The United States Court of Appeals for the Eleventh Circuit affirmed the dismissal of the pro se plaintiff’s EMTALA complaint in its unpublished Opinion filed on May 5, 2026, stating, in part: “Here, the district court properly determined that Plaintiffs failed to allege sufficient facts to state a screening claim under EMTALA, because they merely alleged that the Hospital violated EMTALA by “failing to perform a simple urinalysis,” causing Matthews “irreparable harm to [her] organs.” While this is arguably an unartfully stated claim that the Hospital did not perform a urinalysis test on Matthews after learning that she was uninsured despite providing the test to insured patients exhibiting similar symptoms, this Court may not “rewrite an otherwise deficient pleading,” even for pro se litigants. Campbell, 760 F.3d at 1168 69; see Nolen, 373 F.3d at 1155. Matthews and Moody alleged that the Hospital admitted Matthews upon her arrival and performed tests on her, detecting Matthews’s malnutrition and vitamin deficiency, which comports with EMTALA’s requirement that hospitals provide medical screening to patients who come to the hospital’s emergency room. 42 U.S.C. § 1395dd(a). However, they did not allege the Hospital used different screening procedures for Matthews upon learning she was uninsured, which is required to properly plead a failure to screen claim under EMTALA. Nolen, 373 F.3d at 1155. As Matthews and Moody did not allege, even unartfully, that the Hospital provided urinalysis tests to similarly medically situated insured patients, their claim that the failure to provide Matthews with a urinalysis test caused her harm is more akin to a medical malpractice claim than a disparate treatment claim under EMTALA. Id. at 1155; Marchant, 291 F.3d at 770 (noting that EMTALA “was not intended to be a federal malpractice statute”). Therefore, in their original complaint, Matthews and Moody failed to properly state a claim that the Hospital violated EMTALA’s screening requirement.”
EMTALA Stabilization Claim
With regard to the plaintiff’s claim that the Hospital failed to stabilize Matthews in violation of EMTALA’s stabilization requirement, the plaintiff alleged that on February 16, Plaintiff Lisa Matthews was brought to the Hospital’s emergency room by an ambulance after she had collapsed at home and was briefly unconscious. Upon her arrival, she was admitted to the hospital and put in an inpatient room. Several tests were conducted (but not urinalysis) and she was diagnosed with, inter alia, malnutrition. The plaintiff alleged that then on February 17, a Hospital representative came to the patient’s (i.e. Matthews’) room and reported that Matthews’ insurance had lapsed due to non-payment. Plaintiff alleged that the Hospital made it clear at that point that because Matthews had no insurance, they wanted to discharge her as soon as possible. The plaintiff also alleged that, notwithstanding that the Hospital had diagnosed Matthews with malnutrition, the Hospital failed to feed her and stabilize her. Plaintiff argued that the Hospital violated EMTALA’s stabilization requirement by failing to stabilize her known emergency medical condition, malnutrition. The Hospital’s Motion to Dismiss argued that plaintiff’s stabilization claim failed for several reasons, including the fact that the plaintiff conceded that Matthews was admitted to the main hospital, which ends the reach of EMTALA’s obligations under the authority of Harry v. Marchant, 291 F.3d 767 (11th Cir. 2002) (en banc), as well as the regulation 42 C.F.R. § 489.24.
The federal appellate court stated: “we conclude that the Plaintiffs have failed to state a viable stabilization claim under EMTALA. We conclude that Plaintiffs’ concession that Matthews was admitted to the hospital and put in an inpatient room means that EMTALA’s obligations cease to apply. Matthews was brought to the hospital by ambulance after having collapsed at home and being briefly unconscious. “[A]fter being triaged by the emergency room physician, [Matthews] was admitted to the hospital due to the pain she was experiencing.” Plaintiffs’ Response to Defendant Ascension St. Vincent’s Clay County Hospital’s Dispositive Motion to Dismiss, D.C. Doc. 11 at 16. Thus, it is undisputed that all of the challenged actions of the Hospital with respect to stabilization (and indeed also with respect to screening) occurred after Matthews had been removed from the emergency room and admitted to the main hospital … we conclude that Matthews’ admission to the main hospital ended the Hospital’s stabilization obligations under EMTALA and that remedies for criticism of the Hospital’s actions thereafter would lie with the Florida tort law.”
“Plaintiffs’ EMTALA claims fail, and the district court did not err in dismissing their original complaint and denying their motions to alter or amend and for leave to file their Proposed Amended Complaint.”
Source Matthews v. Ascension St. Vincent’s Clay County Hospital, No. 22-13484.
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