Maryland Court Discusses “One Satisfaction” Rule in Recent Personal Injury Case

Recently, a state appellate court issued a written opinion in a case that originally arose after the plaintiff was injured in a Maryland car accident. The case required the court to determine if the plaintiff’s subsequent medical malpractice lawsuit against her treating physicians was precluded by the one satisfaction rule.

According to the court’s opinion, the plaintiff was injured in a car accident that was caused by another driver. The plaintiff was treated for her injuries at the defendant hospital. While she was being treated at the hospital, medical providers punctured the plaintiff’s brachial artery as they attempted to insert a Peripherally Inserted Central Catheter (PICC) line. The plaintiff developed an infection that required additional surgery.

The plaintiff initially filed a claim against the at-fault motorist seeking compensation for “emotional pain and suffering, past and future medical expenses, and the inability to engage in her usual employments, activities, and pursuits.” The plaintiff settled with the at-fault driver’s insurance company for $25,000, and then filed an underinsured-motorist claim with her insurance company. That claim was settled before trial for $125,000. The hospital was not a part of either settlement agreement.

After the two cases against the insurance companies were settled, the plaintiff filed a medical malpractice case against the hospital. The plaintiff acknowledged that she had received compensation for her injuries through the previous two lawsuits, but claimed that the hospital’s negligence was a separate occurrence. The hospital moved to dismiss the plaintiff’s case against it, arguing that the one satisfaction rule precluded her recovery.

The court explained that the one satisfaction rule is implicated in cases where there are multiple parties who are responsible for a plaintiff’s injuries. Under the rule, “a plaintiff is entitled to one compensation for his or her loss, and satisfaction of the plaintiff’s claim prevents the plaintiff from pursuing another who may be liable for the same damages.”

Here, the hospital argued that the plaintiff was “satisfied” for her injuries through the prior claims against the insurance companies. The court agreed. The court explained that any medical treatment the plaintiff received as a result of the car accident was directly related to the accident and was a part of her claim against the insurance companies. Thus, the court held that the plaintiff had already recovered for the injuries that the plaintiff was attributing to the hospital. As a result, the court dismissed the plaintiff’s case.

Have You Been Injured in a Maryland Car Accident?

If you or someone you love has recently been injured in a Maryland car accident, you may be entitled to monetary compensation. At the Maryland law firm of Lebowitz & Mzhen, LLC we help Maryland car accident victims and their families pursue claims for compensation for the injuries they have sustained. We handle serious car accident claims in Maryland, Virginia, and Washington, D.C, as well as premises liability lawsuits and medical malpractice cases. To learn more, and to schedule a free consultation to discuss your case with one of our dedicated personal injury advocates, call 410-654-3600 today.

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