Jason Allen v. Lafayette General Medical Center, Inc.

Summary

The Louisiana Court of Appeal, Third Circuit, held that Jason Allen’s claims against Lafayette General Medical Center were governed by the Louisiana Medical Malpractice Act rather than the Emergency Medical Treatment and Active Labor Act. Because Allen had not first submitted his claims to a medical review panel, the court affirmed the trial court’s judgment sustaining the exception of prematurity. The court also concluded that the hospital had stabilized Allen’s emergency medical condition before discharge.

Holdings

1. Allen's claims did not sound in EMTALA because the evidence showed that Lafayette General admitted him in good faith, treated him as an inpatient, and stabilized his emergency medical condition before discharge.
2. Allen's claims alleged medical malpractice governed by the Louisiana Medical Malpractice Act.
3. Because Lafayette General was a qualified health-care provider and Allen did not submit his claims to a medical review panel before filing suit, the claims were premature and the trial court properly sustained the exception of prematurity.
4. When evidence is admitted at the hearing on an exception of prematurity, the court decides the exception based on the evidence presented rather than solely on the petition's allegations.

Questions Presented

1. Whether Allen's claims alleging that Lafayette General failed to stabilize him before discharge were EMTALA claims that could proceed without prior review by a medical review panel.
2. Whether Allen's claims sounded in medical malpractice under the Louisiana Medical Malpractice Act and therefore were premature because no medical review panel had reviewed them.
3. Whether the trial court properly considered evidence beyond the petition when ruling on the exception of prematurity.

Disposition

affirmed