Kolari v. New York-Presbyterian Hospital
Plaintiffs, a group of uninsured and indigent patients, brought a consolidated action against New York-Presbyterian Hospital, NY-Presbyterian Health Care System, Inc., and the American Hospital Association. They argued that private non-profit hospitals are legally obligated to provide free or reduced-rate services to uninsured individuals and that the rates charged were unreasonable compared to those offered to insured patients. The plaintiffs alleged violations of federal laws, including 26 U.S.C. § 501(c)(3) (tax exemption), the Fair Debt Collection Practices Act (FDCPA), the Emergency Medical Treatment and Active Labor Act (EMTALA), and 42 U.S.C. § 1983, as well as various New York state laws, such as breach of contract, breach of charitable trust, New York General Business Law § 349, unjust enrichment, and fraud. The District Court granted the defendants' motions to dismiss all claims with prejudice, concluding that no federal or state law requires private non-profit hospitals to offer free or reduced-rate care or to charge uninsured patients the same as insured patients. The court found that plaintiffs lacked standing for several claims and failed to state a claim upon which relief could be granted for the remaining allegations.