Gallagher v. Mercy Med. Ctr., Inc., 463 Md. 615

Summary

The Maryland Court of Appeals held that Michele Gallagher’s medical malpractice claim against Mercy Medical Center was barred by the one satisfaction rule. Gallagher’s prior settlement with her uninsured/underinsured motorist carrier encompassed the same injuries attributed to Mercy, leaving no damages remaining to recover.

Holdings

1. A settlement accompanied by a dismissal with prejudice may constitute an acceptance of full compensation and therefore may satisfy a plaintiff's claim for purposes of the one satisfaction rule; the rule is not limited to judgments that have been paid in full.
2. Gallagher's medical malpractice claim against Mercy was barred by the one satisfaction rule because her State Farm settlement embodied her evaluation and compensation of the same PICC-line injuries alleged in the malpractice action.
3. The collateral source doctrine did not prevent application of the one satisfaction rule because State Farm's contractual liability was tied to injuries caused by the negligent driver and vehicle owner, who were successive tortfeasors connected to Mercy's alleged malpractice.

Questions Presented

1. Whether the one satisfaction rule can bar a later action when the prior action ended in a settlement and dismissal with prejudice rather than a paid judgment.
2. Whether Gallagher's State Farm settlement constituted full satisfaction of the PICC-line injuries for which she later sought recovery from Mercy.
3. Whether the collateral source doctrine prevented the State Farm settlement from constituting satisfaction of the injuries.

Disposition

affirmed