Jerry Duffey, Individually and as Representative of the Estate of Bessie Faith Duffey v. Sleep Center of Longview and Baher Elhalwagi, M.D., Individually and D/B/A Sleep Center of Longview, 598 S.W.3d 711

Bessie Faith Duffey died after cardiopulmonary arrest during a sleep study; her husband (and representative of the estate) sued multiple providers for wrongful death and survival damages.
Plaintiffs sued Dr. Baher Elhalwagi and the Sleep Center (nonsettling defendants) and Dr. Charles Martin and East Texas Pulmonary Associates (settling defendants).
Martin and East Texas Pulmonary settled for $60,000 plus taxable court costs not to exceed $11,500 (total settlement amount $71,500), and the settlement agreement was placed into the record.
A Gregg County jury found the Sleep Center negligent and awarded $91,685.76 in damages; the nonsettling defendants moved for a settlement credit of $71,500, reducing the judgment to $20,185.76.
The trial court granted a dollar-for-dollar settlement credit; on appeal the plaintiff argued (1) no credit was allowed because the jury did not apportion fault to settling defendants and (2) any credit should be limited to the settlement agreement’s per-category allocations.
The Court of Appeals affirmed, holding Chapter 33 and the common-law one-satisfaction rule applied, the injuries were indivisible, no jury apportionment was required, and a dollar-for-dollar credit under section 33.012(c)(1) was proper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to settlement credit	No credit because jury did not apportion fault to settling defendants	One-satisfaction rule and Chapter 33 allow credit when plaintiff alleges a single indivisible injury	Credit allowed: pleadings showed an indivisible injury; Chapter 33 and one-satisfaction rule apply
Need for jury apportionment	Jury had to apportion responsibility to settling parties before credit	Apportionment not required; precedent and §33.012 permit credit even without listing settling parties	No apportionment prerequisite; credit may be applied without jury allocation (Mendez, Garrett)
Amount of credit (dollar-for-dollar vs allocated categories)	Credit should be limited by settlement’s per-category $6,000 allocations and only for categories the jury awarded	Dollar-for-dollar credit permitted under §33.012(c)(1) when defendant elects that option (or when no election is made by defendants)	Dollar-for-dollar credit proper here; defendants met burden by producing settlement; plaintiff failed to show allocation avoiding double recovery

Sky View at Las Palmas, LLC v. Mendez, 555 S.W.3d 101 (Tex. 2018) (one-satisfaction rule applies even without jury apportionment for indivisible injuries)
Crown Life Ins. Co. v. Casteel, 22 S.W.3d 378 (Tex. 2000) (explaining one-satisfaction rule)
First Title Co. of Waco v. Garrett, 860 S.W.2d 74 (Tex. 1993) (settlements offset judgment for indivisible injury to avoid double recovery)
Mobil Oil Corp. v. Ellender, 968 S.W.2d 917 (Tex. 1998) (trial court must reduce judgment by settlements; proof of settlement amount suffices)
Utts v. Short, 81 S.W.3d 822 (Tex. 2002) (burden shifts to plaintiff to show settlement allocation precluding credit)
GreCon, Inc. v. Caddell Constr. Co., 542 S.W.3d 774 (Tex. App.—Houston [14th Dist.] 2018) (settlement credits apply where plaintiff suffered single indivisible injury)
In re Liu, 290 S.W.3d 515 (Tex. App.—Texarkana 2009) (definition and test for indivisible injury)