Physician Retaliation under EMTALA: Objective Reasonableness and Scope Clarified in Partin v. Baptist Health

Introduction

In William R. Partin v. Baptist Healthcare System, Inc., the Seventh Circuit addressed a physician’s claim that his resignation and removal from an emergency department contract was the result of retaliation prohibited by the Emergency Medical Treatment and Active Labor Act (EMTALA), 42 U.S.C. § 1395dd(i). Dr. Partin, employed by a staffing firm (Floyd Associates) but practicing at Baptist Health Floyd, resigned under threat of contract termination after hospital leadership declined to support his forcible treatment of a coherent suicidal patient, J.C. He also sued under Indiana law for breach of contract, tortious interference, breach of the duty of good faith and fair dealing, third‐party beneficiary status, and defamation. The district court granted summary judgment to the defendants on all counts. On April 24, 2025, a unanimous panel of the Seventh Circuit affirmed, emphasizing the limits of EMTALA’s anti‐retaliation provision and clarifying related state‐law doctrines.

Summary of the Judgment

The Court held that Dr. Partin failed to establish a prima facie EMTALA retaliation claim because he neither engaged in protected activity nor had an objectively reasonable belief of an ongoing EMTALA violation.
Professional disagreements over patient treatment (e.g., use of restraints, forced IV fluids or rectal temperatures) do not implicate EMTALA’s requirement to screen and stabilize emergency conditions.
The hospital bylaws contained an unambiguous disclaimer of any contractual relationship and expressly waived hearing and appeal when a physician “voluntarily” resigns, defeating breach‐of‐contract and good‐faith claims.
Dr. Partin was not an intended third‐party beneficiary of the Baptist–Floyd agreement, which promised compensation to Floyd, not direct rights to physicians.
Invoking economic pressure to remove a physician pursuant to a permissive ninety‐day termination clause does not constitute improper interference under Indiana tort law.
Alleged defamatory statements by hospital leadership and a nurse were protected by qualified privilege because they addressed internal personnel matters, and there was no evidence of malice or lack of grounds for belief.

Analysis

Precedents Cited

EMTALA and Screening/Stabilization: Johnson v. Univ. of Chi. Hosps., 982 F.2d 230 (7th Cir. 1992); Harry v. Marchant, 291 F.3d 767 (11th Cir. 2002); Correa v. Hosp. San Francisco, 69 F.3d 1184 (1st Cir. 1995).
Retaliation Framework: McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973); Gillispie v. RegionalCare Hosp. Partners Inc., 892 F.3d 585 (3d Cir. 2018); Elkharwily v. Mayo Holding Co., 823 F.3d 462 (8th Cir. 2016); Logan v. City of Chicago, 4 F.4th 529 (7th Cir. 2021); Genova v. Banner Health, 734 F.3d 1095 (10th Cir. 2013).
Indiana Contract Law: Conwell v. Gray Loon Outdoor Mktg. Grp., Inc., 906 N.E.2d 805 (Ind. 2009); Zimmerman v. McColley, 826 N.E.2d 71 (Ind. Ct. App. 2005); Cain v. Griffin, 849 N.E.2d 507 (Ind. 2006); Harvey v. Lowry, 183 N.E. 309 (Ind. 1932).
Good Faith and Fair Dealing: ARC Welding Supply Co. v. American Welding & Gas, Inc., No. 3:16-cv-00173 (S.D. Ind. Sept. 12, 2017); Gerdon Auto Sales, Inc. v. John Jones Chrysler Dodge Jeep Ram, 98 N.E.3d 73 (Ind. Ct. App. 2018).
Tortious Interference: American Consulting, Inc. v. Hannum Wagle & Cline Eng’g, Inc., 136 N.E.3d 208 (Ind. 2019); Winkler v. V.G. Reed & Sons, Inc., 638 N.E.2d 1228 (Ind. 1994).
Defamation & Qualified Privilege: Bals v. Verduzco, 600 N.E.2d 1353 (Ind. 1992); Cortez v. Jo‐Ann Stores, Inc., 827 N.E.2d 1223 (Ind. Ct. App. 2005).

Legal Reasoning

1. EMTALA Retaliation: The Court assumed without deciding that McDonnell Douglas applies. To show protected activity under § 1395dd(i), a physician must (a) refuse a discharge or report an EMTALA violation, and (b) hold an objectively reasonable belief that the Act was violated. Dr. Partin’s disagreement about treatment modalities and speculative belief in a future discharge did not satisfy either requirement. The Court reinforced that EMTALA remedies screening and stabilization failures, not medical‐judgment disputes.

2. Indiana Contract Doctrines: Bylaws disclaiming contractual relationships are binding; a “voluntary” resignation provision precludes hearings and appeals. Threats of contract termination do not rise to duress under Indiana law. Third‐party beneficiary claims require clear intent in the contract text to benefit the third party, which was absent here.

3. Tortious Interference: Economic pressure consistent with an agreement’s express termination right cannot be “unfair” under Indiana’s Restatement § 767 analysis.

4. Defamation: Statements about internal performance and patient‐care concerns fall within a qualified privilege protecting employer/employee communications. Without evidence of malice or lack of belief in their truth, no defamation per se claim lies.

Impact

Partin clarifies several important points:

EMTALA’s anti‐retaliation provision protects only refusals to discharge or transfers that hinge on screening/stabilization, not clinical disagreements or speculative concerns about future violations.
Physician‐staff disputes over treatment do not trigger protected “reporting” unless an actual EMTALA breach is reported to hospital leadership.
Hospital bylaws can effectively insulate institutions and their officers from contract and good‐faith claims by clear disclaimers and voluntary‐resignation waivers.
Employer communications on personnel issues retain a qualified privilege barring defamation claims absent malice.

Complex Concepts Simplified

EMTALA Screening vs. Treatment: EMTALA mandates an “appropriate medical screening” to identify emergency conditions and requires stabilization before discharge or transfer. It does not dictate treatment methods or curb professional judgment.
McDonnell Douglas Framework: In retaliation cases without direct evidence, a plaintiff must first show protected activity, adverse action, and causation. The employer must then offer a legitimate reason, and the plaintiff must prove pretext.
Third‐Party Beneficiary: Only when a contract expressly intends to confer enforceable rights on a non‐party does a third party gain standing. Incidental benefits are insufficient.
Qualified Privilege in Defamation: Courts protect communications made in good faith on matters of common interest (like personnel performance). Plaintiffs must show malice or lack of belief to overcome this defense.

Conclusion

The Seventh Circuit’s decision in Partin v. Baptist Health serves as a definitive guide to the contours of EMTALA’s anti‐retaliation clause, reinforcing that only actual, reasonably perceived EMTALA violations qualify for protection. It also underscores the power of clear bylaw language to preempt contract‐based claims and affirms Indiana’s rigorous standards for third‐party beneficiary, interference, and defamation actions. For physicians and hospitals alike, Partin delineates the boundaries of statutory protection and institutional autonomy in the management of emergency‐department practices.