Defendants argue that, if Howard did have an emergency medical condition when he came to the hospital, the hospital’s decision to admit him for six days and perform further testing satisfied its obligations under EMTALA to treat so as to stabilize the patient.

We disagree.

Contrary to Defendants’ interpretation, EMTALA imposes an obligation on a hospital beyond simply admitting a patient. . . . The statute requires “such treatment as may be required to stabilize the medical condition,” and forbids the patient’s release unless his condition has “been stabilized.” A patient with an emergency medical condition is “stabilized” when “no material deterioration of the condition is likely . . . to result from or occur during” the patient’s release from the hospital. Thus, EMTALA requires a hospital to treat a patient with an emergency condition in such a way that, on the patient’s release, no further deterioration of the condition is likely. In the case of most emergency conditions, it is unreasonable to believe that such treatment could be provided by admitting the patient and then discharging him. . . .

In short, the hospital was required under EMTALA not just to admit Howard into the inpatient care unit, but to treat him in order to stabilize him. Accordingly, Defendants are not entitled to summary judgment simply on the ground that the hospital admitted Howard as an inpatient and subjected him to several days of testing......................

Discussion Questions

a. What additional information would you like to have about the facts of this situation?

b. What is the EMTALA standard by which the decision to release this type of patient should be made?

c. According to the opinion of the court, was that standard met in this case?