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Power v. Arlington Hospital Association

42 F.3d 851 (1994)

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Power v. Arlington Hospital Association

United States Court of Appeals for the Fourth Circuit

42 F.3d 851 (1994)

Facts

In 1990 Susan Power (plaintiff) saw an emergency room physician at Arlington Hospital (the hospital) (defendant). Power presented with severe chills and pain. The physician examined Power, took X-rays, and ordered a urinalysis. The physician determined that Powers was not suffering from an infection and released her without obtaining the urinalysis results. The next day, Power returned to the hospital in critical condition. Power received a blood test and was diagnosed with an infection. Power’s inflection was later discovered to have been caused by her attempt to lance a boil on her face. As a result of the infection, Power endured an amputation of both legs, blindness, and lung damage. Power filed an action in federal district court against the hospital, alleging a violation of the Emergency Medical Treatment and Active Labor Act (EMTALA). Power claimed that the emergency room physician had treated her differently from other patients by not applying an appropriate medical screening because she lacked health insurance and the ability to pay for treatment. Power supported her allegation by introducing into evidence the physician’s failure to record her medical history and X-ray results in her medical file and the decision to release her without obtaining the urinalysis results. The physician testified that he had treated her in the same manner as he would have treated any other patient presenting with similar symptoms. In response, Power introduced expert testimony that the physician should have obtained a blood test. A jury returned a verdict in Power’s favor. The hospital appealed on the ground that EMTALA required that a plaintiff demonstrate the hospital treated her differently from other patients because of an improper motive. The United States Court of Appeals for the Fourth Circuit considered the case.

Rule of Law

Issue

Holding and Reasoning (Williams, J.)

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