Conner v. Stelly

Summary

The Louisiana Supreme Court held that although a $100,000 malpractice settlement establishes liability and damages of at least $100,000, the plaintiff must prove that the malpractice caused damages exceeding that amount in a trial against the Patient's Compensation Fund. The court reversed the trial court's prohibition on presenting evidence of victim or third-party fault and remanded for further proceedings, with dissents arguing that such fault issues were precluded after the provider admitted liability and settled.

Holdings

1. Payment of $100,000 in settlement establishes proof of liability for the malpractice and proof of damages of at least $100,000 resulting from the malpractice, but the plaintiff retains the burden of proving that the admitted malpractice caused damages exceeding $100,000.
2. The Patient's Compensation Fund may argue or present evidence before the jury that victim or third-party fault caused damages, notwithstanding the provider's $100,000 settlement and admission of malpractice liability.

Questions Presented

1. Whether payment of $100,000 in settlement establishes proof of liability and damages of at least $100,000 resulting from the malpractice, while leaving the plaintiff responsible for proving damages exceeding $100,000 against the Patient's Compensation Fund.
2. Whether the Patient's Compensation Fund may argue or present evidence that victim or third-party fault caused damages beyond the $100,000 settlement.

Disposition

reversed_and_remanded