Spangler v. McQuitty
36 A.3d 928
Md.2012Background
- McQuitty v. Spangler concerns informed consent duty and damages after the Maryland Court of Appeals’ McQuitty I decision.
- Plaintiffs Dylan McQuitty and his parents sued Dr. Donald Spangler for failure to obtain informed consent, resulting in birth injuries in 1995.
- Franklin Square Hospital settled early as to liability/damages; its joint-tortfeasor status was disputed by later releases.
- Dylan died before remittitur proceedings were resolved; post-trial motions sought reduction of future medical expenses and due-process relief.
- Trial court remitted under statutory caps and joint-tortfeasor provisions; Spangler sought further relief including post-judgment adjustments and interest.
- Appellate court held no due-process violation, affirmed finality of the future medical expense award, and addressed joint-tortfeasor and post-judgment-interest issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did McQuitty I change Maryland informed consent law? | McQuitty I changed the doctrine. | McQuitty I overruled prior law; required retrial. | McQuitty I did not substantively alter the law. |
| Should Dylan's death reduce future medical expenses after post-trial relief? | Death should not extinguish future medical damages, preserving finality. | Equity demands reducing to actual expenses. | Finality governs; no reduction absent a statute or annuity; no reversal for death. |
| Is Franklin Square Hospital a joint tortfeasor under the Uniform Act? | Hospital was a joint tortfeasor; its settlement should reduce Spangler’s liability. | Hospital was not a joint tortfeasor due to release terms and lack of adjudication. | Hospital was not a joint tortfeasor; no offset reduction against Spangler. |
| Can a settling defendant’s release reduce the nonsettling defendant’s judgment under the Uniform Act? | Release should operate to reduce damages via contribution. | Release terms prevent offset against nonsettling tortfeasor. | Release did not compel reduction against nonsettling tortfeasor. |
| From what date should post-judgment interest accrue? | Interest accrues from the original judgment date. | Interest accrues from a later post-remittitur judgment date. | Interest accrues from the original judgment date. |
Key Cases Cited
- McQuitty v. Spangler, 410 Md. 1 (Md. 2009) (McQuitty I; clarified informed consent without battery requirement)
- Davis v. Jellico Community Hospital, Inc., 912 F.2d 129 (6th Cir. 1990) (finality favored; post-trial damages not reopened for death)
- Boyd v. Bulala, 672 F. Supp. 915 (W.D.Va. 1987) (finality of judgment; avoid relief due to premature death)
- Porter Hayden Co. v. Bullinger, 350 Md. 452 (Md. 1998) (joint tort-feasor status; release and contribution rules)
- Jacobs v. Flynn, 131 Md. App. 342 (Md. App. 2000) (settlement admissions create joint-tortfeasor status under Uniform Act)
- Garrett v. Owens-Coming Fiberglas Corp., 343 Md. 500 (Md. 1996) (settling party status and contribution limitations)
- Swigert v. Welk, 213 Md. 613 (Md. 1957) (Uniform Contribution Act background on tort-feasor status)
- Collier v. Eagle-Picher Indus., Inc., 86 Md. App. 38 (Md. App. 1991) (principles on settlement offsets and joint liability)
- Reed v. Campagnolo, 332 Md. 226 (Md. 1993) (informed consent doctrine historically linked to negligence)