The Court of Appeals of Maryland (“Maryland Appellate Court”), Maryland’s highest appellate court, in its opinion filed on April 29, 2019 stated, “When multiple tortfeasors contribute to a plaintiff’s injuries, the plaintiff may choose how to structure his or her litigation against one or all tortfeasors in pursuit of compensation for those injuries. The law, however, will permit the plaintiff to obtain only one full satisfaction of his or her injuries. Such satisfaction will preclude the plaintiff from pursuing other tortfeasors for compensation for the same injuries.”
The Underlying Facts
The plaintiff was injured on January 15, 2009 when her motor vehicle was struck from behind by another motor vehicle (“other driver”). As a result of the collision, the plaintiff underwent two reconstructive breast surgeries, which were performed on April 28, 2011 and October 18, 2012, at the defendant hospital. Following the surgical procedures, the plaintiff developed an infection identified as cellulitis and was admitted to the defendant hospital to treat the infection with intravenous antibiotics. Attempts to administer the antibiotics failed, so three days later, she received the antibiotics through a Peripherally Inserted Central Catheter (“PICC line”). While the PICC line was being inserted into the plaintiff’s left arm, it accessed or punctured her brachial artery, requiring vascular surgery to repair her brachial artery. Subsequently, the plaintiff received out-patient treatment at the defendant hospital for pain and Reflex Sympathetic Dystrophy in her left arm.
The plaintiff filed a motor tort action against the other driver and her own uninsured/underinsured motorists carrier. She subsequently settled her claims against the other driver, signing a Release of All Claims (“Release”) that released her claims against the other driver and his automobile insurance company, but expressly reserved her claim against her uninsured/underinsured motorists carrier. However, the Release did not mention the defendant hospital.
The plaintiff pursued her breach of contract claim against her uninsured/underinsured motorists carrier, and in answers to interrogatories stated that she endured two surgeries and developed cellulitis; then, in the course of treating the cellulitis, insertion of a PICC line accessed or punctured her brachial artery, necessitating additional surgery and causing “severe and permanent impairment to her left [arm]” – all of which was “causally relate[d]  to the original accident of January, 2009.”
After opening statements during trial, the parties settled for $125,000.00. The parties placed their settlement on the trial record, the trial judge ordered the case settled and dismissed with prejudice, and the clerk entered the settlement on the docket.
Ten months later, the plaintiff filed her medical malpractice claim against the defendant hospital in the Health Care Alternative Dispute Resolution Office (“HCADRO”). The plaintiff ultimately waived arbitration in her HCADRO action, and she filed a medical malpractice complaint against the defendant hospital in the Circuit Court for Baltimore City, alleging that the defendant hospital was vicariously responsible for the negligent medical care that she received during the PICC line procedure. The plaintiff sought damages for personal injuries, present and future medical expenses, emotional pain and suffering, and inability to engage in her usual duties, employments, and activities.
The defendant hospital filed a motion for summary judgment, arguing that the plaintiff’s claim was barred by the one satisfaction rule. The trial court found that the damages the plaintiff sought from the defendant hospital were the same damages for which she accepted a settlement in the automobile accident case, concluding that the plaintiff already recovered for her injuries as part of her settlement with her uninsured/underinsured motorists carrier and therefore granted the defendant’s motion for summary judgment.
The One Satisfaction Rule
The Maryland Appellate Court stated that it is a well-settled principle of tort law that a negligent actor is liable not only for the harm that he directly causes but also for any additional harm resulting from normal efforts of third persons in rendering aid, irrespective of whether such acts are done in a proper or a negligent manner. For instance, if a plaintiff is injured in a motor vehicle accident by a negligent driver, the tortfeasor may be held liable for the plaintiff’s resulting injuries. If, subsequently, in the course of receiving treatment for his or her injuries, the plaintiff is negligently treated by a physician, the physician’s negligence is a subsequent tort for which the original tortfeasor and the doctor are jointly liable.
Although liability for a particular harm may be shared by multiple tortfeasors, the plaintiff is entitled to one compensation for his or her injuries. The one satisfaction rule establishes that a plaintiff is entitled to one compensation for his or her loss, and satisfaction of the plaintiff’s claim prevents the plaintiff from pursing another who may be liable for the same damages. The rule applies when an individual seeks to be compensated for injuries that he or she sustained, yet, in prior litigation, that individual was already compensated for the same injuries by a joint tortfeasor, concurrent wrongdoer not acting in concert, or a paying party who has no connection with the tort at all. Under such circumstances, the equitable one satisfaction rule applies to prevent double recovery for the same injuries.
In order to decide whether a plaintiff’s claim is barred by the one satisfaction rule, the court must study and compare the injuries for which the plaintiff received recovery in his or her initial action, and the injuries for which the plaintiff seeks recovery in his or her subsequent action. The injuries for which the plaintiff was compensated in the initial action are to be ascertained from an examination of the pertinent portions of the record including the plaintiff’s answers to interrogatories, the pretrial order, the testimony, the charge of the court and the opening and closing statements of counsel.
The Maryland Appellate Court stated that if the satisfaction in the present case only compensated the plaintiff for the injuries she initially sustained from the automobile accident, her claim for injuries that resulted from the subsequent medical malpractice is not barred. If, however, the satisfaction compensated the plaintiff for all of the injuries she sustained from the automobile accident and the medical malpractice, the plaintiff’s Maryland medical malpractice claim is barred by the one satisfaction rule.
The Maryland Appellate Court stated: “Here, by accepting a settlement, [the plaintiff] evaluated – for herself – her claim against [her uninsured/underinsured motorists carrier]. She weighed her claim’s value against the risk of placing her fate in the hands of the jury. That claim encompassed her PICC line injuries, for which she now seeks recovery from [the defendant hospital]. Where, as here, [the plaintiff] enters into an entirely voluntary settlement for all of the injuries that she sustained, she cannot ask the court to conduct a post hoc appraisal of the value of her claims.”
The Maryland Appellate Court held: “[The plaintiff’s] settlement with [her uninsured/underinsured motorists carrier] embodied her evaluation as to all of the injuries that she claimed in her medical malpractice action against [the defendant hospital]. [The plaintiff’s] claim against [the defendant hospital] is, thus, barred by the one satisfaction rule. We affirm the judgment of the Court of Special Appeals, which affirmed the trial court’s ruling granting summary judgment in favor of [the defendant hospital].”
Source Michele Gallagher v. Mercy Medical Center, Inc., No. 44, September Term, 2018.
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