Health Law Daily Wrap Up, EMTALA—E.D. Tenn.: Court dismisses pro se plaintiff’s motion for reconsideration in suit over emergency room treatment, (Sep 9, 2025)

By Donielle Tigay Stutland, J.D.

EMTALA does not to create a federal right of action for medical malpractice.

The federal district court for the Eastern District of Tennessee denied a motion for reconsideration and other pending motions brought by a pro se plaintiff against a Tennessee hospital related to an emergency visit of the plaintiff. The court also granted the hospital's motion to dismiss the case. The court denied the pro se plaintiff’s motion for reconsideration after finding no clear error of law. The court granted the hospital's motion to dismiss the amended claim under the Emergency Medical Treatment and Labor Act (“EMTALA”) after finding the patient failed to state a plausible claim of a violation by the hospital (Crawford v. Metro Knoxville HMA, LLC, No. 3:24-CV-382-TAV-DC (E.D. Tenn. Aug. 29, 2025)).

Background. The case relates to a patient’s treatment in the emergency department at Tennova Healthcare, North Knoxville Medical Center (Tennova North) from November 27 to 29, 2022. The “crux” of the patient’s complaint, is “Tennova North’s alleged failure to diagnose the patient with food poisoning.” The patient alleged that he presented to Tennova North on November 27, 2022, seeking emergency medical care for dehydration and suspected food poisoning. Tennova allegedly triaged patients based on the severity of their condition, and the patient was immediately admitted for treatment upon a determination that his condition was serious. The patient further alleged that the hospital “failed to provide adequate emergency care” to him at several points, including his being restrained to a gurney for “several hours” and his physicians’ refusal to conduct a stool test at his wife’s request. Ultimately, the patient alleged that he was discharged from Tennova on November 29, 2022, “without stabilizing his food poisoning” and “exacerbating his condition.”

The pro se plaintiffs, the patient and his wife, initially filed multiple state and federal claims against Tennova and other defendants. On May 8, 2025, the court dismissed all claims except EMTALA allegations against Tennova North, allowing amendment to clarify the EMTALA claim. Plaintiffs filed an amended complaint on May 21, 2025, alleging failures in screening, stabilization, and transfer under EMTALA.

The patient and his wife moved for reconsideration of the dismissal of state claims arguing errors in applying Tennessee's Health Care Liability Act (THLA) one-year statute of limitations and inquiry notice. The hospital moved to dismiss the amended complaint, arguing it was a disguised medical malpractice claim and outside EMTALA's scope.

Failure to Provide Appropriate Medical Screening. The court began its analysis by indicating that under EMTALA, a hospital is first required to “provide for an appropriate medical screening examination within the capability of the hospital’s emergency department, including ancillary services routinely available to the emergency department, to determine whether or not an emergency medical condition . . . exists.” 42 U.S.C. § 1395dd(a).

The court concluded that the patient did not adequately plead a claim for failure to provide an appropriate medical screening. First, the court pointed out that the patient stated that “Defendant documented their knowledge of an EMC”, meaning that the hospital “determine[d] whether or not an emergency medical condition . . . exist[ed].” The court also indicated that the patient did not allege any facts that would support a finding of improper motive on the hospital’s part upon the patient’s presentation to the emergency department. The patient alleged that defendant’s personnel immediately admitted the patient into the hospital for urgent treatment. The patient’s amended complaint, could not support a claim that the hospital failed to provide him with “standard attention,” as with any other “person who arrives at the emergency room.”

The court also stressed that the patient’s request for a specific stool test would veer into the medical malpractice standards, which EMTALA does not cover. The court concluded that this claim does not fall under the protection of EMTALA “because the statute does not guarantee a particular type of medical treatment that is to the plaintiff’s liking; rather, EMTALA solely requires a participating hospital to take appropriate screening measures.” The court dismissed this claim finding the patient failed to state a plausible claim that the hospital failed to provide an adequate medical screening.

Failure to Stabilize Emergency Medical Condition. The court next analyzed whether the patient stated a claim for failure to stabilize an emergency medical condition. EMTALA requires hospitals to provide “such further medical examination and such treatment as may be required to stabilize the medical condition” or to transfer the individual to an appropriate medical facility.

Again, for this claim, the court found that similar to the allegations in support of Count 1, several of the patient’s allegations in support of Count 2 reflect the view “that he did not receive the type of medical treatment he believes he should have received.” For example, the patient alleged that the hospital failed to provide “adequate fluid therapy” and administered antibiotics despite their claim that such medication was “irrelevant to stabilizing his EMC”. The court reiterated that such allegations fall outside the scope of liability created by EMTALA. In the stabilization context, specifically, the court highlighted that while a defendant must provide emergency care “until the patient’s emergency medical condition is stabilized,” the federal statute does not prescribe specific stabilizing treatments or procedures to which a patient is entitled.

The court also dismissed this claim.

Failure to Transfer. The court also dismissed this claim. The court noted that as it had determined that the patient’s amended complaint failed to state a claim upon which relief could be granted for failure to stabilize prior to discharge, the failure to transfer claim also necessarily fails, because it only arises where “an emergency medical condition . . . has not been stabilized.”

The case is No. 3:24-CV-382-TAV-DCP.

Judge: Varlan, T.

Attorneys: Wesley E. Crawford, pro se. Katharine Klein (Riley & Jacobson, PLC) for Community Health Systems, Inc. a/k/a CHSI.

Companies: Community Health Systems, Inc. a/k/a CHSI

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