Patricia Noonan, individually and in her capacity as of and on behalf of the beneficiaries of the Estate of William J. Noonan v. Sundersansan Sambandam, M.D., 296 A.3d 670

William Noonan died after treatment at Rhode Island Hospital; his executrix (Noonan) sued multiple medical defendants including Dr. Sundaresan T. Sambandam.
Plaintiffs settled with all codefendants except Sambandam and produced the settlement agreement with the dollar amount redacted.
Sambandam sought production of the complete, unredacted settlement agreement, arguing he needed the amount to calculate setoff under the Uniform Contribution Among Tortfeasors Act and to evaluate damages/settlement strategy.
A Superior Court justice granted Sambandam’s motion to compel production of the settlement amount; a conditional dismissal followed for plaintiffs’ noncompliance; plaintiffs petitioned for certiorari.
The Rhode Island Supreme Court quashed the Superior Court order, holding the settlement amount is not discoverable pre-verdict because it is inadmissible under Rule 408 and becomes relevant only after a plaintiff’s verdict for apportionment of damages.

Issue	Noonan's Argument	Sambandam's Argument	Held
Whether a nonsettling defendant may compel disclosure of the dollar amount in a settlement between plaintiff and settling codefendants	Settlement amount is inadmissible under R.I. Evid. 408 and not reasonably calculated to lead to admissible evidence pre-verdict; relevant only for setoff after judgment	Needs amount to evaluate potential setoff, damages exposure, and to negotiate/prepare trial strategy; fairness requires equal information	Quashed Superior Court order; settlement amount is not discoverable pre-verdict because inadmissible and relevant only for post-verdict apportionment of damages

DeCurtis v. Visconti, Boren & Campbell, Ltd., 152 A.3d 413 (R.I. 2017) (scope of Rule 26; de novo review of discovery scope)
Votolato v. Merandi, 747 A.2d 455 (R.I. 2000) (settlement evidence generally inadmissible; reductions made post-verdict)
Tempel v. Murphy, 30 A.3d 992 (Md. Ct. Spec. App. 2011) (settlement amounts not relevant pre-verdict; produced only after judgment)
Bennett v. La Pere, 112 F.R.D. 136 (D.R.I. 1986) (federal trial court compelled disclosure of settlement terms and amounts)
Porter Hayden Co. v. Bullinger, 713 A.2d 962 (Md. 1998) (apportionment of damages is a ministerial post-judgment act)
Fisher v. Lau, 291 A.3d 1261 (R.I. 2023) (trial court decisions must include reasoning to permit appellate review)