section 1395dd(b) of the Act. Section 1395dd of the Act places obligations of screening and stabilization upon hospitals and emergency rooms that receive patients suffering from an "emergency medical condition." The District Court granted summary judgment for Galen on the ground that Roberts had failed to show that "either the medical opinion that Johnson was stable or the decision to authorize her transfer was caused by an improper motive." In affirming, the Court of Appeals held that in order to state a claim in an EMTALA suit alleging a violation of Section 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.

Question 

Must a plaintiff prove that a hospital acted with an improper motive in failing to stabilize a patient in order to prove a violation of the Emergency Medical Treatment and Active Labor Act?

Conclusion 
Decision: 9 votes for Roberts, 0 vote(s) against
Legal provision: 42 U.S.C. 1395

No. In a per curiam opinion, the Court held that Section 1395dd(b) of the Emergency Medical Treatment and Active Labor Act contains no expressed or implied "improper motive" requirement. According o the Court's opinion, "there is no question that the text of Section 1395dd(b) does not require an "appropriate stabilization, nor can it reasonably be read to require an improper motive."

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ROBERTS v. GALEN OF VIRGINIA, INC.. The Oyez Project at IIT Chicago-Kent College of Law. 12 December 2014. <http://www.oyez.org/cases/1990-1999/1998/1998_97_53>.
ROBERTS v. GALEN OF VIRGINIA, INC., The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1990-1999/1998/1998_97_53 (last visited December 12, 2014).
"ROBERTS v. GALEN OF VIRGINIA, INC.," The Oyez Project at IIT Chicago-Kent College of Law, accessed December 12, 2014, http://www.oyez.org/cases/1990-1999/1998/1998_97_53.