Maryland Court Discusses One Satisfaction Rule in Medical Malpractice Cases

It is not uncommon for a patient harmed by medical malpractice to have underlying claims arising out of the harm that caused the initial need for medical treatment. It is crucial for anyone harmed by negligent medical care to understand how any related claims may affect a potential claim against the care provider. This was demonstrated in a recent Maryland case in which the plaintiff’s medical malpractice case was dismissed due to her settlement with her insurer following a car accident. If you were harmed by inadequate medical care, it is advisable to meet with a trusted Maryland medical malpractice attorney regarding what claims you may be able to pursue.

Factual Background

Reportedly, the plaintiff suffered injuries in a car accident. Following the accident, she underwent bilateral reconstructive breast surgeries at the defendant hospital. She subsequently developed cellulitis, which was treated with intravenous antibiotics, which were administered through a PICC line in her left arm. When the line was being inserted, it punctured her brachial artery. The plaintiff then underwent surgery to repair her brachial artery. She developed pain and reflex sympathetic dystrophy in her arm as a result of the injury to her brachial artery.

It is alleged that the plaintiff filed a lawsuit against the driver and ultimately settled the case, signing a release of all claims. Although the release expressly reserved the plaintiff’s right to pursue claims against her insurance carrier, it did not mention the defendant hospital. The plaintiff then filed a lawsuit against her insurance carrier for breach of contract. She alleged the harm suffered due to the PICC line as an element of damages. The claim eventually settled.

Subsequently, the plaintiff filed a medical malpractice lawsuit against the defendant hospital. The hospital filed a motion for summary judgment, arguing that the plaintiff’s claims were barred by the one satisfaction rule. The court granted the motion, and the plaintiff appealed. On appeal, the trial court’s ruling was affirmed.

One Satisfaction Rule

Under Maryland law, while more than one actor may be held responsible for a plaintiff’s harm, a plaintiff can only recover one compensation for his or her harm. In other words, under the one satisfaction rule, a plaintiff is only entitled to one compensation for his or her damages, and satisfaction of the plaintiff’s claim bars the plaintiff from pursuing subsequent claims against another party that may be responsible for the same harm.

The rule applies when a plaintiff seeks to recover compensation for injuries he or she received compensation for in a prior lawsuit, regardless of whether the prior damages were paid by joint tortfeasors, a party acting separately to cause harm, or by a paying party that had no connection with the harm, such as an insurer. To determine whether the one satisfaction rule applies, a court will compare the injuries in each action.

In the subject case, the court found that the settlement with the insurer constituted a satisfaction. Further, the court found that upon review of the evidence of record, it was clear that the plaintiff sought to recover compensation for the harm caused by the insertion of the PICC line. Thus, the court found that the plaintiff’s claim against the defendant hospital was barred by the one satisfaction rule and affirmed the trial court ruling.

Speak with a Proficient Maryland Medical Malpractice Attorney

If you suffered harm because of incompetent treatment by a medical care provider, it is prudent to speak with a proficient Maryland medical malpractice attorney regarding your rights and what evidence you must produce to support your claims. The knowledgeable attorneys of Arfaa Law Group are skilled at assisting people in the pursuit of damages for medical malpractice and will work tirelessly to help you seek a successful result. You can contact us via our online form or at (410) 889-1850 to schedule a confidential and free meeting.


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