One Satisfaction: Gallagher v. Mercy
The Baltimore Medical Malpractice Lawyer Blog features legal issues in Maryland medical malpractice cases. In this post, I examine the legal principle called the one satisfaction rule. Specifically, I examine its application when medical malpractice occurs in treating car accident injuries. The case is the Court of Appeals reported opinion in Gallagher v. Mercy Medical Center, Inc., 463 Md. 615 (2019).
Factual Background
The plaintiff suffered injuries in a car accident in January 2009. (Op. at 1). She then underwent two reconstructive breast surgeries in April of 2011 and October of 2012. In the month following the second surgery, the plaintiff developed an infection. When the medical provider inserted a PICC line to administer antibiotics, it damaged her brachial artery. The plaintiff had surgery to repair the artery and developed Reflex Sympathetic Dystrophy in her arm. (Id. at 2).
The plaintiff filed a lawsuit against the other driver and her own insurer for underinsurance coverage. (Id. at 2). In April and May of 2012, the plaintiff settled her claim against the driver. The driver paid $25,000, which was the full policy amount. The plaintiff provided a release to the driver that reserved her claim against her own insurer but did not mention the hospital. The plaintiff filed a dismissal with prejudice of her claim against the driver. (Id. at 3).
The plaintiff’s claim proceeded against her insurer. The damages that she sought would be important to the one satisfaction rule. In discovery responses, the plaintiff stated that she was seeking damages relating to both surgeries, the infection that followed, and the permanent arm injury that resulted. The plaintiff had expert witnesses testify to the causal connection between the breast surgeries and the car accident. (Id. at 4).
As part of a discovery dispute, the trial court excluded some of the plaintiff’s medical bills from the PICC line procedure because they were produced too late. During the trial in January 2015, the parties settled the underinsurance claim for $125,000, which they dismissed with prejudice. (Id. at 5).
Medical Malpractice Lawsuit
In November 2015, the plaintiff filed a medical malpractice case against the hospital that had treated her. HCADRO transferred the case to the Circuit Court for Baltimore City. She claimed damages relating to the PICC line procedure. (Id. at 5-6).
Application of One Satisfaction Rule
The hospital filed a motion for summary judgment based on the one-satisfaction rule. The circuit court found that the damages the plaintiff sought were the same as she accepted in settlements in the car accident case. The court granted the motion for summary judgment. (Id. at 6-7).
The plaintiff appealed, and the Court of Special Appeals affirmed. The plaintiff appealed to the Court of Appeals. (Id. at 7).
Court of Appeals
A negligent driver can be liable for additional harm when others render aid, regardless of their negligence. There can be situations where a driver and subsequent doctor can both be liable for the same damage. However, where multiple people are responsible for harm, the plaintiff is entitled to compensation for her injuries. (Id. at 8).
The one satisfaction rule establishes that a plaintiff is entitled to one compensation for their loss, and satisfaction of the plaintiff’s claim prevents the plaintiff from pursuing another who may be liable for the same damages. (Id.). It is an equitable rule to prevent double recovery for the same injuries. (Id. at 9).
Satisfaction is an acceptance of full compensation for an injury. Once a plaintiff obtains total satisfaction, she cannot pursue another who may be liable for the same damages. (Id. at 9-10).
To assess the application of the one satisfaction rule, the court must compare the injuries for which the plaintiff received compensation in her first action and the injuries for which the plaintiff seeks compensation in the subsequent action. The court examines various materials from the earlier action, such as the complaint, the settlement agreement, and any expert reports, to make this determination. This process ensures the plaintiff does not receive double recovery for the same injuries.
Application of the Rule
The plaintiff argued that the one satisfaction rule only applies when a defendant in the first suit pays a judgment in full. The court found that prior cases contradicted this argument. (Id. at 13-14).
The litigation between the plaintiff and the insurer encompassed years, and voluminous materials were available to the circuit court to assess the application of the rule. The court also had many materials from the medical malpractice case. There was no dispute about what the materials showed. (Id. at 14-15). The court found that these materials showed that the plaintiff’s settlement with the insurer covered all of the injuries that the plaintiff later sought in the medical malpractice suit. (Id. at 15-16).
The plaintiff argued that the settlement with her insurer did not constitute a full satisfaction of all of her injuries. She specifically relies on the court’s exclusion of some PICC line medical bills. She also says there was no total satisfaction because she compromised her claim for far less than she sought. (Id. at 17). The court rejected these assertions. The plaintiff voluntarily settled her first action, and the court would not revisit the value received. (Id. at 18). The court upheld the summary judgment. (Id. at 19).
Commentary by the Baltimore Medical Malpractice Lawyer on the One Satisfaction Rule
The one satisfaction rule, while straightforward in its statement, can be a labyrinth of complexities to navigate. The unique situation in this case, where a car accident victim becomes a victim of medical malpractice, is a scenario that arises from time to time, demanding a meticulous understanding of the rule.
The analysis of what damages to seek in each case can be complex. It can depend on the strengths and weaknesses of claims and defenses and the amounts of insurance available, among other factors.
It can be particularly challenging for a medical malpractice lawyer who did not handle the car accident case. In such a scenario, seamless coordination with the car accident lawyer becomes crucial to ensure there are no overlapping claims for medical malpractice damages. Even if the car accident lawsuit has concluded, the medical malpractice lawyer must meticulously review the file to determine its impact on the one satisfaction rule.
In this case, where the same law firm handled both cases, the plaintiff, following the Court of Appeals decision, sued her own law firm. This case serves as a stark reminder and a cautionary tale for medical malpractice lawyers, underlining the need for vigilance and foresight in their legal practice.
Mark Kopec is a top-rated Baltimore medical malpractice lawyer. Contact us at 800-604-0704 to speak directly with Attorney Kopec in a free consultation. The Kopec Law Firm is in Baltimore and helps clients throughout Maryland and Washington, D.C. Thank you for reading the Baltimore Medical Malpractice Lawyer Blog.