No. 19-6794October Term 2019Decided April 20, 2020Updated Sep 3, 2026
Smith v. St. Joseph's/Candler Health Sys.
The Supreme Court declined to hear Smith's case, leaving the Eleventh Circuit's result in place without deciding the legal questions.
Case status
Where it stands
Decided · April 20, 2020
Question presented
1. Whether the District Court and the Court of Appeals erred in dismissing the Petitioner's complaint for failure to state a claim under the Emergency Medical Treatment and Labor Act (EMTALA), 42 U.S.C. § 1395dd? 2. Whether the District Court and the Court of Appeals erred in dismissing the Petitioner's complaint for failure to state a claim under Title III of the Americans with Disabilities Act (ADA), 42 U.S.C. § 12181 et seq?
Timeline
Decision
What the Court decided
The Supreme Court declined to hear Smith's case, leaving the Eleventh Circuit's result in place without deciding the legal questions.
Impact
The lower-court result remains in place for Smith. Patients bringing EMTALA claims and people alleging disability discrimination by places open to the public may face similar dismissal questions in the Eleventh Circuit.
Briefing
What it's about
Lakesha Smith asked the Supreme Court to review the Eleventh Circuit's dismissal of her claims under EMTALA and the ADA against St. Joseph's/Candler Health System. The Court declined review and did not decide the merits.
Impact
The lower-court result remains in place for Smith. Patients bringing EMTALA claims and people alleging disability discrimination by places open to the public may face similar dismissal questions in the Eleventh Circuit.
What's next
The Supreme Court has finished its action on this docket. The Eleventh Circuit's result remains in effect for this case.
What did the Supreme Court do in Smith v. St. Joseph's/Candler Health System?
The Court declined to review the case. It did not decide Smith's EMTALA or ADA arguments.
Who is affected by the result in Smith's case?
Smith is directly affected because the Eleventh Circuit's dismissal remains in place. Similar plaintiffs in that circuit may confront comparable pleading issues.
What happens next after the Supreme Court declined review?
The Supreme Court's docket action is finished. The Eleventh Circuit's result continues to govern this case.
Timing
Decided April 20, 2020
The Court released its decision on April 20, 2020 without hearing oral argument.
Documents
Activity
AI analysis generated: Case Briefing
Brief added: Petition
Court Order added: Lower Court Orders/Opinions
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Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.