Bryant

Plaintiffs, the heirs of minor decedent David Bryant (“David”), brought this wrongful death action against Redbud Community Hospital (“Redbud”) for damages and injunctive relief for, among other things, violation of the Emergency Medical Treatment and Active Labor Act (“EMTA-LA”), 42 U.S.C. § 1395dd, commonly known as the “Patient Anti-Dumping Act.” Plaintiffs alleged that when David sought care from Redbud’s emergency room, the emergency room staff failed to detect his emergency medical condition and then discharged him without stabilizing his condition, in violation of EMTA-LA’s stabilization requirement. Plaintiffs further alleged that after David returned to the emergency room the next day and was admitted to the hospital for inpatient care, Redbud again violated EMTALA’s stabilization requirement by failing to stabilize his condition during the three days after it admitted him for treatment.

The district court granted Redbud’s motion for summary judgment on the EMTA-LA claims, and it declined to exercise supplemental jurisdiction over related state-law claims. The district court ruled that Redbud could not be liable under EMTA-LA merely because its medical staff failed to…