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Maryland’s One Satisfaction Rule

What happens when one person’s injuries are caused by more than one person’s negligence? Often, the responsibility, or liability, for the harm suffered by the injured person will be shared by all of the negligent parties. However, once the injured party has obtained full satisfaction for all of his or her claims from one of the negligent parties, her or she may be prevented from recovering from the other parties under Maryland’s “one satisfaction” rule. If you have been injured and believe that the negligence of one or more than one party has caused your injuries,The Law Office of Robert R. Castro can help you understand this rule, and, most importantly, help you recover just and fair compensation for your injuries.

How Does the One Satisfaction Rule Work?

Generally, the one satisfaction rule is aimed at preventing someone from recovering twice for the same injuries. The application of this rule by two lower courts was recently upheld by Maryland’s highest court in the case of Gallagherv. Mercy Medical Center, Inc. In this case, the court held that the plaintiff, who was first injured in a car accident and, subsequently, sustained injuries in a hospital, was barred from suing the hospital because she had already settled her claims, in full, with the negligent driver and her insurer. Essentially, the court found that the settlement of the plaintiff’s claims in a lawsuit she brought against the other driver and her insurance company encompassed all of the injuries she sustained, including the injuries that she alleged were caused by medical malpractice that were the basis of her medical malpractice action.

What Happened in Gallagherv. Mercy Medical Center, Inc.

Here are the key facts of this case:

  • The plaintiff was injured in an automobile accident when her car was struck from behind by another vehicle in January, 2009
  • In 2011, the plaintiff filed a lawsuit alleging negligence against the driver of the other vehicle and breach of contract against her uninsured/uninsured insurance carrier
  • The plaintiff underwent two reconstructive breast surgeries after the accident, one in April, 2011 and one in October, 2012
  • After the surgeries, the plaintiff developed an infection
  • While being treated for the infection, the plaintiff was injured when a catheter punctured an artery in her upper arm
  • The plaintiff underwent surgery to repair the artery and, subsequently, received out-patient treatment for the pain in her arm
  • The plaintiff settled her negligence claim against the other driver in April, 2012
  • The plaintiff settled her breach of contract claim with her uninsured/underinsured motorist insurance carrier in January, 2015
  • The plaintiff filed a negligence lawsuit against the hospital in April, 2016

Based on these key facts, along with others that are set forth in the Court of Appeals of Maryland’s decision, since the plaintiff had already obtained a settlement from her uninsured/underinsured insurance carrier for the same injuries she alleged in the medical malpractice action, she had already received full compensation for her injuries, and her medical malpractice action was barred by the one satisfaction rule. If you have been injured in a car accident in Maryland and have questions about the application of the one satisfaction rule to your claim, contact our professional and experienced team of Maryland personal injury lawyers.