Plaintiff Todd Jeude filed an action under the Emergency Medical Treatment and Active Labor Act (EMTALA) and state law, alleging Defendants negligently discharged him from the hospital after treating him for injuries sustained in a
motorcycle accident. He named as Defendants SSM St. Clare Hospital, Koren Schram, PA, Dr. David Brummett, and Dr. Mathew Schwab.
On July 4, 2022, Plaintiff presented to the SSM St. Clare Hospital emergency room after a motorcycle/ATV accident. Doctors treated and bandaged his wounds, prescribed pain medication, and ordered x-rays and a CT scan. After the radiology reports showed Plaintiff’s injuries were “unremarkable,” medical staff stabilized Plaintiff’s arm with a sling and discharged him.
On July 12, 2022, Plaintiff’s ear was red and swollen and he complained of severe pain and dizziness. Doctors at a different facility examined him and discovered he had an rubber ear fitting from his ear buds lodged in his ear canal.
They removed it and treated the infection.
The United States District Court Eastern District of Missouri Eastern District stated in its Opinion, Memorandum and Order filed on December 29, 2025: “Although the Court finds Plaintiff’s EMTALA claims time-barred, even if he had timely filed his claims, they are subject to dismissal on initial review for failure to state a claim upon which relief may be granted. See 28 U.S.C. § 1915(e)(2)(B) … Viewing the facts in the light most favorable to Plaintiff, the Court finds he has failed to state a plausible claim for an EMTALA violation. Under EMTALA, hospitals have an obligation to screen and stabilize patients. “Stabilized” is defined as “to provide such medical treatment of the condition as may be necessary to assure, within reasonable medical probability, that no material deterioration of the condition is likely to result from or occur during the transfer of the individual from a facility” … EMTALA does not guarantee a proper diagnosis and it does not guarantee that additional treatment will not be required … It does not guarantee that patients will be pain free upon discharge or that they will be ambulatory. Nor is it a substitute for a state law medical malpractice claim.”
“As to Plaintiff’s allegation that Defendants violated EMTALA by discharging him with a foreign object in his ear, his complaints of pain at the hospital were not isolated to his ear. He complained of pain to his entire right side: his shoulder, neck, arm, and leg. More than a week later, after Plaintiff experienced dizziness and debilitating pain near his right ear, doctors reexamined his ear and discovered the obstruction. Doc. 1 at 11. But, a later finding upon a different presentation of symptoms does not evidence an EMTALA violation. See Summers, 91 F.3d at 1137-38 (“[I]nstances of negligence in the screening or diagnostic process, or of mere faulty screening, are not [actionable under EMTALA].”). For these reasons, in the alternative, the Court dismisses Plaintiff’s EMTALA claims for failure to state a claim upon which relief may be granted.”
Source Jeude v. SSM St. Clare Hospital, No. 4:25-cv-00604-RHH.
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