On July 19, 2017, Diana Oxley visited Frederick Memorial Hospital’s emergency department with complaints of ongoing and worsening low back pain. She denied any recent falls and denied incontinence. On examination, Mrs. Oxley had normal strength in her lower extremities. She was diagnosed with nontraumatic back pain and, after a few hours, she improved in the emergency department and was released to receive physical therapy at home.

On July 31, 2017, a physician saw Mrs. Oxley following complaints of back pain and urinary incontinence. An MRI performed on August 1, 2017, revealed a “severe compression deformity” and “stenosis and disc protrusion” in her lumbar spine. Mrs. Oxley visited a spine surgeon on August 4, 2017, who prescribed to her a back brace that she “refuse[d] to wear,” and scheduled her for spine repair surgery to be conducted ten days later.

On August 19, 2017, Mrs. Oxley was evaluated at Meritus Medical Center’s emergency department for onset of generalized weakness, and told staff that “she ha[d] been falling several times a day due to her weakness.” The following day, she “requir[ed] ‘immediate medical intervention as a result of severe, life threatening, or potentially disabling conditions[,]” and resultantly was transferred to Johns Hopkins Medicine’s emergency department, where she was admitted as a patient.

Mrs. Oxley subsequently underwent spinal surgery on August 23, 2017. While recovering after the surgery in her hospital room, Mrs. Oxley fell when she attempted to move to the bathroom. Her right hip was fractured as a result of this fall, and corrective surgery was performed the following day.

The Oxleys filed a Maryland medical malpractice complaint on April 2, 2019, alleging medical malpractice during Mrs. Oxley’s July 19, 2017 emergency department visit. The Oxleys’ complaint contended that the defendants’ negligent failure to diagnose and order proper diagnostic testing, and negligent recommendation that Mrs. Oxley perform “light stretching and physical activity[,]” contributed to Mrs. Oxley’s development of cauda equina syndrome, conus medullaris syndrome, and permanent damages, including bowel and bladder incontinence, severe back and leg pain, numbness, and weakness.

While awaiting the rescheduled medical negligence trial, on May 1, 2021,—nearly four years after the alleged medical malpractice—Mrs. Oxley was involved in a motor vehicle accident resulting in multiple injuries, including a left hip fracture. Mrs. Oxley’s left hip was surgically repaired on May 2, 2021, and her medical records noted severe pain and “impaired mobility, ambulation[,] and activities of daily living secondary to left hip fracture[.]”

On November 6, 2023, Mrs. Oxley settled the motor vehicle negligence case for $100,000 by executing a “Full and Final Release of All Claims” (“Release”). The Release stated that it was “intended to cover all actions, causes of action, claims and demands for, upon or by reason of any damage, loss or injury which might appear at any time in the future, no matter how remotely they may be related to the aforesaid accident.” The Release did not mention or carve out exceptions for Mrs. Oxley’s then-pending medical negligence suit or any other injuries predating the May 1, 2021 motor vehicle accident.

The circuit court continued the medical negligence trial and ordered the parties to brief possible grounds for summary judgment following the parties’ revelation of the Release. The defendants moved for summary judgment on multiple grounds, including the one satisfaction rule. The circuit court ultimately concluded that the one satisfaction rule applied because the permanent damages were not apportionable, and, accordingly, granted summary judgment. The Oxleys appealed.

One Satisfaction Rule

For the one satisfaction rule to apply, which mandates that there can be but one satisfaction for the same injury, the unresolved negligence must flow legitimately as a natural and probable consequence of the satisfied injury. Under the one satisfaction rule, once the plaintiff has obtained a full satisfaction (i.e., an acceptance of full compensation for an injury), he or she is prevented from pursuing another who may be liable for the same damages. If the satisfaction only compensated the plaintiff for the injuries he or she sustained from the first-resolved action, the plaintiff’s claim for injuries that resulted from the unresolved action is not barred. If, however, the satisfaction compensated the plaintiff for all of the injuries he or she sustained from both incidents, the plaintiff’s unresolved claim is barred by the one satisfaction rule.

The Appellate Court of Maryland stated in its February 2, 2026 reported Opinion: “It is appropriate for a trial court to grant a motion for summary judgment based on the one satisfaction rule, even absent a full trial on the merits in the settled case, when “there [is] sufficient information before the trial court to compare the injuries that were satisfied by [a] [] settlement [agreement] with the injuries that [the plaintiff] claimed in the [unresolved action.]” … Viewing the evidence in the light most favorable to the Oxleys, we hold that the circuit court erred in applying the one satisfaction rule to the underlying medical malpractice action … The alleged medical malpractice occurred on July 19, 2017—nearly four years before the motor vehicle accident. Given the Release’s temporal limitation, we do not see how a plaintiff’s general settlement of claims “resulting from” or “arising out of” a 2021 accident makes that plaintiff whole for claims arising from a 2017 incident. Based on our review of the record, the circuit court did not consider whether the Release compensated for injuries arising before the May 1, 2021 motor vehicle accident … Mrs. Oxley could not possibly have sought to recover, in her November 2022 motor vehicle negligence case, for injuries she sustained in July
2017—nearly four years before the accident underlying the motor vehicle negligence case occurred.”

“The motor vehicle negligence Release was temporally limited to injuries arising from the May 1, 2021 accident; therefore, it could not have encompassed, and did not satisfy, claims for all injuries arising from the alleged malpractice in July 2017. Because the motor vehicle negligence Release did not represent a full satisfaction of the Oxleys’ medical negligence claims, we hold that the one satisfaction rule does not bar the medical negligence action from proceeding.”

Source Diana Oxley, et al. v. Frederick Memorial Hospital, et al., No. 1335, September Term, 2024.

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