Reddy v. PMA Insurance
20 A.3d 1281
| Del. | 2011Background
- Ms. Spriggs, a severely disabled child, was placed in Harbor Health care; Harbor Health engaged Dr. Reddy as a consultant for her care.
- Ms. Spriggs’ scoliosis worsened over years due to irregular follow-up; surgery was recommended but not timely pursued.
- Ms. Spriggs died in 1998; Harbor Health settled related claims in 2006 and separately brought a contribution action against Dr. Reddy in 2008.
- Harbor Health sought contribution under the Uniform Contribution Act, arguing Delaware’s three-year limitations apply; Dr. Reddy contended the medical malpractice two-year limitation should apply.
- The Superior Court denied summary judgment on limitations and later denied Dr. Reddy’s JMOL on causation; a jury found Dr. Reddy negligent and liable for 25% of Harbor Health’s settlement, with the contribution action deemed timely.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What statute of limitations governs contribution claims? | Harbor Health argues three-year general limitation applies under Uniform Contribution Act. | Reddy argues medical malpractice two-year limitations apply. | Three-year limitations govern contribution; not controlled by the two-year medical act. |
| Is the contribution claim independently cognizable apart from the underlying medical negligence? | Contribution arises from joint liability and is independent of the underlying tort. | Contribution should be subsumed under medical malpractice limitations. | Contribution claim is independent; not subject to the medical malpractice two-year limit. |
| Does the absurd result principle apply to avoid an absurd outcome if the two-year limit controlled? | Applying two-year limit would yield an absurd result. | Strict reading of medical malpractice limits should control. | Absurd result principle prevents treating the contribution claim as within the two-year medical-malpractice framework. |
| Was the evidence sufficient to prove causation for contribution liability? | Failure to timely surgery would have proximately harmed Ms. Spriggs; expert and record support. | Unclear whether surgery would have been approved; causation uncertain. | Sufficient record evidence supports causation; jury verdict proper. |
Key Cases Cited
- Dambro v. Meyer, 974 A.2d 121 (Del. 2009) (distinguishes underlying tort limitations from contribution claims under the three-year period)
- Taylor v. Pontell, 3 A.3d 1099 (Del. 2010) (savings statute not applicable to medical malpractice claims and thus not extending time for plaintiff)
- Christiana Hospital v. Fattori, 714 A.2d 754 (Del. 1998) (savings statute not applicable to medical malpractice claims)
- Rowland v. Skaggs Cos., Inc., 666 S.W.2d 770 (Mo. 1984) (contribution accrues independently of underlying tort, not governed by the tort limitation)
- Duphily v. Del. Elec. Coop. Inc., 662 A.2d 821 (Del. 1995) (defines proximate causation as but-for causation in context of medical evidence)