Published by Arfaa Law Group
When multiple incidents contribute to a patient’s injuries, courts must carefully determine whether a prior settlement bars recovery in a subsequent medical malpractice action. The one satisfaction rule prevents double recovery, but its application requires a detailed analysis of the injuries involved and the scope of any prior release. A recent Maryland decision clarifies these principles and demonstrates the importance of distinguishing between separate causes of harm. If you are dealing with overlapping injury claims in Maryland, it is important to consult with a Baltimore medical malpractice attorney who can protect your right to full compensation.
History of the Case
Allegedly, the plaintiff sought emergency treatment for worsening back pain and neurological symptoms, where healthcare providers failed to diagnose a serious spinal condition requiring urgent intervention properly.
It is alleged that following this encounter, the plaintiff’s condition deteriorated significantly, leading to surgery and long-term complications, including loss of mobility and bodily function. The plaintiff subsequently filed a medical malpractice action against the providers involved.
Reportedly, several years later, the plaintiff was involved in a motor vehicle accident that resulted in additional injuries, including a fractured hip and further physical limitations.
It is reported that the plaintiff pursued a separate negligence claim arising from the accident and ultimately settled that case, executing a release covering injuries related to the motor vehicle incident.
Reportedly, the defendants in the medical malpractice action moved for summary judgment, arguing that the settlement triggered the one satisfaction rule and barred the plaintiff from recovering additional damages. The trial court agreed and dismissed the malpractice case. The plaintiff then appealed.
The One Satisfaction Rule
The appellate court examined the application of the one satisfaction rule, which prevents a plaintiff from obtaining multiple recoveries for the same injury. The court emphasized that the rule applies only when a prior settlement compensates the plaintiff for the same harm at issue in the current action.
The court analyzed the release’s language and found it limited to injuries arising from the motor vehicle accident. It rejected the notion that the timing of the settlement alone could bar unrelated claims.
The court further explained that proper application of the rule requires a detailed comparison of the injuries alleged in each case. The trial court erred by focusing exclusively on medical records following the accident without considering the plaintiff’s condition before the accident or distinguishing between the sources of her injuries.
Because the injuries from the alleged malpractice and the motor vehicle accident were not clearly identical, and because the record did not establish that the settlement fully compensated the plaintiff for all claimed damages, the court concluded that summary judgment was improper.
The court therefore reversed the decision and remanded the case for further proceedings.
Speak with an Experienced Baltimore Medical Malpractice Attorney at Arfaa Law Group
If you sustained injuries because of inadequate medical care, it is in your best interest to talk to an attorney to prevent your claims from being unfairly limited or dismissed. The experienced Baltimore medical malpractice attorneys at Arfaa Law Group can evaluate your situation and help you pursue the compensation you deserve. You can reach out through our online contact form or call (410) 889-1850 to set up a meeting.