Hester v. University of Alabama Birmingham Hospital

On November 30, 2018, the U.S. District Court for the Northern District of Alabama granted summary judgment in Hester v. University of Alabama Birmingham Hospital. The case involved Bertha Hester, who presented to the UAB Hospital emergency room with concerning symptoms. After evaluation and diagnosis, she was transferred to another facility where she died the following day. Her son, James Hester, acting as personal representative of her estate, sued the hospital under the Emergency Medical Treatment and Labor Act (EMTALA). He alleged the hospital failed to provide an appropriate medical screening examination and failed to stabilize her emergency medical condition before transfer. The court found the hospital conducted a screening reasonably calculated to identify an emergency condition, and the transfer was appropriate. Finding no evidence of an EMTALA violation, the court dismissed the lawsuit with prejudice.

The court granted summary judgment in favor of the defendant hospital, holding that the hospital provided an appropriate medical screening and that no EMTALA violation occurred. The case was dismissed with prejudice.

Whether University of Alabama Birmingham Hospital violated the Emergency Medical Treatment and Labor Act (EMTALA) by failing to provide an appropriate medical screening and failing to stabilize the decedent's emergency medical condition prior to transfer.

The ruling clarified the EMTALA standard, emphasizing that hospitals are required to perform a medical screening reasonably designed to detect emergency conditions rather than guaranteeing a correct diagnosis. It reinforced protections for hospitals that follow proper transfer and stabilization procedures, setting a precedent for how courts assess emergency screening liability.