Gallagher v. Mercy Med. Ctr., Inc., 207 A.3d 634

Michele Gallagher was injured in a 2009 auto accident, underwent two reconstructive breast surgeries at Mercy Medical Center, developed cellulitis, received a PICC line on Nov. 12, 2012, which punctured her brachial artery, and required vascular surgery and ongoing treatment.
Gallagher sued the negligent driver and owner and pursued an uninsured/underinsured motorist (UIM) breach-of-contract claim against her insurer, State Farm, alleging the accident (and resulting treatments including PICC line injuries) caused her damages.
She settled the tortfeasor claims for the policy limit and later, after discovery and a partially contested evidentiary posture, settled with State Farm for $125,000 and dismissed that case with prejudice.
Gallagher subsequently filed a medical malpractice suit against Mercy alleging negligent PICC line insertion and post-procedure care caused additional injury to her left arm.
Mercy moved for summary judgment asserting the one satisfaction rule; the trial court granted summary judgment, the Court of Special Appeals affirmed, and the Maryland Court of Appeals granted certiorari to decide whether Gallagher’s State Farm settlement barred her malpractice claim.
The Court of Appeals held the State Farm settlement constituted a satisfaction that fully compensated Gallagher for the same injuries she later sought from Mercy, and therefore the malpractice claim was barred by the one satisfaction rule.

Issue	Gallagher's Argument	Mercy's Argument	Held
Whether a prior settlement (no final judgment) with a UIM insurer that resulted in dismissal with prejudice can constitute a "satisfaction" barring a later malpractice claim under the one satisfaction rule	Settlement with State Farm cannot be a full satisfaction unless a judgment was entered; Gallagher settled under duress from discovery sanctions and inadequate recovery, so she still has recoverable damages against Mercy	The State Farm settlement (with dismissal with prejudice) covered the same injuries Gallagher later sued Mercy for (including PICC line injuries); once full satisfaction is accepted, one cannot recover again	Held: Settlement amounted to a full satisfaction for the injuries claimed; Gallagher’s malpractice suit is barred by the one satisfaction rule

Morgan v. Cohen, 309 Md. 304 (1987) (defines "satisfaction" and explains the one-satisfaction rule; whether a prior recovery covered subsequent torts is a factual question)
Underwood-Gary v. Mathews, 366 Md. 660 (2001) (applies one-satisfaction rule where settlement/judgment in earlier action embodied evaluation of all harms later claimed against treating physicians)
Kennedy Krieger Institute, Inc. v. Partlow, 460 Md. 607 (2018) (sets summary judgment standard in Maryland; appellate review is de novo)