A Plaintiff is Entitled to One Satisfaction for her Injuries, even when the alleged prior satisfaction is a settlement, not a judgment
July 16, 2019 By Mark A. Kohl
Maryland’s courts have long-recognized that multiple tortfeasors can contribute to a plaintiff’s injuries, and that the plaintiff is entitled to only one satisfaction for her injuries. For example, a driver injured in a car accident can recover (from the at-fault driver) for injuries arising from errors made by her treating doctors. However, the same motorist is barred from obtaining a judgment first against the at-fault driver, and then (when dissatisfied with the award), seeking a second judgment against her treating providers.
In Gallagher v. Mercy Medical Center the Court of Appeals clarified that the “one satisfaction rule” applies to settlements as well as judgments. In Gallagher a motorist settled her claims against the alleged tortfeasor and her uninsured motorist carrier, then later filed suit against her medical providers. During discovery in both actions Plaintiff claimed as damages injuries arising from the conduct of her medical providers (although in the motor vehicle case the trial judge struck portions of those claims due to discovery violations). In reaching its holding that the Plaintiff’s claims in the medical malpractice case were barred, the Court focused on whether the injuries claimed in the prior action were the same (they were). The Court was untroubled that the auto claim was settled rather than tried (noting that the doctrine was called the “one satisfaction” rule, not “one judgment” rule). The Court was also unconcerned with the trial court’s exclusion of certain evidence or claims.
The ruling underscores the importance of clarifying what claims were actually raised in the prior case in any situation where prior litigation has occurred regarding the same loss.