One Satisfaction: Oxley v. Frederick
The Baltimore Medical Malpractice Lawyer Blog examines Maryland appellate court opinions in medical malpractice cases. In this post, I discuss the one satisfaction role. The case is the Appellate Court of Maryland’s reported opinion in Oxley v. Frederick Mem. Hosp., et al., on February 2, 2026.
Factual Background to the One Satisfaction Rule
The appellate court noted that the plaintiff has an extensive and complex medical history. (Op. At 2).
In 2009, the plaintiff reported chronic myalgias and extreme fatigue affecting her shoulders, wrists, neck, thoracic area, hips, knees, and ankles. Doctors then diagnosed her with osteoporosis and degenerative spine disease. (Id.).
In 2012, the plaintiff suffered a traumatic brain injury (“TBI”) when she fell down a flight of stairs, resulting in massive intracranial bleeding that left her cognitively and physically disabled. Following her TBI, the plaintiff suffered from vision problems, balance disturbances, and reduced strength. She required assistance with virtually all activities of daily living, was unable to walk without assistance, dress, or use the bathroom independently, and was found to be “disabled” by the Social Security Administration. (Id.).
This history preceded the events that gave rise to one satisfaction rule issue.
Alleged Medical Malpractice
On July 19, 2017, the plaintiff visited the defendant hospital’s emergency department with complaints of ongoing and worsening low back pain. She denied any recent falls and denied incontinence. On examination, she had normal strength in her lower legs. She was diagnosed with nontraumatic back pain, and, after a few hours, she improved in the emergency department and was released to receive physical therapy at home. (Id.).
On July 31, 2017, a physician saw the plaintiff following complaints of back pain and urinary incontinence. An MRI revealed a “severe compression deformity” and “stenosis and disc protrusion” in her lumbar spine. The plaintiff visited a spine surgeon on August 4, 2017, who prescribed her a back brace that she refused to wear and scheduled her for spine repair surgery to be conducted ten days later. Before the surgery could take place, however, the plaintiff was discharged from the surgeon’s practice after her sister was abusive toward the office. (Id.).
On August 19, 2017, the plaintiff was evaluated at a different hospital’s emergency department for the onset of generalized weakness and told staff that she had been falling several times a day due to her weakness. The following day, she required immediate medical intervention as a result of severe, life-threatening, or potentially disabling conditions. She transferred to the Johns Hopkins emergency department, where they admitted her. (Id. at 3-4).
The plaintiff subsequently underwent spine surgery on August 23, 2017. While recovering after the surgery in her hospital room, she fell when she attempted to go to the bathroom. Her right hip was fractured as a result of this fall, and corrective surgery was performed the following day. (Id. at 4). This was the unsettled claim part of the one satisfaction rule in this case.
Medical Malpractice Claim
The plaintiffs filed a complaint in the Circuit Court for Frederick County on April 2, 2019, alleging medical malpractice during the July 19, 2017, emergency department visit. The plaintiffs’ complaint contended that the defendants’ negligent failure to diagnose contributed to the plaintiff’s development of cauda equina syndrome, conus medullaris syndrome, and permanent damages, including bowel and bladder incontinence, severe back and leg pain, numbness, and weakness. (Id. at 4-5).
The court twice postponed the trial until ultimately scheduling it for May 20, 2024. (Id. at 5).
Car Accident
While awaiting the trial, on May 1, 2021, nearly four years after the alleged medical malpractice, the plaintiff was involved in a motor vehicle accident resulting in multiple injuries, including a left hip fracture. She had left hip surgery on May 2, 2021. Her medical records documented both current problems and historical ones. (Id. at 5-6).
On November 17, 2022, the plaintiff filed a complaint concerning the car accident case. The plaintiff settled the suit for $100,000 and gave a release concerning the accident. (Id. at 6-7). This was the settled claim in the one satisfaction rule issue. The release did not mention or carve out exceptions for the plaintiff’s then-pending medical negligence suit or any other injuries before the May 1, 2021, motor vehicle accident. (Id. at 7).
The plaintiffs did not disclose the motor vehicle negligence proceedings or the release to their trial counsel in the medical negligence case. Counsel learned afterward of the release. (Id.).
The defense moved for summary judgment based on the release, and the court granted it under the one satisfaction rule. (Id. at 8). The plaintiffs appealed. (Id. at 9).
Appellate Court of Maryland on the One Satisfaction Rule
The one satisfaction rule states that there can be only one satisfaction for the same injury. The first step is to identify what constituted the plaintiff’s alleged satisfaction. Satisfaction is an acceptance of full compensation for an injury. In addition, the unresolved negligence must flow legitimately as a natural and probable consequence of the satisfied injury. (Id. at 13).
In the second step, the court decides whether the satisfaction from the first-resolved action encompassed all of the injuries sustained by the plaintiff, including those injuries, in the subsequent proceeding, alleged to be attributable to the negligence in the second, unresolved action. (Id. at 14).
The alleged satisfaction here is the $100,000 payment that the plaintiff accepted in the motor vehicle negligence case. The Release was limited to injuries arising out of the car accident. This did not make the plaintiff whole for medical malpractice claims arising four years before the car accident. (Id. at 15-16).
In addition, the car accident case focused on the fracture of the left hip, while the medical malpractice case focused on matters that preceded the car accident: cauda equina syndrome, conus medullaris syndrome, and permanent damage, including bowel and bladder incontinence, severe back and leg pain, numbness, and weakness.
Because the motor vehicle negligence release did not represent a satisfaction of the plaintiff’s medical negligence claims, the Appellate Court held that the one satisfaction rule does not bar the medical negligence action from proceeding. (Id. at 19).
Commentary By Baltimore Medical Malpractice Lawyer Mark Kopec on the One Satisfaction Rule
The analysis of the one-satisfaction rule in this case is straightforward. The medical malpractice did not flow from the car accident injury. It preceded it. (Unlike a situation where a car accident caused injury, and during treatment for the injury, the plaintiff was harmed by medical malpractice. See Blog post, One Satisfaction: Gallagher v. Mercy)
Moreover, the plaintiff got separate injuries in the two events. The medical malpractice allegedly resulted in incontinence and pain in the lower back. The car accident resulted in a broken left hip.
There is no reasonable analysis that could conclude that the car accident settlement compensated the plaintiff for the medical malpractice injuries.
Practical Considerations
In the context of releases, I’ve previously written in this Blog about the importance of medical malpractice and car accident lawyers coordinating their efforts to ensure that their claims do not interfere with each other’s. In this case, no one told the medical malpractice lawyer about the car accident, the injury, the claim, or the settlement until afterward. That should not happen.
The bigger concern for the plaintiff in this case should not be the one satisfaction rule or the car accident injury. Rather, it is her prior history of disabling medical conditions. There is no question that the incontinence caused by cauda equina syndrome and conus medullaris syndrome is a horrible thing to have to live with. On remand, however, the defense will emphasize how difficult the plaintiff’s daily life was for years before the alleged medical malpractice occurred.
You can read other Blog posts on cases involving Damages and Settlement issues.
Mark Kopec is a top-rated Baltimore medical malpractice lawyer. Contact us at 800-604-0704 to speak directly with Attorney Kopec in a free consultation. The Kopec Law Firm is in Baltimore and helps clients throughout Maryland and Washington, D.C. Thank you for reading the Baltimore Medical Malpractice Lawyer Blog.