Delgado-Caraballo v. Hospital Pavia Hato Rey, Inc., No. 17-1654 (1st Cir. 2018)Annotate this Case
The First Circuit vacated in part the district court’s grant of summary judgment in favor of Defendants in this lawsuit alleging violations of the Emergency Medical Treatment and Active Labor Act (EMTALA) and claiming medical malpractice.
Plaintiffs sued Hospital Pavia Hato Rey, APS Healthcare of Puerto Rico (APS), and two doctors. In granting summary judgment, the district court held that the action could not in “equity and good conscience” proceed without two necessary parties but that the parties could not be feasibly joined under Fed. R. Civ. P. 19. The judge found that complete diversity of citizenship of each plaintiff from each defendant was not met on the federal-EMTALA claim, and because no diversity jurisdiction existed, the court declined to exercise supplemental jurisdiction over the local-law claims. The First Circuit vacated the summary judgment for Hospital Pavia on the EMTALA claim and dismissed the local law claims, holding (1) the trial judge Fed. R. Civ. P. 19 analysis could not be sustained; and (2) this Court’s vacating part of the judge’s summary judgment ruling on the federal EMTALA claim undercut the analysis behind his supplemental jurisdiction decision.