Christopher Fonte v. Memorial Hospital of Laramie County, dba Cheyenne Regional Medical Center, et al.

The Due Process Clause limits the authority of federal courts to extinguish federal statutory causes of action by enforcing state law in a form the state itself does not recognize or apply. In cases such as EMTALA, which ties its civil remedy to state personal-injury law and disclaims preemption absent direct conflict, due process is violated when a federal court forecloses a federal claim by enforcing a state procedural prerequisite in a form the state’s own controlling precedent does not apply. Where federal protections incorporate and coexist with state law, this Court requires federal courts to ascertain and apply controlling state law, not replace it with a different rule before treating a prerequisite as outcome-determinative. Breaking from this Court’s precedent and its own, the court below failed to apply controlling state law, or to certify any perceived ambiguity to the State’s highest court before creating and enforcing a version of a notice-of-claim requirement that does not exist under the State’s own controlling precedent. The question presented is: Whether federal courts exceed their authority by enforcing state law in a form the State’s highest court does not recognize, thereby nullifying a federal statutory right in violation of the Due Process Clause.