Adanna Fountain, on behalf of M.L. and T.F., et al. v. Memorial Hospital at Gulfport doing business as Memorial Hospital Biloxi, et al.

District Court, S.D. Mississippi·Decided August 14, 2026·No. 1:26-cv-00120·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI SOUTHERN DIVISION

ADANNA FOUNTAIN, on behalf § PLAINTIFFS of M.L. and T.F., et al. § § § v. § Civil No. 1:26-cv-120-HSO-BWR § § MEMORIAL HOSPITAL § AT GULFPORT doing business as § Memorial Hospital Biloxi, et al. § DEFENDANTS

MEMORANDUM OPINION AND ORDER GRANTING DEFENDANTS’ MOTION [21] FOR JUDGMENT ON THE PLEADINGS

In this medical negligence case that also includes a claim under the federal Emergency Medical Treatment and Active Labor Act (“EMTALA”), 42 U.S.C. § 1395dd, Defendants seek judgment on the pleadings under Federal Rule of Civil Procedure 12(c) as to the EMTALA claims and ask the Court to decline supplemental jurisdiction over the remaining state-law claims. See Mot. [21]. Because the Complaint [1] fails to state plausible EMTALA claims, the Motion [21] should be granted. The Court will decline to exercise supplemental jurisdiction over Plaintiffs’ state-law claims and will dismiss them without prejudice. I. BACKGROUND A. Factual Background The Complaint [1] alleges that on May 15, 2025, Kimyius Lawler (“Mr. Lawler” or “Kimyius”) became unresponsive and fell to the floor at his place of employment. See Compl. [1] at 2; see also Am. Compl. [12] at 1 (realleging all allegations from the Complaint [1]). Emergency Medical Services (“EMS”) found Mr. Lawler face down and unresponsive, with “blood-tinged saliva flowing from his mouth.” Compl. [1] at 3. During transport to Defendant Memorial Hospital at

Gulfport, doing business as Memorial Hospital Biloxi (the “Hospital”), Mr. Lawler “vomited, went in and out of consciousness with borderline hypoxia and received Narcan prior to arrival to the hospital.” Id. Upon arrival at 9:08 p.m., Mr. Lawler “woke up briefly before being transferred to the hospital bed, where ‘he became unconscious again and just slept.’” Id. Mr. Lawler was examined by Defendant Dr. Christopher Smelley (“Dr. Smelley”) at 9:32 p.m., who noted that Mr. Lawler “was alert and oriented x 3, but

with no specific neurologic examination findings mentioned.” Id. Dr. Smelley ordered an electrocardiogram (“EKG”), a complete blood count (“CBC”), a comprehensive metabolic panel (“CMP”), ethanol level, and urine drug screen. See id. Dr. Smelley ultimately diagnosed Mr. Lawler with “marijuana hyperemesis syndrome and syncope” and discharged him around 11:50 p.m. Id. “Prior to discharge, Kimyius was noted as having an oxygen level of 69%, though it is unclear

if this reading was communicated by nursing staff to Dr. Smelley.” Id.; see Ex. [1-1] at 3, 4 (report of Plaintiffs’ expert physician noting Dr. Smelley documented an oxygen saturation level of 94% but that prior to discharge “Kimyius was noted at having an oxygen level of 69%,” though the “records are unclear whether the 69% oxygen reading was communicated by nursing staff to Dr. Smelley prior to discharge”). Mr. Lawler’s girlfriend met him outside the emergency room and found him “lethargic, confused, coughing up blood and unsteady.” Compl. [1] at 4. She drove Mr. Lawler to his car at his place of employment, but Mr. Lawler subsequently

“drove off the road and was later found dead in his car.” Id. An autopsy revealed that Mr. Lawler died of “sudden cardiac death due to probable unspecified cardiomyopathy.” Id. B. Procedural History Invoking federal question jurisdiction under 28 U.S.C. § 1331 and supplemental jurisdiction under § 1367, see id. at 1-2, Plaintiffs Adanna Fountain, on behalf of Mr. Lawler’s minor children M.L. and T.F., and the Estate of Kimyius

Lawler, individually and on behalf of Mr. Lawler (collectively, “Plaintiffs”), have filed suit in this Court against the Hospital and Dr. Smelley (collectively, “Defendants”), see id. at 1; see also Am. Compl. [12] at 1; Order [19]. Plaintiffs advance state-law claims for negligence under the Mississippi Tort Claims Act (“MTCA”), Miss. Code Ann. § 11-46-1, et seq., and federal claims for violation of EMTALA, 42 U.S.C. § 1395dd. See Compl. [1] at 4-6. Defendants have answered

Plaintiff’s Complaint [1] and Supplemental and Amended Complaint [12]. See Ans. [7]; Ans. [17]. Defendants’ Motion [21] for Judgment on the Pleadings argues that Plaintiffs cannot bring a claim against Dr. Smelley under EMTALA and that the pleadings fail to state an EMTALA claim against the Hospital, which are the only federal claims brought in this case. See Mot. [21]; Mem. [22] at 4-15. Defendants ask the Court to decline to exercise supplemental jurisdiction over the remaining state-law claims and dismiss them without prejudice. See Mem. [22] at 1, 15-19. Plaintiffs respond that, “[a]s properly stated in Defendant’s [sic] motion to

dismiss, EMTALA does not create a private cause of action against individual physicians,” Resp. [24] at 6, and they acknowledge the EMTALA claims against Dr. Smelley should be dismissed, see id. at 17. But Plaintiffs argue that the facts plead “a cognizable screening and stabilization claim under EMTALA” against the Hospital. Id. at 3. They insist that discovery will likely show Defendants failed to screen Mr. Lawler under 42 U.S.C. § 1395dd(a), see id. at 6-8, and, citing new medical records obtained post-filing,1 they contend that Defendants violated

§ 1395dd(b) because, even though there were clear indications that Mr. Lawler “was suffering an emergency medical condition, Dr. Smelley discharged him without stabilizing that condition,” id. at 8. In the event the Court finds Plaintiffs’ EMTALA claims against the Hospital are inadequately pled, they contend the Court should grant them leave to amend under Federal Rule of Civil Procedure 15(a)(2), as they “did not have Kimyius’ complete medical records when the Complaint was

filed” and “key evidence bearing on the screening and stabilization claims remains within Defendants’ exclusive control.” Id. at 18.

1 “As a general rule, claims and allegations that are not raised in the complaint, but raised for the first time in a response to a motion to dismiss are not properly before the court.” Middaugh v. InterBank, 528 F. Supp. 3d 509, 535 (N.D. Tex. 2021). But even if the Court considered the new allegations in the Response [24], the result would not change. II. DISCUSSION A. Standard of Review

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Adanna Fountain, on behalf of M.L. and T.F., et al. v. Memorial Hospital at Gulfport doing business as Memorial Hospital Biloxi, et al., (S.D. Miss. 2026).

Adanna Fountain, on behalf of M.L. and T.F., et al. v. Memorial Hospital at Gulfport doing business as Memorial Hospital Biloxi, et al. (Adanna Fountain, on behalf of M.L. and T.F., et al. v. Memorial Hospital at Gulfport doing business as Memorial Hospital Biloxi, et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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