In 1986, concerned that indigent and uninsured patients were not receiving proper emergency treatment, Congress enacted the Emergency Medical Treatment and Active Labor Act (EMTALA), designed to prevent hospitals from “patient dumping.” To determine when the statute applies, federal courts have had to interpret what constitutes an “emergency medical condition,” and ascertain the category of individuals protected by the act.

In Torretti v. Main Line Hospitals Inc., the 3rd U.S. Circuit Court of Appeals confronted these issues for the first time.