Smith (P) was pregnant and was admitted to Richmond (D) with premature rupture of the uterine membranes. The condition developed into a medical emergency with contractions. P was ordered transferred to another hospital where she was taken to the delivery room, and both mother and child suffered substantial deliveries from the caesarean. P sued D, and the trial court sustained a demurrer to the complaint against D. The issue was over the interpretation of COBRA and whether P fell within its ambit for emergency medical treatment for women in active labor.