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The One Satisfaction Rule

A well-settled legal principle in Maryland, commonly known as the “One Satisfaction Rule,” generally limits injured parties to one full recovery for their injuries. While superficially simple, the notion of what constitutes one satisfaction is not always clear.

In a recent illustrative matter, Maryland’s highest appellate court barred an injured party’s medical malpractice recovery, because the injured party had previously settled a motor vehicle claim involving the same injuries.

A.  The Facts

In 2009, Michele Gallagher was injured in a motor vehicle collision when she was rear-ended by another vehicle. As a result of her injuries, she underwent two reconstruction surgeries at Mercy Medical Center. Unfortunately, Gallagher developed post-surgical infections, and her doctors decided to administer antibiotics through a PICC line catheter to stop the infection.

Further complicating Gallagher’s predicament, as Mercy was placing the catheter, Mercy providers allegedly punctured Gallagher’s brachial artery. Ultimately, Gallagher underwent a final surgery to repair her brachial artery; however, she never fully recovered and was left with permanent physical impairments.

Initially, Gallagher filed a motor vehicle negligence lawsuit against the at-fault driver, as well as an underinsured motorist claim against her own insurance carrier. In her case against both of these defendants, she alleged that the driver’s negligence caused all of her injuries, including those that arose due to injuries from the PICC line insertion. Ultimately, she settled the motor vehicle negligence claim and the underinsured motorist claim for $150,000.

Ten months after her motor vehicle claim was settled, Gallagher filed another lawsuit alleging that Mercy Medical Center had committed medical malpractice when it caused her PICC line injuries. In defense, Mercy argued that the damages sought by Gallagher in the malpractice action had already been recovered by her. That is, the damages Gallagher was claiming against Mercy were the exact same damages she had sought and recovered in her previously settled motor vehicle negligence case.

In support of its position, Mercy cited Gallagher’s discovery responses from the previously settled claims in which she asserted the PICC line injuries. Accordingly, Mercy argued to the trial court that Gallagher’s claims should be dismissed under the One Satisfaction Rule. The trial court agreed with Mercy and granted its motion to dismiss. Gallagher appealed the ruling.

B. The Holding

In Gallagher v. Mercy Medical Center, Inc., Maryland’s highest appellate court recently affirmed the lower court’s ruling, holding that Gallagher’s medical malpractice claim was barred under the One Satisfaction Rule.

In refusing to do an evaluation of whether Gallagher had received “fair” compensation, the court instead reasoned that whether she had already received “one” full satisfaction depended on whether or not she had received compensation for the injuries related to the alleged malpractice at Mercy Hospital in her prior settlement.

Given that Gallagher asserted PICC line injuries in the previously settled auto tort claim, the court concluded that the compensation she received “encompassed her PICC line injuries, for which she now seeks recovery ... .” Accordingly, Gallagher’s subsequent malpractice claim was barred.

C. Analysis

This case has important implications for all litigants who contemplate multiple lawsuits arising from the same transaction or occurrence. Injured parties, who attempt to seek separate recoveries against various defendants, may need to weigh carefully the timing of asserted damages claims and determine in which action each claim would be most effective.

Conversely, defendants who find themselves in one among a series of lawsuits may find it useful to determine their positioning in the crowd. Such defendants might be able to chip away at some or all of an injured party’s claims if the injured party has alleged indistinguishably similar injuries in prior litigation.

Justin P. Katz
410-576-4102 • jkatz@gfrlaw.com

Barry Rosen
410-576-4224 • brosen@gfrlaw.com


A version of this article appeared inThe Daily Recordon February 6, 2020.


September 23, 2019




Katz, Justin P.


Health Care