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Palmer v. Hospital Authority

22 F.3d 1559 (1994)

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Palmer v. Hospital Authority

United States Court of Appeals for the Eleventh Circuit
22 F.3d 1559 (1994)

  • Written by Heather Whittemore, JD

Facts

Paulette Palmer and her unborn child died during childbirth. Jerry Palmer (plaintiff), an Alabama citizen and Paulette’s husband, filed a lawsuit in federal district court against Hospital Authority of Randolph (the hospital) and John G. Bates (defendants), citizens of Georgia, alleging violations of the Emergency Medical Treatment and Active Labor Act (EMTALA) and Georgia state law. Palmer was a citizen of Georgia for the purposes of the EMTALA claim and a citizen of Alabama for the purposes of the state-law claim. During the litigation, legal developments resulted in Palmer not having a cause of action against Bates under EMTALA. The district court dismissed all of Palmer’s claims against Bates, holding that it did not have subject-matter jurisdiction over the claims. Palmer appealed, arguing that the court had supplemental jurisdiction over the claims.

Rule of Law

Issue

Holding and Reasoning (Birch, J.)

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