Lower court's ruling reversed on scope of EMTALA

On March 23, a federal appeals court overruled a lower court decision that the Emergency Medical Treatment and Labor Act (EMTALA) covers diagnostic and treatment centers.

In Rodriguez v. American International Insurance Company of Puerto Rico, the U.S. Court of Appeals for the First Circuit rejected the district court's determination that it would be "unconscionable" not to extend EMTALA to cover the diagnostic center, Centro de Diagnostico y Tratamiento (CDT), with 24-hour emergency services because doing so would have the effect of "excluding the poor population who primarily rely on CDT services."

The appeals court disagreed with the district court in its conclusion that the spirit, if not the law, of EMTALA was meant to cover the action against CDT and its insurer, American International Insurance Company of Puerto Rico. In her decision, Judge Sandra L. Lynch wrote that, "Federal courts are not free to ignore the letter of the law in favor of the 'spirit' of a law. There is no legal ambiguity about the language Congress used in EMTALA-EMTALA requires the emergency room be of a participating hospital."